47 State AGs, Others Urge FCC Action on Improving Robocall Mitigation Database
Attorneys general of 46 states and the District of Columbia urged the FCC to proceed with its proposed revisions to the robocall mitigation database (RMD). In reply comments posted Wednesday in docket 24-213 (see 2410160037), several industry groups also backed the proposal and sought some changes that will ensure information filed by providers is as accurate as possible.
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The AGs said the database is "an essential resource" for states' efforts at combating illegal robocalls and raised concerns about "clearly false" information providers submitted. Inaccurate information in the database "demonstrates contempt for the commission's requirements and the consumers those requirements protect," the AGs said. The coalition asked the FCC to "consider embedding clarifying information into the process" of submitting filings and strengthening its rules on commission registration system (CORES) submissions. "Harmonizing the information in CORES and the RMD will reduce confusion" and improve accuracy of both databases, the AGs said.
The AGs also backed the FCC's proposal requiring that providers pay a filing fee for RMD submissions. "Imposing a fee will discourage filings by bad actors." The coalition suggested that fees be limited to new submissions and not when an entry is edited. "Providers should not be disincentivized to make frequent updates," ensuring their information is as current as possible.
The database "should be a high-integrity database that stakeholders can use as they onboard and interact with registered providers," said ZipDX. The provider backed iconectiv's call for automated validation of submissions. It also suggested human reviewers when automation isn't as practical. "However it gets done, the data in the RMD needs to be trustworthy," ZipDX said. The provider agreed with public interest groups' suggestion that facially deficient filings be rejected "before they are ever made active."
In joint comments, the Electronic Privacy Information Center, CTIA, USTelecom, National Consumers League and Public Knowledge said, "Addressing deficient filings already in the RMD, and expeditiously removing those filers, is the best way the commission can ensure the effectiveness of the RMD." The database is "meant to serve as a resource for regulators and entities in the voice ecosystem," they added, which helps ensure providers with facially deficient filings can't authenticate calls. The coalition also opposed implementing additional authentication measures or filing fees for database access.
ZipDX said it opposed using a personal identification number to improve data integrity. It added, "To the extent that something like filing fees proves contentious, we suggest that it be set aside, because it is not likely to have a very big effect in achieving our mutual overall objectives."
"Strengthening the robocall mitigation database so that it contains fulsome and accurate filings providers and greater functionality" is "an important part of our government's overall strategy to combat fraud perpetrated through illegal phone calls," said the American Bankers' Association. ABA urged a "whole of government" approach to combating illegal robocalls.