FCC’s New Robocall Mitigation Plan & Certification Filing Deadline In Effect

• The FCC has set a deadline for voice service providers (VSPs) to submit their new Robocall Mitigation Plans (RMPs) and certifications. The deadline is February 26, 2024.
• All VSPs, including intermediate providers and those without STIR/SHAKEN facilities, must take "reasonable steps" to mitigate illegal robocall traffic. They are required to submit a certification to the FCC's Robocall Mitigation Database and also provide a detailed robocall mitigation plan.
• VSPs need to submit detailed information about their company, policies, practices, role in the industry, and more in the certification. It must be signed by an officer of the company under penalty of perjury.
•  The plans must outline the "reasonable steps" taken by VSPs to comply with regulations, including measures to mitigate illegal robocalls, "know your customer" and "know your upstream provider" procedures, and details about call analytics systems.
• Failure to comply with the new rules may result in economic sanctions, with a maximum forfeiture amount of $23,727 per call for violating blocking requirements. The FCC may remove certifications from the database for deficient submissions or knowingly processing illegal robocalls. Reinstatement could take 6 to 12 months.

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