Operation Robocall Roundup: 51 Attorneys General Warn 37 Voice Providers

Here is what happened

According to California Attorney General Rob Bonta's announcement, the 37 providers had failed to comply with one or more Federal Communications Commission (FCC) rules:

1. Not responding to government traceback requests.
2. Not registering in the FCC's Robocall Mitigation Database (RMD).
3. Not filing a plan describing how they will reduce illegal robocalls on their networks.

The FCC announced at the same time that it was removing seven of these providers from the RMD. Once a provider is removed, other providers may no longer accept and route its calls.

The downstream letters

The task force also wrote to more than 99 downstream providers that accept traffic from the 37 companies. The stated purpose was to make sure those downstream companies understand they are doing business with companies that are not following the rules.

Here is why it matters

Enforcers are going after the entire call path. A warning letter to one upstream provider is also notice to every carrier that takes its traffic. Once on notice, a downstream provider will have a hard time arguing it did not know.

Traceback responses and RMD filings are not optional paperwork. They are the first things regulators check.

What this means for you

1. Respond to every traceback request. FCC rules require a complete response within 24 hours.
2. Confirm your RMD certification and mitigation plan are current.
3. Monitor your upstream partners. If one receives a warning letter, decide whether to keep accepting its traffic.
4. Document your decisions. A record of what you knew and what you did will matter if a state comes calling.