Compliance news

FCC & telecom compliance news.

Short summaries of FCC rulemakings, enforcement actions and robocall developments — with what each one means for a provider running traffic on its own switch.

Enforcement

State attorneys general press the FCC to require upstream provider vetting

Attorneys general from 49 states filed comments asking the Commission to make vetting of upstream providers a binding obligation for voice providers, pointing to their own multistate robocall enforcement work.

The states' task force has been sending warning letters to smaller providers in parallel with FCC action. Their position is that voluntary diligence has not been enough.

What it means for your network

State and federal pressure now point the same way. Assume know-your-upstream-provider checks will become mandatory and start building the records to prove you do them.

Source: Regulatory Oversight

Robocall Mitigation Database

FCC proposes a broad expansion of Robocall Mitigation Database requirements

A Further Notice of Proposed Rulemaking would make the RMD a stronger gatekeeping tool, with stricter requirements for the accuracy, completeness and currency of provider filings.

It continues the Commission's strategy of removing bad actors from the database and relying on carriers to refuse traffic from unlisted providers.

What it means for your network

Give your RMD certification an owner and a review schedule. The direction of travel is that an inaccurate filing alone could be enough to lose network access.

Source: Mintz

Robocall Mitigation Database

Further FCC action on RMD effectiveness published

A Commission item aimed at improving the effectiveness of the Robocall Mitigation Database, part of the Call Authentication Trust Anchor proceeding (WC Docket No. 17-97), appeared in the Federal Register.

The FCC continues to treat RMD certifications as an enforcement instrument: they must be accurate, current and backed by a mitigation program the provider actually runs.

What it means for your network

If your certification still describes controls you no longer operate, fix it now. Downstream carriers may refuse traffic from providers with deficient or removed filings.

Source: Federal Register

Enforcement

FCC removes 14 providers from the Robocall Mitigation Database

The Commission removed 14 named companies from the RMD for violating robocall rules, following its usual sequence of warning letters and information requests.

Removal has immediate commercial effect: other U.S. providers must stop accepting the removed provider's traffic.

What it means for your network

Keep your own certification defensible — and check the RMD status of every upstream partner. Accepting traffic from a removed provider puts your own standing at risk.

Source: National Law Review

Enforcement

Providers face RMD removal for ignoring traceback requests

The FCC moved to remove nine providers from the database after they failed to answer multiple traceback requests — despite certifying that they would respond within 24 hours.

The Enforcement Bureau treats an unmet traceback commitment as a defective certification.

What it means for your network

Traceback is an operational discipline. Make sure someone owns the inbox, the 24-hour clock and the escalation path — silence is the violation.

Source: Communications Daily

FCC Rulemaking

Stronger know-your-upstream-provider rules and STIR/SHAKEN changes

The Commission acted to strengthen know-your-upstream-provider obligations alongside changes to STIR/SHAKEN call authentication requirements.

The logic: illegal traffic usually enters the U.S. network through a provider that did not look closely at who handed it the calls.

What it means for your network

Keep documented KYC for every customer and upstream: legal entity, contacts, expected traffic and what you did when traffic didn't match. Records created after an inquiry arrives carry little weight.

Source: Federal Register

AI & TCPA

FCC proposal on KYC, per-call penalties and an AI safe harbor

A Further Notice of Proposed Rulemaking proposed more prescriptive KYC requirements for originating providers, significantly higher per-call base forfeitures for failing to take effective measures against illegal calls, and asked whether effective AI-based fraud and KYC systems should qualify as a safe harbor.

Proposals are not final rules, but they are the clearest preview of where compliance expectations are heading.

What it means for your network

Providers that can demonstrate working, automated KYC and fraud controls — with records — will be best placed whatever the final rules say.

FCC Rulemaking

FCC proposes enhancements to STIR/SHAKEN

The Commission set out proposals to make STIR/SHAKEN a sharper tool against illegal calls, including better know-your-upstream-provider requirements (WC Docket No. 17-97; CG Docket No. 17-59).

Attestation quality is under review: A attestation is supposed to mean the provider knows the customer and their right to the number — not just that the call started on its switch.

What it means for your network

If you hand out A attestation broadly, measure how much of it you could actually justify. Fixing attestation logic now is far cheaper than doing it under an inquiry.

Source: FCC

Enforcement

FCC proposes forfeiture against a gateway provider over robocall traffic

The Commission issued a Notice of Apparent Liability (FCC 26-22) against an intermediate/gateway provider in connection with illegal robocall traffic it carried.

As with other NALs, the penalty is proposed, not final — but the reasoning signals what the FCC expects providers to know about their upstream sources and how they respond to traceback.

What it means for your network

Gateway and intermediate providers are firmly in scope. Documented customer diligence, attestation decisions and traceback responses are the difference between a defensible position and a fine.

Source: FCC 26-22

Robocall Mitigation Database

FCC orders 35 companies to cure RMD filing deficiencies

The Enforcement Bureau ordered 35 companies to fix deficiencies in their RMD certifications or explain why they should not be removed from the database.

Typical problems include incomplete mitigation plans, missing contact details and certifications that don't reflect a provider's actual operations.

What it means for your network

If you receive a cure order, the window is short and the response must be substantive. Treating it as paperwork is how providers end up in the next removal order.

Source: FCC

Enforcement

FCC cuts a provider off from U.S. networks over robocall violations

The Commission took action to immediately stop a provider that violated robocall rules from connecting to U.S. networks.

Actions like this end a carrier's U.S. business overnight; other providers are directed to stop accepting the traffic.

What it means for your network

Respond to traceback quickly and completely. A provider that can show call detail, attestation decisions and the action it took on a flagged customer is in a very different position from one that can't.

Source: FCC

Summaries are informational and not legal advice. Always refer to the official source.

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