CHARLESTON, W.Va. (WVDN) — Attorney General JB McCuskey and a bipartisan coalition of 48 attorneys general are pushing the Federal Communications Commission (FCC) to make improvements to its Robocall Mitigation Database (RMD) that would help curb illegal robocalls.
Voice service providers are required to submit a filing with the RMD before they can accept and route call traffic through the U.S. communications network. That filing must include information about the provider’s business and robocall mitigation practices. Downstream providers are only allowed to accept calls from providers that are included in the RMD. However, bad actors are currently able to enter and stay in the database with minimal effort and limited impediments.
The attorneys general are urging the FCC to improve the effectiveness of the RMD by strengthening filing obligations and deterring bad actors and noncompliant providers from appearing in the RMD. The attorneys general argue that improvements could allow the RMD to serve as the authoritative resource for promoting transparency and accountability around all providers’ robocall mitigation practices. Improvements would allow the FCC’s tool to serve as a barrier to entry, reducing illegal call traffic.
The coalition filed comments in response to the FCC’s proposed changes to the RMD. In addition to what the FCC is already doing, the attorneys general urge it to:
- Ensure that all information in the RMD is accurate and complete. The FCC should thoroughly vet all information submitted to the RMD before allowing a provider to appear in the RMD and to start sending call traffic through the network.
- Require additional disclosures. The FCC should require providers to disclose their use of third parties, related entities, the legitimacy of claims of a domestic presence, and access to numbering resources.
- Make it more difficult for bad actors to enter or re-enter the RMD. The attorneys general support the FCC’s proposed methods to suspend or remove bad actors from the RMD, strengthen the filing format and content of robocall mitigation plans, and require that RMD filers provide evidence of solvency.
- Hold providers responsible for all filings done on their behalf. The coalition does not oppose allowing for third-party submissions on behalf of providers to the RMD, as long as providers and their principals are responsible for the information submitted on their behalf.
- Impose additional certification requirements to allow for quicker removal from the RMD when necessary. Providers should be required to certify that they have not submitted false or misleading information, are in compliance with all applicable FCC robocall rules, and will respond within 24 hours to traceback requests.
- Require providers to notify their upstream customers and downstream providers of FCC orders and notices. The FCC should require providers subject to an FCC removal order, suspension, or mandatory blocking order to notify their calling customers of the same. It should further allow the downstream providers of the voice service providers subject to such orders to also notify those same customers that their calls will be blocked if they continue to attempt to send their call traffic through that provider that was issued an FCC order.
- Make historical RMD filings public. The historical data of providers that have been removed from the RMD would be useful to law enforcement and others.
- Implement all proposed rules as soon as possible and maintain RMD obligations in the meantime. If the proposals to strengthen the RMD are adopted, the RMD is set to become a reliable tool to help safeguard the communications network against illegal robocalls, making swift implementation crucial. The FCC should also keep in place all obligations that protect against bad actors until reinforced guardrails are implemented.
Attorney General McCuskey is part of the Anti-Robocall Multistate Litigation Task Force, which launched Operation Robocall Roundup in 2025.
In phase 1 of the operation, the task force sent warning letters to 37 smaller voice providers that were disregarding their obligations to mitigate the origination and transmission of illegal and/or suspicious robocalls by failing to comply with certain baseline mandates from the FCC. In the last year, the FCC has issued subsequent orders to at least 16 of those companies, ordering them to fix their robocall mitigation issues and/or removing them from the RMD altogether and preventing them from routing any calls across the U.S. telephone network.
In phase 2, the task force:
- Expanded its crackdown to four of the country’s largest intermediate voice service providers.
- Pushed the FCC to strengthen rules that would cut off scammers’ access to legitimate phone numbers.
- Pushed the FCC to strengthen its Know Your Customer rules to require phone companies to verify who is making calls using their networks and what kinds of business their customers are conducting.
- Pushed the FCC to strengthen its Know Your Upstream Provider rules to require voice service providers to ensure that they receive calls from legitimate and responsible providers and don’t route high volumes of illegal calls.
Read the comment letter here.
