Carriers ask the FCC to finish the RMD rework before KYC and KYUP rules
CTIA comments, WC Docket No. 24-213 · source ↗
Initial comments on the FCC’s Robocall Mitigation Database further notice (FCC 26-49, WC Docket No. 24-213) were due October 9. The large carrier filers ask the Commission to finish the RMD rework before it acts in the separate KYC and know-your-upstream-provider proceedings. CTIA’s comments carry a section titled “The Commission Should Prioritize the RMD FNPRM Before Proceeding with Its KYC, KYUP, or Other Proceedings.” T-Mobile asks the FCC to “implement and evaluate those reforms before imposing additional prescriptive obligations proposed in other proceedings.”
USTelecom, which leads the Industry Traceback Group, backs Bureau review of filings before they publish and argues a stronger RMD “can more efficiently accomplish many of the objectives” behind the KYC and KYUP proposals. NCTA supports Commission vetting and wants the RMD changes coordinated with the KYC/KYUP proceedings rather than run on their own. INCOMPAS and the Cloud Communications Alliance want the RMD to be the single Commission-verified source of KYUP information, with a shot clock and a cure opportunity on pre-publication review, and oppose the broad reading of who must file. CTIA and INCOMPAS both want to keep the “reasonable steps” standard the notice proposes to replace with “affirmative, effective measures.” Numeracle proposes that the Bureau verify filings and that the STI-PA issue SPC tokens only to verified filers. ZipDX endorses that and adds a separate filing class for high-volume callers.
The KYUP proposals put the vetting of upstream traffic on each provider. RMD screening puts it on the Bureau. The filers asking for the RMD first are the providers the KYUP rules would bind. Replies are due November 9; the Regulatory Watch dispatches will follow them.