Week ending October 9, 2026

Comments on the Robocall Mitigation Database FNPRM were due October 9, and USTelecom, Numeracle and Ridgeway want the database to check who a filer is before it publishes anything. The Club for Growth comment round on AI-voice political calls closed October 5 with one supporting comment among the filed documents, and Commissioner Gomez came out against the petition on October 8. The October 29 agenda, also out October 8, carries an international Section 214 order with new ownership, cross-border and Covered List requirements, and an accessibility NPRM that asks about one-number service for relay users and accessible multi-factor authentication.

RMD comments: verify at the gate

USTelecom, Numeracle, Ridgeway and ICBA all back the proposal in paragraph 69 of FCC 26-49: a filing does not “appear” in the database until the Bureau has accepted and published it. USTelecom, Numeracle and ACA Connects filed on October 9.

USTelecom’s comments, signed by Kathleen Slattery Thompson and Nirali Patel, support pre-publication review and the Bureau’s authority to hold filings in pending status: “Publication in the RMD should mean more than the filer successfully submitted information to the Commission.” USTelecom, which leads the Industry Traceback Group, wants the strengthened database to do double duty for the KYC and KYUP proposals, so downstream providers can rely on an active listing instead of collecting the same records from every upstream provider. It supports a one-step removal for “clear impersonation or identity theft, direct evasion of an existing removal order, fraudulent use of another provider’s identifiers, or knowingly false identity information,” opposes raw traceback counts as a removal trigger, and asks for liability protection for good-faith blocking: “The RMD should establish an authoritative regulatory floor, not a ceiling on responsible mitigation practices.” It also opposes requiring a particular automated traceback process as a condition of listing.

Numeracle, through general counsel Keith Buell, puts numbers on the problem from the FNPRM itself: “although 6,689 RMD filings indicate full or partial STIR/SHAKEN implementation, only 2,143 providers appear on the Governance Authority’s list of authorized providers.” Its diagnosis is that “the RMD accepts whatever it is told,” and that each of the six checkpoints a new provider passes (FRN, Form 499 ID, OCN, SPC token, traffic agreements, RMD filing) “largely registers what the applicant says about itself.” Numeracle proposes verifying legal existence, beneficial owners and human principals once, at the RMD publication gate, with the STI-PA issuing SPC tokens only to providers with a published, verified filing, and a 30-day shot clock on pending filings. On the FNPRM’s question of whether NANPA could vet applicants, it prefers accredited independent verifiers or a designated RMD Administrator: “Trust decisions should be made by parties who do not profit from the answer.” It acknowledges that Numeracle, “like its competitors, could provide such services.” It also asks that foreign filers be allowed to list the authentication frameworks they participate in, naming Non-Jurisdictional Governance Authorities under the STI-GA and GSMA’s Open Verifiable Communications.

Ridgeway Telecommunications, which describes itself as a candidate STI Certification Authority working through STI-PA approval, filed 60 pages built on its own review of the database. It counts 890 filings still claiming the long-expired small-provider STIR/SHAKEN extension, and finds that of 4,860 filings certifying complete implementation, 2,931 report no OCN. Ridgeway wants filers that certify implementation to upload their STI certificate, with the RMD checking it against the Policy Administrator’s lists of approved CAs and revoked certificates and refusing one whose SPC does not match the filer’s OCN. It opposes letters of credit in favor of a KYUP record naming which provider vetted each filer. It takes no position on an external RMD Administrator, but suggests one could be funded partly through charges for optional services, “adapting the Reassigned Numbers Database model.”

ACA Connects supports “trust, but verify” for new filers and opposes most of the rest on behalf of its roughly 500 small and midsized members: no removal for a non-material deficiency or a single missed traceback, no quarterly recertification, no letter-of-credit requirement for established providers, and no copies of government ID or “photographs of principals holding that identification” in routine filings. The Independent Community Bankers of America, whose members could issue those letters of credit, says issuing one “should remain voluntary” and that “a letter of credit does not make a bank responsible for a provider’s conduct.”

