On November 12, attorneys general from 47 states (AGs) filed reply comments in response to a public notice seeking comment on the FCC’s proposals to increase accountability and accuracy among filings in the Robocall Mitigation Database (RMD). The AGs expressed their support for the FCC’s proposed rulemaking to enhance the accuracy and accountability of RMD entries, which are used to help combat illegal robocalls. They highlighted issues such as false or incomplete information submitted by providers, which the letter explained undermines enforcement efforts.

The AGs recommended additional procedural measures, including embedding clarifying information in the RMD certification process, requiring timely updates to the Commission Registration System (CORES), and implementing multi-factor authentication and PIN requirements for submissions. They also signaled support for imposing filing fees to discourage bad actors and suggested periodic renewals to maintain current information. Additionally, the AGs advocated for the use of data validation tools to prevent false and inaccurate filings and supported serious penalties for false information. They agreed with the FCC’s proposal for permissive blocking of facially non-compliant providers and emphasized the importance of the RMD as a consumer protection tool.