The Telephone Consumer Protection Act (TCPA) is the 1995 law that was supposed to protect…
STIR/SHAKEN has been years in the making, with legislative and regulatory backing. One of the more exciting and useful outcomes is the FCC’s Robocall Mitigation Database (RMD). The RMD is not itself part of the new technology but was created to help manage its rollout.
This new database was launched by the FCC in April. Service Providers were required to file STIR/SHAKEN status, a Robocall Mitigation Plan (RMP) if applicable, and contact information by a June 30th deadline. Registrations continue to roll in from tardy or new providers.
Effective September 28th, Intermediate Providers and Terminating Service Providers will not be permitted to accept calls from providers that are not in the database.
ZipDX initiated a project which allows us to better understand and track this database. Our tools monitor the RMD and offer a variety of viewing options, including filtering, sorting and drill-down capabilities. Significantly, ZipDX has also undertaken an effort to score each of the filed RMPs and make those results available in the viewer.
ZipDX is making the RMD Explorer publicly available at http://rmd.legalcallsonly.org. Additional information follows.
Ways to Explore: The FCC has some basic viewing capabilities at their RMD web site. Our tools provide additional sorting and filtering tools:
- The Name Search matches an entered string against the Business Name, Previous Names, and DBA fields in the database.
- You can filter on just foreign providers, just USA providers, or just providers from a particular USA state.
- You can filter on just intermediate providers, or Voice Service Providers (VSPs) with a particular level of STIR/SHAKEN implementation.
- When viewing the list, you can sort by various columns, including when the record was created or updated.
- The primary RMD Explorer display contains a small set of what we think are the most relevant columns so you can view it without horizontal scrolling. Clicking on a Provider Name takes you to a view with more detail.
- The detailed view shows any match(es) that we find in the FCC’s 499A filer database, with link(s) to see more detail. We also have links to the FRN entries in the FCC’s CORES database.
- Also on the detailed view is a history of that provider’s records in the RMD. There is a link in the active (current) record which will take you to that record’s origin at the FCC’s RMD website.
RMP Scores: VSPs that have not completely implemented STIR/SHAKEN are required to file a Robocall Mitigation Plan (RMP) as part of their certification when creating their RMD entry. The FCC did not dictate details of a suitable RMP. The RMP must include “the specific reasonable steps the voice service provider has taken to avoid originating illegal robocall traffic.” RMPs come in all shapes and sizes because each provider’s plan is specific to the nature of their business and the types of customers they serve.
ZipDX has developed a scoring system for RMPs. In an attempt to make the evaluation as objective as possible, we have defined five different categories in which each plan is rated on a scale of 0 to 3; those ratings are then summed to get a score between 0 and 15. This system is focused on prevention of high-volume illegal robocalling. We know that the vast majority of providers are not conduits for illegal robocalls, so we first categorize a provider as low, medium, or high risk according to the information (if any) included in their plan regarding the fundamentals of their business.
Our evaluation approach and criteria is based on our years of experience in this domain – but it is still evolving and we are thirsty for feedback. Our RMD Explorer lets you see (and sort) how we have scored each plan. It is a huge job with over 2,000 plans filed; we are gradually making our way through the stack. Despite trying to be objective, our system is NOT perfect. You might even find two nearly-identical plans with different scores; this happens because members of our team have slightly different perspectives, or because our impression of one provider’s business gave us a different perspective on risk versus another provider. Our purpose is to provoke thought and discussion as we all try to evolve illegal robocalls out of existence.
Tracking Changes and Deletions: The RMD Explorer includes an important feature: it keeps track of changes to the database over time. Every night, we download the latest RMD from the FCC, and compare it to the previous version. This allows us to see which records have been updated – and which have been deleted. If a particular provider is deleted from the database, others serving as intermediate providers are prohibited from accepting the deleted provider’s traffic.
Key Statistics: Here are some summary statistics from the RMD as of 11-July 2021:
- Total (non-duplicate) entries: 3,165
- Intermediate Providers: 493
- Foreign Intermediate Providers: 3
- USA Intermediate Providers: 490
- Voice Service Providers: 2,672
- Foreign Voice Service Providers: 253
- USA Voice Service Providers: 2,419
- Providers that are both Intermediate and VSP: 191
- USA: 190
- Foreign: 1
- Intermediate Providers: 493
- Foreign Countries with the most entries:
- Canada: 30
- United Kingdom: 12
- China, Hong Kong SAR: 12
- Israel: 10
- India 9
- Mexico: 8
- Singapore: 8
- Australia: 6
- USA (?): 6
- Pakistan: 6
- States with the most entries:
- California: 183
- Florida: 172
- Texas: 166
- Wisconsin: 162
- Georgia: 161
- Iowa: 158
- New York: 129
- Illinois: 100
- STIR/SHAKEN STATUS:
- No S/S: 1,563
- Partial S/S: 764
- Complete S/S: 365
- Not Specified: 473 (generally intermediate providers)
- Robocall Mitigation Plans Filed: 2,338
Anomalies: Given the number entries, and the number of individuals inputting data, there are bound to be some errors. For example, as shown above, there are a few providers marked as “Foreign” but with the Country set to USA. We expect this will get cleaned up in the weeks ahead.
Feedback: We are committed to making the RMD Explorer and our RMP Scoring System as good as they can be and are anxious for your feedback. Please feel free to drop a note with your thoughts. We’re also happy to have a call to brainstorm ideas, questions, or anything else you’d like to discuss in this realm.