Track what the standing Robocall Mitigation Database filing still claims — the steps as operated, the upstream accounts, the traceback answers — and start the update clock when one of them moves.
A traceback request arrives, and § 64.1200(n)(1) starts a 24-hour clock that counts business hours.
02
A request lands on a Friday, and that clock does not run on weekends or on Federal holidays.
Reason
03
An upstream provider changes, and § 64.6305(g) allows only listed, un-delisted filers.
04
A carrier is de-listed, and the traffic stops in two business days with only 911 carved out.
05
A know-your-customer step changes, and § 64.6305(h) allows 10 business days to update the filing.
Decide
06
An analytics vendor is swapped, and the specific reasonable steps on file stop describing the network.
07
A regulatory investigation closes with findings, and the two-year disclosure duty reaches it.
Out
08
A year turns, and recertification falls on or before 1 March, a duty in force since 5 February 2026.
09
Execute write actions only inside the approval boundaries agreed during implementation.
→Product statement
The agent assembles and tracks; a named officer certifies under penalty of perjury, signs, files, and the provider answers for it.
Example workflow
One change, evidence to filing
AgentHuman
1Change in a mitigation stepCustomer screening, upstream contracts, analytics configuration or a traceback answer
2Filing impact assembledEvery field of the standing filing the change touches, and the accounts sitting behind it
3Recertification draftedThe steps as operated, the analytics vendor, the traceback record and the two-year disclosure
4Controls appliedClock checks, evidence-sufficiency checks, field-coverage checks and completeness confidence
No human action required
Stages 1 to 4 run unaided, and nothing is filed at any of them — the agent is drafting, and the regulatory lane opens at the completeness gate.
5DecisionBranches at the completeness gate
Evidence sufficient
Goes to the signing officer to certify.
Anything thin
Adds a regulatory counsel read first.
Regulatory review
The draft is held with its clocks, its evidence and the fields it would move.
Certify and file · Append evidence · Send to counsel
Filed — by a named officer▼
6Account and case records updatedOnly where write access and account policy allow it
7Outcome evaluatedUpdate-clock margin, evidence completeness, counsel corrections and what review found
Corrections
Each counsel correction is counted in the evaluation.
What should not run autonomously
Human approval stays in control
Outside the boundary — human approval required8 items
Certifying that the filing is true and correct.
Signing or filing in the Robocall Mitigation Database.
Blocking traffic, or ceasing to accept it.
Deciding a mitigation step is reasonable.
Automation boundaryAgent acts unaided
✓Assemble the step evidence and name the account each one governs.
✓Run the 10-business-day update clock from the day a step changes.
✓Check every upstream provider against its own database listing.
✓Draft the recertification against the fields the filing already holds.
Nothing is certified or filed except by a named officer, inside the agreed boundaries.
Judging that a de-listed provider may still be used.
Telling a customer that its traffic is lawful.
Deciding what a traceback answer should concede.
Changes to screening rules or certification templates.
Example output
One change, annotated
Removals ran through 2025, and an order in March 2026 gave reinstated companies fourteen days.
Recertification draft · single changeIllustrative example
Change
Drafted as
Clock
Evidence of record
Confidence
Held for
Upstream provider swapped in
Know-your-upstream step amended, filing field affected
Day 3 of 10 business days
Interconnect record, 18 August 2026
Held uncertified
The signing officer, in person
As receivedTaken from the interconnect record and the listing a show-cause order read in December 2024.
What the record holdsUpstream screening proofDatabase listing checkTraceback answer log
Why no removal call hereThere is no one-strike rule, and removal runs as a two-step process.
ActionCertify and fileAppend evidenceSend to counsel
What the score decidesUnder the configured threshold a counsel read is added before the officer sees the draft.
Value
Where AI adds value
The same four claims, placed at the point in the workflow where each one applies.
Where the value landsValue 01 – 04
Every changeFrom the step that moved
03Evidence
The provider on the other end
Our wholesale settlement agent works the partner you invoice; § 64.6305(g) makes that same partner a listing you read before you take a call from it.
01Approved path
The filing goes stale by itself
§ 64.6305(h) has wanted a true-and-correct certification on or before 1 March since 5 February 2026, with any change filed within 10 business days and each day past it counted on its own.
02Human review
Signed under penalty of perjury
§ 64.6305(d)(3)(ii) sends the signature to 47 CFR 1.16, which carries the declaration under penalty of perjury that 28 U.S.C. 1746 allows. State telemarketer registration is not a second database.
04Build an evidence trail
The step taken, the customer it applies to and the officer who signed stay on the filing.
Integrations
Typical integrations
Five system groups connect to the same agent. Which of them are in scope is decided in discovery.
Filing and databaseRobocall Mitigation Database CORES registration records
Traceback and enforcementIndustry traceback consortium Enforcement Bureau notices
A provider-level step-evidence figure can read clean while one upstream provider carries most of the corrections. Nestack reports the counsel-correction rate by upstream provider, not only in total.
