by Kevin G. Rupy (Washington), Kathleen E. Scott (Washington), Stephen
Conley (Washington) and Kelly Laughlin (Washington)

At its March 16, 2023 Open Meeting, the Federal Communications
Commission (FCC or Commission) adopted a Sixth Report and Order and
Further Notice of Proposed Rulemaking (Order and FNPRM, respectively),
which adds anti-robocall regulatory obligations for all voice service providers, including intermediate providers and providers that have
fully deployed the STIR/SHAKEN call authentication standard.

Specifically, the Order amends the FCC's rules to require non-gateway intermediate providers that receive unauthenticated Session Initiation
Protocol calls directly from an originating provider to authenticate
the call. The Order also expands mitigation obligations to require all non-gateway intermediate providers and voice service providers that
have fully implemented STIR/SHAKEN to meet the "reasonable steps"
general mitigation standard that is currently applied to gateway
providers and voice service providers that have not fully implemented STIR/SHAKEN under the FCC's rules. Further, the Order builds on
Robocall Mitigation Database (RMD) filing obligations, requiring that
all providers file a robocall mitigation plan and a certification in
the RMD, regardless of whether they are required to implement
STIR/SHAKEN. Lastly, the Order strengthens the FCC's robocall
enforcement framework by adopting per-call forfeiture penalties and
expedited procedures for removal of certain RMD certifications.

https://www.mondaq.com/article/news/1297756?q=1803232&n=740&tp=14&tlk=4&lk=64

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