Week ending September 4, 2026

The Enforcement Bureau pulled fourteen companies’ certifications from the Robocall Mitigation Database this week, and the Consumer and Governmental Affairs Bureau proposed publishing a public scorecard rating voice providers on how well they keep illegal robocalls off their networks. Separately, a run of ex parte filings put dollar figures on what the all-IP transition is doing to 911 circuit pricing, and a new reply comment filled out the record on direct video calling to 911.

Robocall enforcement gets teeth, and a scorecard to go with it

The Enforcement Bureau’s September 2 order (DA 26-872) removed the Robocall Mitigation Database certifications of fourteen companies, effective on release. The order traces back to a March 24 show-cause order that gave thirty-five companies a chance to cure deficient RMD certifications or explain why the Bureau shouldn’t act; these fourteen did neither. Under the order, every intermediate provider and voice service provider had two business days to stop accepting traffic directly from the companies, which include Skycom Healthcare, Reachme.com, Conference America, and Dixie Net Communications. None of the fourteen may refile without joint sign-off from the Enforcement Bureau and the Wireline Competition Bureau.

The same day, CGB released a Public Notice (DA 26-932) opening a new docket, CG 26-239, to seek comment on a “Robocall Mitigation Scorecard.” The Bureau proposes rating only domestic retail voice providers — not wholesale or intermediate providers — across wireless, wireline, and VoIP, using a threshold pegged to market share rather than every provider in the country. The notice is careful about what the Scorecard is not: “It will not be an indication of whether providers have or have not complied with the Commission’s robocall rules — that is a case-specific legal inquiry.” Comments are due September 22, replies October 2.

Fifty-two state and territorial bankers associations wrote Chairman Carr on September 3 to back the pending KYC/KYUP rulemaking in WC 17-59, CG 02-278, and WC 17-97. Their letter names the mechanism precisely: “When an originating provider improperly provides an ‘A-level’ attestation to a call, it may lead a terminating provider to apply a green checkmark or other signal indicating (falsely) the number is not illegally spoofed.” The letter asks the Commission to finalize both the originating-provider know-your-customer requirement and the downstream know-your-upstream-provider requirement “without delay.”

The FTC brought its own know-your-customer case the same week. On September 4 it settled with payment processor Nuvei for $4.85 million over merchant accounts it “knew or should have known” were running scams, including $30 million processed for the tech-support scam Reimage between 2017 and 2023. The complaint charges Nuvei under the Telemarketing Sales Rule as well as the FTC Act.

CGB also sought comment (DA 26-940) on September 4 on two petitions in CG 02-278. Club for Growth, through COO and general counsel Michael Donnelly, wants a limited waiver of § 64.1200(a)(1)(iii) and an exemption from § 227(b)(1)(A)(iii) so that noncommercial political calls can reach wireless numbers “using an artificial or prerecorded voice—including an AI-generated voice—without obtaining prior express consent.” It offers the conditions already applied to noncommercial prerecorded calls to residential lines, plus the statutory bar on charging the called party. The argument is the asymmetry between landline and wireless treatment, framed as a content-based restriction under Barr v. American Association of Political Consultants, and tied to both Delete-Delete-Delete and the Administration’s AI Action Plan. The 501(c)(4) says AI calling tools would let it reach voters “in more languages,” and it wants a ruling before the November 3 midterms. The same notice carries Joe Shields’ petition asking the Commission to declare that a P2P system “that uses a perfunctory human being for the sole purpose of clicking on a ‘send’ or similarly termed button to transmit thousands of text messages per hour is an autodialer under the TCPA.” Comments are due October 5, replies October 19.

The all-IP transition’s still-open 911 and pricing questions

Bandwidth and its CLEC subsidiary, through Cooley’s Tamar Finn, told the Commission on August 28 that Lumen has started billing Bandwidth business data service rates for TDM trunks that carry 911 traffic to Lumen’s selective routers — trunks Bandwidth says it has always paid local exchange and switched access rates for under Lumen’s obligations as a 1996-Act incumbent. The filing puts a number on it: a T1 circuit in Boise, Idaho went from $17.22 a month in August 2025 to $32,291.98 a month in December 2025. Bandwidth says the pricing shift has forced it to reroute some 911 traffic to emergency call center operators and, in one market, port customers to Level 3 — an affiliate of the incumbent — because it had no other viable path to the local calling area. SDN Communications’ Jody Kalt described a similar circuit-pricing jump at the July IP Transition Workshop, calling it “a canary in the coal mine of what happens when there’s not oversight by the FCC.” The letter is filed in WC 25-304 and PS 21-479 and asks the Commission to examine whether incumbent LECs are discriminating against competitors in favor of their own affiliates during the TDM-to-IP migration.

