Week ending October 16, 2026

The rest of the October 9 comments on the Robocall Mitigation Database FNPRM posted this week. CTIA, T-Mobile, NCTA, and INCOMPAS with the Cloud Communications Alliance all back Bureau review of a filing before it appears in the database. Commenters split on who has to file, how fast removal should cut off traffic, and whether numbering data belongs in the database. On October 16 the Enforcement Bureau removed Mexico IP Phone from the RMD after finding that it sent NANPA a forged FCC numbering authorization. Club for Growth replies are due Monday.

RMD comments: the carriers back the gate

CTIA and T-Mobile both ask the Commission to finish the RMD FNPRM (FCC 26-49) before it acts on the KYC and KYUP proposals. CTIA, through Sarah Leggin, Scott Bergmann and Courtney Tolerico, supports the paragraph 69 rule that a filing does not appear until accepted: “Making the RMD entry process more like an application and review process will provide strong protections against bad actors gaining access to the voice network.” It adds risk factors for the Bureau to check, among them online presence, company and officer age, and identifiers shared with a removed provider. It says a letter of credit is unnecessary if the Bureau vets filers itself, and that the filing fee would be too. T-Mobile wants filing statuses, an API, a searchable status history and a good-faith safe harbor for relying on them: “Downstream voice service providers should not be required to independently reconstruct or verify the information underlying the Commission’s RMD status determination.” It opposes financial assurances and photo ID for principals, and wants the two-business-day cutoff after a removal kept as the default, with Enforcement Bureau discretion to allow more time.

NCTA, through Steven Morris and Callie Coker, describes the current database this way: “The presence of a provider in the RMD means relatively little, as there is little keeping bad actors from filing in the RMD in the first instance.” It supports front-end vetting, would let SEC-reporting companies satisfy ownership disclosures by cross-reference, and would limit any letter of credit to providers with a removal history or less than a year of operation. INCOMPAS and the Cloud Communications Alliance, signed by Christopher Shipley and Joe Marion, want the RMD to be the single Commission-verified source of KYUP information, replacing bilateral collection rather than adding to it, with a safe harbor for any provider that accepts traffic from a filer that is published and active at the time of the call. They oppose cutting the two-step removal response window from 10 days to five, and support the temporary exemption for providers awaiting an SPC token, since new entrants “cannot obtain a token without an RMD filing and cannot complete a compliant RMD filing without a token.”

The scope fight is over paragraph 14, which would read “voice service” to cover PBXs, call centers, dialing platforms, cloud and over-the-top services, and telephone number service providers. CTIA, T-Mobile, INCOMPAS, VON and ACA International oppose it. INCOMPAS proposes a functional test that puts the filing obligation on whoever furnishes the PSTN interconnection. VON, through Glenn Richards, says the database already holds nearly 11,000 filings, many from companies filing out of caution. ACA International, for the collections industry: “call centers do not furnish voice communications to end users, they are end users.” Bandwidth, which requires a valid RMD filing from every voice reseller customer, comes at it from the other side. It warns of “increasingly widespread beliefs among VSPs that creative legal arguments to not register at all in the RMD are a path to avoiding regulatory burdens,” and wants a field where an entity explains why it does not have to file, with the Commission deciding disputes. Bandwidth also wants participation in the ITG’s automated traceback process made a condition of listing.

The two consumer app providers split on how removal should work. TextNow, signed by COO Lindsay Gibson, wants the “repeated appearance in tracebacks” removal cause deleted or conditioned on notice: “appearances scale with users, not wrongdoing.” It wants at least 15 business days between a removal order and the downstream cutoff. Pinger, signed by CEO Greg Woock, wants the current two business days codified, a traceback cause that applies when a provider was the originating or gateway provider in three or more tracebacks within 30 days and did not investigate or act, and ITG warnings sent to providers that are not consortium members: “A warning withheld from a non-member stops nothing.” CTIA, T-Mobile, INCOMPAS, VON, TextNow and Pinger all oppose using RMD status to block text messages.

Most commenters that addressed letters of credit would limit them to previously removed or new filers. WISPA, whose members mostly have between 500 and 50,000 broadband subscribers, opposes a universal requirement. ZipDX’s David Frankel proposes two filing tiers instead: new and updated filers would start without a “high-volume badge,” earn it through further vetting, and until then downstream providers would have to enforce a traffic limit on them, with 10,000 calls an hour as the suggested threshold. He says “a few dozen” providers are responsible for a significant fraction of robocalls at any given time.

Numbering data, and a forged authorization NANPA caught

DA 26-1116, released October 16, removes Mexico IP Phone LLC from the RMD and orders all providers to stop accepting its traffic within two business days. On February 4 the company filed an “Application for Authorization to Obtain Direct Access to Telephone Numbers” straight into the WC 13-97 rulemaking docket, with no fee and not in the designated inbox, and its CEO, Hemant Kumar Bharti, emailed NANPA Support the same day to start getting numbers. Two days later he sent NANPA a “Notice of Interconnected VoIP Numbering Authorizations Granted” numbered DA 26-8. The Wireline Bureau’s real DA 26-8 had granted authorization to an unrelated company, DayStarr, on January 2; the texts matched except for the name, dockets and dates. NANPA Vice President Florence Weber asked the Bureau to confirm on February 25. The answer from Wireline staff: “They [Mexico IP] have not been approved and they have never even applied. The public notice attached appears to be falsified.”

