FCC issues order for 2,411 providers to fix RMD submissions

[BlazeStudios (Tom Ray)]

Earlier this year the FCC had a deadline for many in the RMD (if not all) to update and fix their original submissions to the RMD. This had to be completed by April 2024.

On Dec 10th 2024 the FCC issued this order listing 2,411 providers to fix their RMD submissions due to not meeting all requirements. The providers have been given 14 days to comply with this order or they will be removed from the RMD. Removal from the RMD means two things; First, providers will be ordered to block all traffic from any provider removed from the RMD. Second, re-submitting to the RMD will require additional vetting. This will delay getting traffic blocks removed or even the re-submission being rejected.

I’m pretty confident that a big chuck of those on the list will have their re-submissions taken care of by the deadline (it’s been a week, so some may already have). I am interested in seeing the list of those being removed after the deadline.

Some of you may want to check out the list to make sure you’re not on it or if your provider may be on it. For those in the US who still haven’t complied with the current requirements by the FCC for what is a VoIP Provider, you really really should get that taken care of. Between the RMD and the STIR/SHAKEN databases, we are getting closer and closer to the possibility of the FCC requiring that only registered providers in those databases can have traffic terminated with other carriers/providers. Strike that, I re-read the full order and other relevant releases, if a carrier isn’t in the RMD the receiving carrier must block their calls.

[BlazeStudios (Tom Ray)]

I should also follow up and clarify that the FCC considers any entity that is invoicing customers for voice service is a Voice Service Provider and thus subject to the RMD and STIR/SHAKEN requirements. I say this because I’m still seeing people out there claiming “I’m a reseller not a provider” or “I don’t have my own SBC/network, I use provider X’s for everything. I’m not really a voice provider” and those reasons no longer matter.

The FCC doesn’t care how you connect to the PSTN. They don’t care if you using a PBX, a SBC or you connect your clients directly to an upstream provider’s network. To clarify, if Sprocket’s VoIP is using VoIP Innovations and connecting all their customer’s PBX systems directly to VoIP Innovations it still means Sprocket’s VoIP is the voice service provider. Sprocket’s VoIP is responsible for being in the RMD and STIR/SHAKEN. Sprocket’s VoIP is responsible for signing all their outbound calls. Sprocket’s VoIP is responsible for mitigating any fraud/robo calls for their customers (inbound and outbound). Because Sprocket’s VoIP is invoicing and billing their customers for the voice service, it makes Sprocket’s VoIP a voice service provider in the eyes of the FCC.

Oh and because of other rules being implemented, Sprocket’s VoIP would be responsible for Known Your Customer compliance and be able to show KYC when required.