Updates
EPIC, Public Knowledge, National Consumers League Encourage the FCC to Improve the Robocall Mitigation Database
October 19, 2024
On October 15, EPIC, Public Knowledge, and the National Consumers League submitted comments urging the Federal Communications Commission to hold voice service providers and intermediary providers in the phone system accountable for transmitting illegal robocalls by improving the effectiveness of the Robocall Mitigation Database (RMD). The RMD is a database containing companies that connect phone calls; it stores each company’s purported plan to reduce the amount of illegal robocalls it transmits to consumers. The FCC prohibits providers from transmitting phone calls from providers who are not listed in the RMD.
When a caller makes a phone call, it travels through a sometimes complex network of multiple providers. The RMD can help providers understand if they are connecting calls from other providers who are trying to reduce robocalls based on those other providers’ Robocall Mitigation Plans. However, the good faith effort behind these plans is variable; the FCC has previously taken steps to remove entries from the RMD for inadequate mitigation plans which effectively cuts those providers off from the U.S. phone network. These removals echo known issues with the quality of submissions to the RMD, such as companies that submit a Robocall Mitigation Plan that does not describe a plan to mitigate robocalls at all, fails to report basic contact information, fails to designate a representative who can be contacted about the company’s entry, and generally falls short of required information. These deficiencies reflect a larger problem of some providers being unresponsive to requests to investigate the origin of scams and robocalls.
EPIC and its partners supported the Commission in adopting these rules that will lead to higher RMD submission quality and greater provider attention to meaningful robocall mitigation. For example, EPIC supported the FCC’s 10-day deadline to update any changes to a company’s RMD entry, and encouraged the FCC to incorporate annual certifications of a company’s RMD entry. EPIC also supported provisions to enhance the security of a provider’s entry as a further oversight and compliance mechanism. Lastly, EPIC encouraged the FCC to hold providers accountable for risky actions and regulatory noncompliance, such as ignoring traceback requests, continually transmitting illegal robocalls, or accepting calls from providers not listed in the RMD.
EPIC routinely participates in regulatory and legislative processes concerning robocalls and files amicus briefs in robocall cases.
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