INCOMPAS’s September 1 letter, covering the same July workshops, reads the record as showing USTelecom’s “ALIII” (Agreement-less IP Interconnection over the Internet) proposal isn’t technically ready. Panelists couldn’t explain how 911 traffic would be handled under an ALIII architecture or whether dedicated paths would be required. ATIS’s standards work has a December 31, 2028 target, the same date the Commission has floated for completing the transition — INCOMPAS estimates, based on its own STIR/SHAKEN experience, that “the standards process and implementation could take approximately six years,” well past that date. Rural carriers told the workshops they can’t quantify their transit-cost exposure under ALIII, especially if the Commission simultaneously ends CAF-ICC support and moves remaining intercarrier compensation to bill-and-keep. INCOMPAS lists the compounding pressures rural carriers raised: rising BDS prices, incumbents refusing IP interconnection at tandems, and a lack of competitive alternatives in many regions.

The DVC-to-911 record breaks one way

International Deaf Emergency’s September 3 reply comments in PS 21-479 and PS 13-75 survey the initial round on direct video calling to 911 and find no commenter opposing it on the merits. The Accessibility Organizations — TDIforAccess, the National Association of the Deaf, the Hearing Loss Association of America, Deaf Equality, Deaf Seniors of America, the DHH-RERC at Gallaudet, and accesSOS — ask the Commission to establish a DVC-to-911 pilot; Communication Service for the Deaf filed the most detailed design, an 18-to-24-month timeline with a measurement plan. Sorenson Communications, the largest VRS provider, “strongly supports the accessibility community’s request for DVC-to-911 with call takers who are fluent in ASL,” and says it would consider participating in a pilot. Intrado devotes a full section of its comments to backing a “structured pilot program, limited to DVC,” citing two years of prior pilot work with CSD. NENA and the joint iCERT/NASNA comments ask the Commission to wait for CSRIC X guidance and question its authority to impose operational requirements on 911 authorities directly — but NENA’s own filing says it “supports the implementation of multimedia calling capabilities for 9-1-1, including video, in the near term.” IDE points to the numbers behind the demand: nearly 30,000 DVC calls to the 988 Suicide & Crisis Lifeline in its first ten months, and a CSD FOIA-released figure of roughly 55,000 VRS calls placed to 911 in 2025.

AT&T’s September 1 petition in the same docket cluster, plus PS 25-143, asks for a limited waiver of the default NG911 implementation timeline — but only for its legacy TDM incumbent and competitive wireline services, pushing that deadline to September 30, 2026 or February 28, 2027 depending on jurisdiction. AT&T’s petition lists completed NG911 Phase 1 requests covering 1,496 PSAPs on business VoIP, 1,548 on consumer VoIP, 886 on AT&T Phone – Advanced, and 1,548 on AT&T Phone Business – Advanced.

High-Cost reform’s reply round splits along predictable lines

Reply comments closed September 3 in WC 26-96 (“Reforming the High-Cost Program for an All-IP Future”) and WC 10-90, drawing two dozen filings from NCTA, NTCA, WISPA, the Fiber Broadband Association, ITI, SIIA, the National Tribal Telecommunications Association, several state and regional rural coalitions, and TechFreedom, among others. NTCA’s reply argues the record “overwhelmingly supports a High-Cost mechanism capable of sustaining rural networks and the services they enable,” and says the Commission should act before the end of 2026 to extend A-CAM I at existing support levels through December 31, 2028. TechFreedom’s reply, filed under the heading “We Ignore the ‘Negroponte Switch’ at our Peril,” takes the opposite view: the current program costs $4.5 billion a year against $42.5 billion already moving through BEAD outside High-Cost mechanisms, and the record shows “clear attempts by incumbent carriers to maintain as much High Cost support as possible, basically oblivious to the satellite revolution going on above their heads.”

Honorable mentions

The Wireline Competition Bureau issued two Rip-and-Replace Program public notices in WC 18-89 on September 3: DA 26-936 conditionally grants four recipients’ requests for extended removal-replacement-disposal terms, and DA 26-937 clarifies that administrative costs incurred between a recipient’s RRD deadline and its reimbursement-claim deadline remain eligible for reimbursement. CORES opened for FY2026 regulatory fee payments this week under MD Docket 26-94, due September 24.

Looking ahead

Comments on the Robocall Mitigation Scorecard (CG 26-239) are due September 22, replies October 2. Comments on the Club for Growth and Shields petitions in CG 02-278 are due October 5, replies October 19 — the Club has asked for a ruling before November 3, which would require the Commission to move inside two weeks of the reply date. The DVC-to-911 reply round in PS 21-479 and PS 13-75 closes September 8, which should bring NENA, Intrado, and the Accessibility Organizations back with responses to each other’s initial filings. FY2026 regulatory fee payments are due September 24. The ATIS standards process for ALIII continues toward its December 31, 2028 target, the same deadline the Commission has set for completing the all-IP transition.