Analysis · FCC & rulemaking

Ignoring Tracebacks Puts Nine Providers on the Path to Robocall Mitigation Database Removal

On August 27, 2026, the Federal Communications Commission (FCC) Enforcement Bureau ordered nine providers to cure deficient Robocall Mitigation Database (RMD) certifications or explain why they should not be removed (Order DA 26-873). The deficiency in each case was the same: the company failed to respond to multiple traceback requests.

By Harrison GevirtzPublished 2 min read
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The bottom line is that the promise to answer tracebacks within 24 hours is part of your sworn RMD certification. Breaking it makes the certification deficient.

The nine companies

The order names:

  1. Advantage Investors llc
  2. sunstreamnetwork
  3. Quantum Link VOIP
  4. Summit Industries
  5. Scissortail Communications, LLC
  6. Globe Tech Solutions
  7. COLLECTION 3 LLC
  8. Alpha Stream
  9. MMN Tech LLC

FCC rules require voice service providers, gateway providers and non-gateway intermediate providers to certify in the RMD that they will respond within 24 hours to all traceback requests from the FCC, law enforcement and the industry traceback consortium. That commitment became part of the certification requirements under amendments that took effect February 26, 2024.

The Bureau found that each company made that commitment and then failed to respond to the traceback requests listed in Appendix B of the order. Appendix B, in total lists 51 unanswered tracebacks. The counts per company range from three (Quantum Link VOIP, Scissortail Communications and MMN Tech) to twelve (Advantage Investors). The call dates go from February of 2024 into 2025.

The process so far

  1. On September 29, 2025, the Bureau emailed each company a Notification of Deficient Robocall Mitigation Database Certification.
  2. Each company had 14 days to cure by responding fully to the past traceback requests and promising to respond to future requests within 24 hours.
  3. According to the order, none of the companies cured the deficiency.
  4. The August 27, 2026, order gives each company a final 14 days to cure or explain why its certification is not deficient.

If a company fails to do so, the Bureau said it will remove that company's certification. Intermediate providers and voice service providers would then have to stop accepting calls directly from it, except calls to 911 or from public safety answering points and government emergency numbers.

Why tracebacks matter

Tracebacks are how the industry and the FCC identify the source of illegal robocalls. A provider that does not respond breaks the link and makes it difficult to identify the caller. The FCC treats this failure to comply as a defect in the certification itself, not a courtesy.

What this means for you

  1. Assign someone to look for traceback requests every business day. The rule is 24 hours.
  2. Respond fully. A partial or late response can still be a deficiency.
  3. Check old requests. Some of the tracebacks in this order were more than two years old when the order issued.
  4. Answer FCC notifications within 14 days. These companies had nearly a year between the first notice and this order and did not use it.

Traceback compliance has become a standalone ground for RMD enforcement. Providers should treat traceback compliance as a core compliance function.

Not legal advice. TCPA.com provides general information, not legal advice, and is not a substitute for the advice of an attorney. Do not rely on it. Verify any action with your own licensed lawyer before you take it. See our Terms of Use.

Primary sources

  1. FCC Enforcement Bureau Order, In the Matter of Advantage Investors llc et al., DA 26-873 (Aug. 27, 2026)
Harrison Gevirtz, Chief Strategy Officer of Ringba, Las Vegas, Nevada

About the Author: Harrison Gevirtz

Harrison Gevirtz serves as the Chief Strategy Officer (CSO) of Ringba, a call tracking and pay per call platform, and is based in Las Vegas, Nevada. Harrison Gevirtz is a serial operator in call tracking, call routing and telemarketing operations, and for the past several years he has focused on how federal regulations affect the daily operations of these industries. At TCPA.com, Harrison Gevirtz covers TCPA litigation, Telemarketing Sales Rule (TSR) enforcement, tech support fraud prosecutions and Federal Communications Commission (FCC) rulemaking in a way that's accessible to the non-lawyer executive or compliance manager.

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