by Kevin G. Rupy , Kathleen E. Scott , Stephen Conley and Kelly Laughlin
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 significantly expands robocall regulatory obligations on all providers, including intermediate providers and providers that have fully deployed the STIR/SHAKEN call authentication standard. The Order also establishes new enforcement frameworks, including additional penalties for noncompliance and an expedited removal procedure for facially deficient Robocall Mitigation Database (RMD) filings. The FNPRM seeks targeted comments relating to the deployment of the STIR/SHAKEN call authentication standard. With the Commission's adoption of the Order, several new obligations and filing deadlines for providers throughout the voice ecosystem will become effective in the weeks and months ahead.