CTIA Files FCC Robocall Mitigation Database FNPRM Comments

CTIA filed the attached comments in response to the FCC's Robocall Mitigation Database FNPRM. In the comments, we strongly support the FNPRM's proposals to strengthen the processes for entry into the RMD, which will help deter bad actors from entering or remaining in the RMD, and we urge the FCC to act on these anti-robocall proposals first, before considering action on its other open proceedings. We urge the FCC to keep the RMD appropriately targeted and oppose proposals in the FNPRM to expand the definition of "Voice Service Providers" subject to filing requirements and extend blocking obligations to text message traffic. We also support the FCC codifying cure and removal procedures, streamlining some filing requirements, removing the filing fee, and maintaining the current "reasonable measures" standard for robocall mitigation plans. We also encourage the FCC to clarify the scope of the robocall blocking safe harbor to cover blocking based on non-compliance with FCC rules and other bad behavior, which will help strengthen protections for consumers.