Three filers pushed back on putting numbering resources in the RMD. 10x People, whose founder Lisa Marie Maxson worked on the original NPAC messaging specifications, says number-block data in a static filing “will become obsolete upon the first update” and points the Commission to the NPAC instead. Sonera says providers with direct numbering access already report to NANPA and “The RMD should not become a parallel numbering resource database.” ACA Connects asks that a reseller not have to certify a wholesale carrier’s number inventory.

Mitel, through Jonathan Marashlian, argues that “providing the technology used to facilitate a call is not the same as furnishing the underlying PSTN-connected voice service” and asks for a call-specific functional test. IPtelX and DICE Corporation ask that alarm monitoring centers be treated as end users, that life-safety customers of a removed provider get notice before downstream blocking starts, and that authenticated alarm verification calls get the same protection as PSAP calls; DICE says it is an onboarding and vetting agent in CTIA’s Branded Calling ID program. Ashdi LLC, which prepares RMD filings for small providers as VoiceFiling, supports third-party preparation with a non-delegable officer declaration.

On October 5 the Enforcement Bureau released DA 26-1073, which removes Digital Solutions Inc. from the RMD and orders downstream providers to block its traffic starting 30 days after release, after an April 2 notice and a June 29 initial determination order. The company cured one of two RMD deficiencies, left the other, and did not supply the required information about the suspected illegal traffic it originated.

ClearCaptions told the Chairman’s office, Commissioner Gomez’s office and CGB leadership on October 6 that “some third-party companies that carriers use appear to be identifying calls from new ClearCaptions customers as possible spam or fraud calls.” ClearCaptions says its average customer is eighty years old.

Club for Growth: one comment in favor

The round under DA 26-940 closed October 5. Between October 5 and 9, 126 express comments were filed in CG 02-278 and CG 23-362, the AI-robocall docket. About twenty comments on the petition came with attached documents. The only one supporting the petition is from the Center for American Rights, signed by Daniel Suhr, which asks the Commission to use its Section 227(b)(2)(C) authority for a conditioned exemption modeled on the package-delivery, healthcare and financial-institution exemptions: “Adopting the Club’s petition would ensure fair treatment for political speakers in a technology-neutral way.”

The opposition from the National Consumer Law Center was joined by thirteen groups, among them The Leadership Conference, Consumer Federation of America, Common Cause, Public Citizen and NAVA, the National Association of Voice Actors. NCLC says the petition’s three-calls-per-month limit and ten-day stop window “are illusory as they would only apply to an individual caller,” with no limit on the number of campaigns, PACs and nonprofits that could each call. It argues the statute itself blocks the exemption: Section 227(b)(2)(C) requires exempted calls to be “not charged to the called party,” and the petition offers no way to identify prepaid and per-minute cell plans. On AI specifically, it says an AI chatbot call cannot be fully vetted before it is placed because the content changes with the recipient’s responses.

Joe Shields, whose own autodialer petition shares the notice, called the Club for Growth petition “absurd.” Vincent Lucas filed Google AI Mode’s answer to whether people want AI-generated political calls.

Commissioner Gomez issued a statement on October 8: granting the petition would “unleash a deluge of political AI slop on their phones.” The release notes that replies are due October 19, “just 15 days before Election Day,” and that the February 2024 ruling that AI-generated voice calls are artificial voice under the TCPA could only be reversed by a vote of the full Commission.

All-IP: AT&T asks to finish 8YY bill-and-keep

AT&T’s Brian Benison filed a letter in WC 25-304 and 25-311 on October 6 asking for two cleanups. First, end the equal-access obligation grandfathered in the 2015 USTelecom forbearance order, which AT&T says requires incumbents to keep legacy tandems and routing “even if only a single grandfathered customer remains.” Second, move the remaining toll-free intercarrier charges to bill-and-keep. AT&T estimates from NECA data that rural LECs’ annual originating access revenues fell from $30.3 million in 2020 to under $300,000, while toll-free minutes fell by about two thirds. Its complaint is with the carriers in the middle: “Yet some carriers refuse to deliver toll-free traffic over IP. They instead convert it to TDM so that it can be routed through one or more intermediate carriers that share access charge revenue with them.”