Slice performance — reported separately, not only in aggregateIllustrative example
Slice
Failure rate
Lift
Lift vs. threshold
Status
Newly onboarded upstream providers
9.8%
3.6×
Review
Foreign-originated traffic partners
7.1%
2.6×
Review
Reseller and MVNO accounts
4.4%
1.6×
Watch
Long-standing interconnect partners
2.4%
0.9×
Normal
Bar: counsel-correction-rate lift vs. long-standing interconnect baseline · scale 0–4.0× · tick marks the 2.0× review threshold2 of 4 slices over threshold
Evidence-linked improvement
What a stale filing costs
The loop shuts when the unreported change is a regression case. That suite is what the next filing checked is measured against.
Improvement cycle · five stagesSwitchback — the path turns at Improve and returns at Learn
01Detect
Counsel-correction rate rises for one upstream provider.
02Diagnose
The certification that was true the day it was signed and had been wrong for a year is read back until one cause remains.
03Improve
Any change goes out numbered, with the accounts behind it attached.
04Verify
One upstream case still failing is enough to hold the release back.
05Learn
One case joins the suite, one line joins the mitigation record.
Learn → DetectThe return edge. The next filing is measured against a suite one case longer.
Typical build scope
Twelve workstreams across six weeks
The build scope read against the delivery timeline. Week structure follows the six-week plan — discovery, sources, filing assembly, evaluation, integration, then production validation and handover.
WorkstreamWeek 1Week 2Week 3Week 4Week 5Week 6
01Recertification-workflow discovery and boundary work.
02Traceback and screening sources.
03Upstream-provider and step-evidence coverage mapping.
04Step evidence ingestion.
05Account, field and clock binding.
06Completeness scoring and counsel routing.
07Officer certification workflow.
08Traceback and case-system integration.
09Traceback and screening cases.
10Guardrails and certification controls.
11Filing-trail instrumentation.
12Deployment, documentation and Agent Care handover.
12 workstreams · 6 weeks · bar shows the weeks a workstream is active — several run in parallelFinal scope and sequence confirmed in discovery
Engagement tiers
What each tier includes
Rows are the capabilities named in each tier's scope. Higher tiers include everything below them.
Capability✓ in scope · — not at this tierPilotOne provider group, one yearProductionProduction recertification workflowAdvancedMultiple entities / OCNs
Introduced at Pilot
Draft assembly from your steps✓✓✓
Named-officer certification✓✓✓
Mitigation-programme baseline✓✓✓
Introduced at Production
Reporting by upstream provider—✓✓
Certification workflow in your systems—✓✓
Approved write-back—✓✓
Traceback-system integration—✓✓
Introduced at Advanced
Multi-entity filing duties——✓
Cross-account evidence packs——✓
High traceback volume——✓
Multi-provider screening controls——✓
Build priceFrom $5,000From $8,000Custom quote
Final build priceConfirmed after discovery based on integrations, workflow complexity, transaction volume, approval controls and deployment requirements.
Separate from buildBuild pricing is separate from recurring Agent Care, which covers managed monitoring, evaluations, incidents and verified improvements after launch.
What we need from you
What you bring, and what we build with it
Each input maps to a piece of build scope and a week in the delivery timeline.
You bringWe build with it
01Your mitigation programme as operated→Step mapping and evidence captureWeek 1
02Representative tracebacks and screening files→Traceback binding, account mapping and the draft baselineWeek 2
03Your upstream providers and their listings→Step mapping, account binding and the automation boundaryWeek 1
04Access to relevant APIs, feeds or exports→Traceback, CRM and interconnect-source assessment, then integration setupWeek 2
05Filings you would not want re-read→Traceback cases and the evaluation suiteWeek 4
06What no mitigation filing may claim→Completeness scoring, counsel routing, guardrails and certification controlsWeek 3
07A named officer to certify and file→Officer certification workflow, then pilot and production validationWeeks 5–6
Nothing else is requiredDeployment, documentation and Agent Care handover are ours.
Delivery timeline
Four phases across six weeks
Width here is worked time rather than layout space, and so two bands have to share the fifth week.
PhaseW1W2W3W4W5W6
DiscoveryW1
BuildW2 – W3
EvaluateW4 – W5
Pilot & LaunchW5 – W6
Week focusW1Recertification workflow discovery, step mapping and the automation boundaryW2Source integration and the mitigation-programme baselineW3Draft assembly, clock logic and certification controlsW4Evaluation suite, traceback cases and failure-mode testingW5Case integration, pilot changes and targeted correctionsW6One recertification year run under the signing officer, then Agent Care handover
Reading the bandA bar runs across only the weeks its own work is named in. The fifth week doubles because two phases sit in it.
At the end of W6Once the mitigation record validates, Agent Care assumes the agent.
DurationSix-week plan shown · typical delivery 4–6 weeks depending on scope confirmed in discovery.
Next step · Telecom AI agent
Build a robocall mitigation agent around a filing that ages while nobody touches it.
Show us what your standing Robocall Mitigation Database filing claims today, and what has moved since. A named officer signs it under penalty of perjury, through § 64.6305(d)(3)(ii) and 47 CFR 1.16. Your CPNI certificate falls on the same day and shares nothing else with it.
