From: Erik Beith To: Erik Beith Subject: Update on Robocall Mitigation Database Filing Date: Friday, February 18, 2022 10:56:00 AM Dear Robocall Mitigation Database Filer:   Upon review of your filing in the Federal Communications Commission’s (FCC) Robocall Mitigation Database, we have determined that the robocall mitigation program description for which you are listed as the point of contact is deficient.   FCC rule 47 CFR § 64.6305(b)(2) requires a voice service provider that has not fully implemented the STIR/SHAKEN authentication framework across its entire network to upload a robocall mitigation program description that explains the specific reasonable steps it is taking to avoid originating illegal robocall traffic as part of a robocall mitigation program.  A robocall mitigation program must include detailed practices that can reasonably be expected to significantly reduce the origination of illegal robocalls, and the voice service provider must comply with the practices it describes.  See FCC 20- 136, para. 78 (https://docs.fcc.gov/public/attachments/FCC-20-136A1.pdf).     However, your program description does not contain your specific mitigation steps.  Rather, it appears you made a filing error and submitted the incorrect attachment.   By March 20, 2022, you must upload a revised mitigation program description that corrects the issue, or provide evidence that the current mitigation program is sufficient.  See FCC 20-136, para. 78 (https://docs.fcc.gov/public/attachments/FCC-20-136A1.pdf).   Failure to comply could result in referral to the FCC’s Enforcement Bureau and removal of this entry from the Robocall Mitigation Database, which would require all intermediate providers and terminating voice service providers to cease accepting traffic originated by the provider for which you are listed as a contact.  See 47 CFR § 64.6305(c).  This notice serves as a warning letter and constitutes the first step in the enforcement process for removal.    Please send any questions and any responses via email to erik.beith@fcc.gov.   Sincerely,   Erik Beith Attorney Advisor Competition Policy Division, Wireline Competition Bureau The Robocall Mitigation Database Team