FCC proposes RMD filing for dialing platforms, call centers and cloud providers

The FCC’s Further Notice on the Robocall Mitigation Database (WC Docket Nos. 24-213 and 17-97, CG Docket No. 17-59), adopted July 22, was published in the Federal Register September 9. Comments are due October 9 and replies November 9. It proposes that “voice service provider” cover “all initiating, originating, intermediate, and terminating providers,” including “VoIP resellers and MVNOs,” and asks about extending the filing duty to “PBXs, dialing platforms, cloud service providers, over-the-top service providers, call centers, value-added-service providers, and telephone number service providers.” The RMD holds more than 11,000 filings.

New filing content would include a lack-of-candor certification, certification of compliance with the robocall rules in Part 64 subparts L, P and HH and Part 52, a US registered agent for service of process, and disclosure of third parties used for analytics, STIR/SHAKEN signing and KYC/KYUP. Providers claiming a STIR/SHAKEN exemption would have to explain it with “facts specific to its network and services.” A foreign voice service provider would be any entity incorporated outside the US, whatever its US operations. Mintz’s client alert also reads the item as replacing “reasonable steps” with “affirmative, effective measures” and requiring foreign adversary control attestations.

The scorecard proposal in CG Docket No. 26-239 would rate retail providers only. This item pulls entities that are not carriers into the database whose removal list blocks a filer’s traffic. Watch the Regulatory Watch dispatches as the October 9 comments land.