In short, if you don’t certify a Robocall Mitigation Plan for inclusion in the FCC database, you could be prohibited from originating calls out of your network by the end of September. The majority of Innovative Systems voice customers qualify for the two year STIR/SHAKEN extension, but the FCC has set for June 30th 2021, a deadline to have in place a certifiable Robocall Mitigation program.
All companies that have certified that they are monitoring their outbound traffic and taking any action needed to prevent originating robocalls will be listed in a yet to be created FCC database. This public database will be available within 90 days after the June 30th certification deadline. By the end of September, intermediate and terminating providers will not be able to legally accept traffic directly from providers not shown in the database as having a certified Robocall Mitigation program.
What are the elements of the certification program?
The Commission is leaving it up to the discretion of each voice provider to develop their own plan, calling it a non-prescriptive approach. They do want to see in the certification documented practices that are being used to reduce the origination of illegal robocalls, and that you are complying with your plan of action. They also want to see that you agree to participate in industry traceback efforts, and are cooperative with any requests received at your company from the Industry Traceback Goup (ITG).
Items that would be important to consider for your plan include any contractual obligations with your customers regarding their use of services in a legally compliant manner, and also analytics or documented procedures for monitoring of your originating traffic for any suspicious or out of the ordinary activity. It would be strongly suggested that you seek the assistance of a reputable consultant for more details.
You Will also Have other Responsibilities
At present the FCC has placed the responsibility on all terminating and intermediate providers to monitor and verify the database listing of voice service providers with which they interconnect, and to block traffic from non-certified providers.
As a call terminating service, the APMAX TCM Call Screening service is not part of this plan, but is does protect your most vulnerable customers from being exploited by this ever growing scam call plague.
