In the FCC’s Second Report and Order (September 2020) they announced plans for a Robocall Mitigation Database, where all carriers would need to file their plans for STIR/SHAKEN and robocall mitigation. In particular, a key requirement in qualifying for the 2 year extension for STIR/SHAKEN implementation (available to carriers with fewer than 100K subs) was to implement a robocall mitigation plan and file it in the database.
Last week (April 20) the Wireline Competition Bureau launched the Robocall Mitigation Database – along with some useful supporting documents. I’ll start by providing links to the most important information, then I’ll add some comments. I should also state clearly that I am not a lawyer nor a regulatory consultant – so don’t put undue trust in my words. 🙂
Robocall Mitigation Database links
- You can see the Robocall Mitigation Database itself here, including filings by other service providers.
- The FCC public notice announcing it is a surprisingly readable 3-page summary of everything you need to know about STIR/SHAKEN and robocall mitigation.
- There are instructions for how to submit your filing to the database.
Everyone needs to file
When I first heard about the robocall mitigation database, I thought that only those who took the STIR/SHAKEN extension and implemented a robocall mitigation plan would be required to file – however that’s not the case. All voice service providers need to be included in the database, even if they’ve implemented STIR/SHAKEN.
In fact, after September 28, 2021, intermediate and terminating carriers will be prohibited from accepting traffic from service providers who do not appear in the database.
So it’s very important that you file!
When submitting a filing to the database you have to select one of three certification options for your network.
- Complete STIR/SHAKEN certification – meaning that every call that originates on your network is certified.
- Partial STIR/SHAKEN certification – with robocall mitigation implemented.
- No STIR/SHAKEN certification – with robocall mitigation implemented.
I would imagine that the vast majority of those reading this will be filing either Partial or No STIR/SHAKEN. It’s impossible to have complete STIR/SHAKEN certification if you have TDM trunks in your network. This means that basically everyone needs to be doing robocall mitigation – at least on that portion of your calls that are not STIR/SHAKEN certified.
Prohibition on accepting traffic
Also, notice that as a terminating service provider, you are prohibited from accepting traffic from service providers who do not appear in the database. Most small CLECs and ILECs have only a few (and rarely changing) set of interconnections to carriers, but nevertheless it seems like you’ll need to implement a process to review this list to make sure that they’re all in the database. For class 4 (intermediate) service providers this will be a much more significant and challenging requirement.
The deadline for submitting required information to the database is June 30, 2021. So over the next two months, you need to complete the following.
- Create a robocall mitigation plan – which could potentially include a software solution as part of the plan.
- Implement the practices (and/or software) that you documented in your plan.
- Submit the required information to the Robocall Mitigation Database.
(If you qualify for the extension, you could optionally implement STIR/SHAKEN on SIP carrier trunks too – it’s certainly a good thing to do, increasing call deliverability, but unfortunately that doesn’t remove the need for a robocall mitigation plan.)
We would recommend working with a regulatory consultant on the filing submissions and writing the robocall mitigation plan, but if you have questions on the technical side of things feel free to contact us and we can give you some pointers.