Three ways a company ends up in the database
The FCC does not care much what you call yourself. It cares where you sit in the call path. Find your group below. The obligation, and the way a stale entry hurts you, is different in each one.
You originate calls
Traffic starts on your network or on your platform. Your entry is the one downstream carriers look at first, and it is the one your customers' calls depend on.
Reselling somebody else's minutes does not exempt you. If you sell voice service under your own name, you are the provider your customers signed with.
You carry or process calls
You did not originate the traffic, but it passes through you. Intermediate providers sit in the middle of the path and are still expected to have a filing that describes what they do about illegal robocalls.
This is the group most likely to assume the obligation belongs to somebody upstream. It does not transfer.
You bring calls into the US
Gateway providers landing foreign-originated traffic in the US, and companies abroad using US numbers to send calls to American subscribers, are inside the same public database as any domestic carrier.
Distance is the practical problem: no US-based person owns the filing calendar, the contact on the entry left years ago, and nobody notices until traffic stops landing.
Not sure which one you are?
Answer these four out loud. If any answer is “I don't know”, the free check is the cheapest way to find out.
- Do we have an entry in the Robocall Mitigation Database at all?
- Who inside the company certified it, and are they still here?
- When was it last recertified, and when is the next window?
- Does the description on the entry still match what we actually do?