Inteliquent took the National Transit Provider case to the Chairman’s office. Former Commissioner Harold Furchtgott-Roth and Tamar Finn of Cooley met Keelin Ferris on October 1. The letter argues that connections on the public internet “are subject both to potential congestion on busy networks and to cybersecurity threats,” and dedicated fiber to an NTP is not.

Mitchell and Pamela Smith of Piney View, West Virginia, wrote in WC 25-209 that Frontier is discontinuing the copper line serving their home, that cell coverage there is unreliable even with Starlink-assisted Wi-Fi calling, and that Frontier was funded about two years ago to run fiber to a point less than 600 feet from their house but has not connected them. Frontier’s notice, as they quote it, says they “will have the opportunity to switch to service delivered using fiber, cable, or modern wireless technology.” Nine express comments were also filed in WC 25-209 this week. The FCC 26-19 discontinuance rules take effect October 15.

On 911, Viiz Communications CEO Norm Phipps and Howard Waltzman of Mayer Brown met PSHSB staff and advisors to Chairman Carr and Commissioners Trusty and Gomez on October 5 to ask for a public notice on Viiz’s September 8 petition. Viiz wants a safe harbor under the 911 outage-notification rules for originating providers that use a third-party PSAP contact database covering at least 95 percent of PSAPs in their territory. It says its own covers 98.8 percent of PSAPs nationwide.

October 29 agenda: Section 214 conditions and relay numbering

The Evolving Risks Report and Order and FNPRM (IB 23-119) rewrites the international Section 214 framework. Applicants and holders would report cross-border facilities on the Mexico and Canada borders, report ownership at a 5 percent threshold, disclose use of foreign-adversary-controlled service providers, adopt baseline cybersecurity practices, and stop using or adding equipment or services on the Covered List. Discontinuance filings would have to say whether the holder is surrendering International Signaling Point Codes. The draft also starts revocation of authorizations held by companies that ignored the earlier Evolving Risks one-time collection: about 1,235 of roughly 7,000 holders responded. The FNPRM proposes a presumption against grant for a range of untrusted applicants.

The Eliminating Accessibility Barriers NPRM (CG 10-213, 03-123, GN 21-140) proposes streamlining rules it describes as duplicative or outdated, and asks about three specific barriers. On numbering, it notes that VRS and IP Relay users “must maintain two telephone numbers; one for TRS calls and one for their wireless device for text-based communications, including RCS, SMS, and RTT,” and that misdirected messages break automated reminders, confirmations and authorizations. On identity, it asks “whether alternative identity and security verification methods are available or possible to address accessibility barriers while maintaining critical security protections,” whether authentication counts as part of a covered service, and how far FCC authority over it reaches. It also asks about Direct Video Calling for customer service. The background puts TTY usage at more than 6.4 million minutes in 2010 and a projected 658,000 for the 2025-2026 fund year.

The agenda also carries a Rural Broadband Protection Act NPRM on vetting USF applicants (WC 10-90, 26-96, 26-288).

Honorable mentions

Ken Westbrook of the Stop Scams Alliance sent materials Mr. Delacourt of the FCC requested at the September 30 Communications Fraud Control Association conference: the September 2026 Ofcom and Comms Council UK guidance on sharing fraud data, and the Gallup survey estimating Americans lost about $68 billion to scams in 2025, more than four times the losses reported to the FTC.

The Wireline Bureau conditionally granted RRD term extensions to 14 rip-and-replace recipients on October 9, with added reporting conditions; nine carriers filed 14 extension requests in WC 18-89 during the week.

PSHSB recognized A2LA and ANAB as accreditation bodies for Cyber Trust Mark label administrators and test labs on September 28.

Looking ahead

The FCC 26-19 discontinuance and network-change rules take effect October 15, and customer objections start landing in WC 26-214. Club for Growth replies are due October 19. The Sunshine notice for the October 29 meeting should come about a week before it. RMD FNPRM replies are due November 9; comments filed late on the October 9 deadline will post to ECFS early next week.