REMINDER: Robocall Mitigation Program Implementation and Certifications Due June 30, 2021

Voice service providers with an extension to implement STIR/SHAKEN must implement a Robocall Mitigation Program (RMP) by June 30, 2021, and all voice service providers must file a certification and related information in the FCC’s Robocall Mitigation Database (RMD) via https://fccprod.servicenowservices.com/rmd. Beginning September 28, 2021, intermediate providers and terminating service providers will be prohibited from accepting traffic directly from voice service providers not listed in the Database.

In addition, not later than June 30, 2021, a voice service provider shall either:

(a) Upgrade its entire network to allow for the initiation, maintenance, and
termination of SIP calls and fully implement the STIR/SHAKEN framework as
required in § 64.6301 throughout its network; or

(b) Maintain and be ready to provide the Commission on request with
documented proof that it is participating, either on its own or through a
representative, including third party representatives, as a member of a working
group, industry standards group, or consortium that is working to develop a non-
internet Protocol caller identification authentication solution, or actively testing
such a solution.1

If you have questions or would like help2 with the robocall mitigation requirements or submitting the certification filing, please contact Greg Whiteaker at greg@hermanwhiteaker.com, Clare Andonov at candonov@hermanwhiteaker.com, Hilary Rosenthal at hrosenthal@hermanwhiteaker.com, or Colleen von Hollen at cvonhollen@hermanwhiteaker.com.