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Robocall Mitigation Database Filing Compliance

Robocall Mitigation Database Filing Compliance

Bob Webb

I recently read an excellent article from Marshlian and Donohue, PLLC, outlining the challenges faced by a VoIP service provider that has become a target in an FCC investigation. You can read the article here: https://commlawgroup.com/2024/robocall-mitigation-for-voip-providers-and-pure-resellers/.

The article highlights the need for all VoIP provider–that is, anyone billing customers for VoIP service, including VoIP resellers–to register with the Robocall Mitigation Database (RMD.) The article lists the potential costs facing VoIP resellers that risk becoming a target of the FCC. Those costs include:

  • Fines and Penalties
  • Legal Fees
  • Settlement Costs
  • Severe Reputational Damage
Essential notes from the article:
  • Every VoIP reseller must register with the RMD immediately. The deadline was in February, but compliance by May 28th is essential if the reseller plans to keep operating.
  • The registration must include new mandated disclosures. The FCC is actively weaning the database of registrations that are incomplete.
  • Starting May 28th, ClearlyIP and other VoIP providers will only deliver calls from a reseller that is registered with the RMD.
Citing a webinar I did a month ago or so, I want to remind all resellers of common obligations. Every reseller must:
  • Report USF charges
  • Contribute to the TRS fund
  • Rate and collect all State, County, and Local Taxes and Fees and 911 surcharges
  • File a Robocall Mitigation Plan with the FCC
  • Meet the requirements of Stir/Shaken as defined by the TRACED Act

ClearlyIP is here to help. ClearlyIP cannot register you in the RMD. However, we can help you with Stir/Shaken. We can host your digital certificate and sign calls originating from your customers with your digital certificate. Also, suppose you decide that the reseller responsibilities no longer make sense for your business. In that case, we can help you transition to an agent model whereby ClearlyIP bills the customer directly and assumes the robocall mitigation responsibilities while paying you a monthly commission. Regardless of your choice, reach out to your account manager for assistance.

Thank you for your continued partnership and trust in ClearlyIP.

Best regards,

Bob Webb
Chief Business Development Officer