The FCC's First Robocall Mitigation Database Removal Orders, and the Provider That Fought Its Way Back

The bottom line: a filing in the RMD is not paperwork you can ignore. If your certification is deficient, other carriers may be required to stop taking your traffic.

The seven providers

These providers were ordered to show cause within 14 days why they should not be removed from the database:

1. Akabis
2. Cloud4
3. Global UC
4. Horizon Technology Group
5. Morse Communications
6. Sharon Telephone Company
7. SW Arkansas Telecommunications and Technology

The FCC explained the stakes plainly. Removal would require all intermediate providers and terminating voice service providers to stop carrying the company's traffic. All calls from the provider's customers would be blocked.

FCC Chairwoman Jessica Rosenworcel said: "This is a new era. If a provider doesn't meet its obligations under the law, it now faces expulsion from America's phone networks."

Loyaan A. Egal, acting Chief of the Enforcement Bureau, said: "STIR/SHAKEN is not optional."

What the FCC found

Every voice service provider must file a certification in the RMD. A provider that has not fully implemented STIR/SHAKEN caller ID authentication must describe the specific reasonable steps it takes to avoid originating illegal robocalls.

In the Global UC order (DA 22-1037), the Bureau found that the company's certification did not include a robocall mitigation plan describing any specific reasonable steps. Global UC was given until October 18, 2022, to cure the problem or explain why its filing was not deficient.

Removal, then reinstatement

According to a later FCC order, Global UC did not cure its certification by the deadline. The Bureau removed it from the RMD on November 22, 2022.

Global UC then asked to be reinstated. On October 16, 2023, the Bureau found that the company had cured the deficiencies, and it reinstated Global UC to the RMD in Order DA 23-956. Citing what it called Global's "repeated failures to understand and comply with the Commission's rules and the Bureau's orders," the Bureau also required a compliance program. Under that program, Global UC agreed to:

1. Appoint a named Compliance Officer.
2. Develop Operating Procedures and a compliance plan within set deadlines.
3. Train covered employees and repeat that training every year.
4. Report any noncompliance with the caller ID authentication and robocall mitigation rules to the Bureau within 15 calendar days of discovering it.

What this means for you

1. Read your own RMD filing today. A generic plan that names no specific steps is the kind of filing the FCC called deficient here.
2. Respond to a show cause order before the deadline. Missing it led to removal in this case.
3. Expect some conditions if you are reinstated. Getting back in came with a formal compliance program.
4. Check your downstream partners' RMD status. Removal affects every provider that carries the removed company's traffic.

These 2022 orders set the template for many later RMD actions. The process starts with notice and an opportunity to cure, but the deadlines are short.