The company blamed a Malaysia-based freelancer it said it hired on Fiverr as “Lance Lee” and paid in cryptocurrency, and could produce no contact information for him. The state AG task force had already placed Mexico IP immediately downstream of non-responsive providers in at least 40 tracebacks. Bharti declined to come to Washington, citing international travel, although the RMD filing lists an Albuquerque address, and the Bureau says that indicates the company has no physical presence in the United States. The order also notes that Carrier Upgrade LLC filed a numbering request “in a similar letter format” on February 5.

The comment record mostly wants numbering data kept out of the RMD. ATIS, for its Industry Numbering Committee, says block-level data would be outdated “almost immediately after submission,” that the Commission already gets it through NRUF, and that numbering data “should not be repurposed for unrelated regulatory, enforcement, or competitive purposes.” INC does say removal from the RMD “would warrant the withholding and reclamation of numbering resources.” T-Mobile, INCOMPAS, TextNow and Pinger oppose numbering disclosures beyond, at most, a non-public direct-or-indirect indicator. Bandwidth says the Commission is already considering the future role of number administration in the IP transition proceeding and should not add numbering reporting here.

CallerAPI wants NANPA data used differently. CEO Dmitry Bazarov proposes that anyone with a CORES account be able to upload a PASSporT, and that the RMD automatically record an A-level attestation for an invalid or unallocated number against the filing whose certificate signed it, after checking the signature, the certificate chain, the SPC and NANPA’s allocation status: “An A-level attestation for such a number shows, in the signer’s own signature, that it vouched for a number that no one can hold.” The filing would show a 12-month count of unexplained records. The STI-GA says its policies let affiliates share one account and SPC token and it would oppose changing that. It is willing to give the Commission authorized providers’ OCNs on a non-public basis but cannot publish them, since OCNs are NECA’s. It already directs the STI-PA to revoke tokens and certificates when the Commission orders a removal, and it proposes a NANC-like advisory council for robocall issues.

Callers who get mislabeled ask for identity-based protection

IPtelX and DICE answered the KYUP FNPRM’s question (FCC 26-32, paragraph 130) about public-safety exceptions beyond 988 with alarm monitoring. Scott Tabor of IPtelX and Clifford Dice say verification calls are short, high-volume and placed from small number pools, so analytics engines label them as spam, and that monitoring centers pay analytics vendors so lawful, often state-required calls get through: “No caller should have to buy back the deliverability of an emergency-related call.” They propose protection conditioned on verified identity: A-level attestation from a provider with a verified association to the number or a TN-scoped delegate certificate (ATIS-1000092), Rich Call Data (ATIS-1000094), and Branded Calling ID vetting, which DICE performs. They also say most alarm signals arrive over analog lines, so a mandate to block unsigned SIP calls “is, for this traffic, a mandate to block most alarm signals.”

ClearCaptions made its case again on October 14, this time to Marcus Maher, senior legal advisor to Commissioner Trusty, with Michael Strecker, Neil Kraetsch and Tamar Finn of Cooley. It repeated that analytics firms used by carriers are labeling calls from new customers as possible spam, and argued that “Layering additional know your customer and know your upstream provider obligations on regulated iTRS providers is unnecessary.” It says IP CTS providers already collect name, date of birth, the last four SSN digits and a hearing-loss self-certification.

Box Commons, a Wyoming nonprofit standards body, filed an early reply proposing voluntary independent assessments of mitigation programs, recorded in structured RMD fields, and an optional field for call-audio authenticity measures, with C2PA content credentials carried in a PASSporT extension as one option: “STIR/SHAKEN verifies the right to use a number, not the voice on the call.” Brice Love discloses that Box Commons could seek to act as an assessment body.

Club for Growth replies arrive ahead of Monday

Every Club for Growth reply filed with a document this week opposes the petition. Charles Becker of StillFaxing.com, which lends out about 450 fax numbers and pays for every call they receive, argues that the exemption fails Section 227(b)(2)(C) because the petition only agrees to the not-charged condition: “Agreeing to the condition is not the showing the Commission has required.” He asks the Bureau to refer the petition to the full Commission if it does not deny it. Mark Dobronski works through the per-caller limit: “twenty separately counted organizations making three calls each would produce sixty calls in thirty days.” In a second reply he supports Joe Shields’s petition and argues that a human’s final button press should not take a P2P texting platform outside the ATDS definition. Solutions by Jewel says the petition borrows conditions written for prerecorded messages and “proposes no disclosure condition, no record of what the AI agent says and no limit on what the AI agent may say,” and lists six conditions any future AI political-call request should meet. Thirty-one express comments were filed in CG 02-278 between October 9 and 16.

Honorable mentions

The FCC, Ofcom, Canada’s ISED, Australia’s Department of Home Affairs and New Zealand’s NCSC issued a joint statement after their third annual convening on October 16, committing to quarterly coordination meetings and to work on scams and fraud, AI and communications security, and threats such as Salt Typhoon.

Michael Neely filed an early RMD reply built on the 2024 New Hampshire voice-clone calls, supporting impersonation as a codified removal cause and one-step removal for egregious cases.

Damini Sood filed cost modeling in the onshoring NPRM (CG 26-52): a modeled $14.95 per solved problem for a tiered Philippine operation against $14.52 for a 50-seat rural U.S. hub. The letter says the results come from a model and have not been measured in the field.

Five customer comments were filed in WC 26-214, the discontinuance docket, between October 9 and 16, and five express comments in WC 25-209.

Looking ahead

Club for Growth and Shields replies are due October 19. Providers must stop accepting Mexico IP Phone traffic by October 20. The Sunshine notice for the October 29 meeting, with the Evolving Risks order and the accessibility NPRM, should be out around October 22. RMD FNPRM replies are due November 9.