FCC Robocall Mitigation Database (RMDB) Frequently Asked Questions (FAQs)

Clarifying Compliance around the RMDB

The Federal Communications Commission (FCC) says that starting September 28, 2021, intermediate and terminating service providers must not accept traffic from carriers that are not registered in the Robocall Mitigation Database (RMDB). But how to do that is not clear. Get the answers from our experts.

How do you access the FCC Robocall Mitigation Database (RMDB)?

The FCC’s Robocall Mitigation Database (RMDB) is publicly available here.

Is there an obligation for Terminating Service Providers (TSPs) to participate in Traceback?

Yes, all TSPs are required to participate in Traceback when the Industry Traceback Group (ITG) sends them a traceback request. Service providers must also respond to all traceback requests from the Federal Communications Commission (FCC), law enforcement, and the industry traceback consortium, and they must cooperate with such entities in investigating and stopping any illegal robocallers that use its service to originate calls.

Is it legal for international service providers to send calls using North American Numbering Plan (NANP) calling numbers?

Yes, there are many valid reasons for international service providers to send calls utilizing NANP numbers - call centers and remote offices may want to use NANP numbers to convey a domestic presence.

Carriers that use NANP telephone numbers (including foreign entities) are required to file a certification in the FCC database to demonstrate that traffic is either signed with STIR/SHAKEN or subject to a robocall mitigation program.

If a carrier is not in the FCC database, can I still register in time to avoid calls from getting blocked?

Yes, but you need to hurry as your calls risk being blocked. The deadline is 9/28/2021.

If incoming trunks are TDM based, is there requirement to block inbound calls on 9/28?

Yes, all inbound carrier calls, regardless of trunk type, are subject to the mandate.

If a carrier is not using Neustar’s Robocall Mitigation Database (RMDB) solution, how can they validate that all of the service providers they accept traffic from are properly represented in the RMDB?

A carrier can manually confirm that each of the OCNs, or company names, from which they are receiving calls, are in the RMDB. This can be an arduous task as the carrier will need to map the correct company name from the RMDB to their internal systems (Billing, Provisioning, Operations, etc.) Since companies can change names, and abbreviations are often used in more technical systems, it is a complex and time consuming task.

Are VOIP providers (providers who don’t obtain their own phone numbers or operate a switch) required to register in RMDB, or are they covered by the wholesale carriers’ robocall mitigation plan?

All originating voice carriers, including VOIP providers, are required to register in the RMDB. One of the aims of the FCC RMDB is to understand what progress service providers of all types have made by implementing measures to mitigate robocalls.

Does the industry expect to see a real reduction in robocall traffic after blocking becomes mandatory on 9/28?

Yes, the FCC’s RMDB mandate represents another tool for enforcement organizations to identify and thwart bad actors. It is important to comply with this order to demonstrate your organization’s commitment to mitigating robocalls and restoring trust in the phone network.

A Service provider “A” has telephone numbers it received from Service Provider “B”. If Service Provider “A” receives a call from Service Provider “C”, and “C” is not registered in the RMDB, should the call be accepted?

No. Since Service Provider “C” is an Intermediate or Terminating Service Provider, they need to be registered in the RMDB for Service Provider “C” to accept the call. Per FCC regulations, Intermediate and Terminating Service Providers are prohibited from accepting calls from Originating Service Providers (OSPs) that are not registered in the RMDB.

Is there an expectation that the FCC will ask carriers with insufficient robocall mitigation plans outlined in the Robocall Mitigation Database to revise their plans?

Yes, the FCC’s Enforcement Bureau will review each CSP’s program and can also prescribe more specific robocall mitigation obligations for any carrier that hasn’t implemented a sufficient robocall mitigation program.

The FCC doesn’t describe a checklist or prescriptive set of requirements for carriers, as it could act as a blueprint for bad actors to avoid detection. However, CSPs are required to “document and publicly certify how they are complying.” The FCC does say that a robocall mitigation program is sufficient if it:

• Includes detailed practices that can reasonably be expected to significantly reduce the origination of illegal robocalls
• Complies with the practices it describes
• Participates in industry traceback efforts