On November 12, 2024, under the leadership of the National Association of Attorneys General, 47 state AGs joined in a Comment responsive to the Federal Communications Commission's recent proposals to increase accountability and accuracy in Robocall Mitigation Database ("RMD") filings. See Notice of Proposed Rulemaking, Improving the Effectiveness of the Robocall Mitigation Database, WC Docket No. 24-213, et al., Adopted August 7, 2024.
The Comment notes that the RMD is an essential resource in State AGs' efforts to combat illegal robocalls. Since 2021, providers have been required to register on the FCC's database to operate as a voice service provider in the United States. The registration process, according to the Comment, has not prevented bad actors from obtaining legitimate registrations to send illegal robocalls.
The Comment notes that information submitted by providers to the RMD can often be false or inaccurate to the detriment of consumers. Such deficiencies can include false, incomplete, or misleading contact information, blank or inapplicable mitigation plans, and representations which are contradicted by other FCC filings or publicly available sources.
The coalition of AGs supports FCC proposals that include additional procedural measures after submission of required information to RMD; potential technical solutions to identify and require correction of data discrepancies in filings; measures to increase accountability for providers that submit inaccurate and false information to the RMD or fail to update their filings when the information they contain changes; and other steps to increase the effectiveness of the RMD as a compliance and consumer protection tool.
State AGs from the following States signed the submission: Alabama, Alaska, Arizona, Arkansas, California, Colorado, Connecticut, Delaware, District of Columbia, Florida, Georgia, Hawaii, Idaho, Illinois, Indiana, Iowa, Kansas, Kentucky, Louisiana, Maine, Maryland, Massachusetts, Michigan, Minnesota, Mississippi, Missouri, Nevada, New Hampshire, New Jersey, New Mexico, New York, North Carolina, North Dakota, Ohio, Oklahoma, Oregon, Pennsylvania, Rhode Island, South Carolina, South Dakota, Tennessee, Utah, Vermont, Virginia, West Virginia, Wisconsin, and Wyoming.
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