# Material Change Update Procedures Guide

## Implementation Handbook for Voice Service Providers

**Prepared by Performance West Inc.**
**Effective Date: 2026**

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## 1. What Is the Material Change Requirement?

Under the FCC's 2025 RMD Report & Order (effective February 5, 2026), all providers with an RMD filing must update their certification within **10 business days** of any material change to their operations, ownership, or filing information.

Failure to update within 10 business days can result in a **$1,000 per day forfeiture**.

**Regulatory basis:** 47 CFR § 64.6305, 2025 RMD Report & Order (FCC 25-6)

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## 2. What Counts as a Material Change?

| Category | Examples |
|---|---|
| **Ownership** | Change in controlling interest, merger, acquisition, new parent company |
| **Corporate identity** | Legal name change, DBA change, new EIN |
| **Contact information** | New robocall mitigation contact person, email, phone, address |
| **STIR/SHAKEN status** | Change from partial to full implementation, switch to a different STI-CA, loss of SPC token |
| **Provider classification** | Adding gateway operations, ceasing to be a VSP, becoming an intermediate provider |
| **Upstream provider** | Changing the upstream carrier that provides STIR/SHAKEN signing |
| **Robocall mitigation program** | Significant changes to KYC procedures, analytics vendors, blocking policies |
| **Trade names / DBAs** | Adding or removing names under which you operate |

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## 3. Implementation Steps

### Step 1: Designate a Compliance Officer

Assign one person (and a backup) as the **RMD Compliance Officer** responsible for:
- Monitoring for material changes
- Initiating the update process within 10 business days
- Maintaining an audit trail of updates

**Recommended:** The same person who is listed as the RMD contact on your filing.

### Step 2: Create a Material Change Checklist

Post this checklist where operations, legal, and management teams can see it:

**When ANY of the following occur, notify the RMD Compliance Officer immediately:**

- [ ] Company name or DBA changed
- [ ] Ownership or controlling interest changed
- [ ] New parent company, merger, or acquisition
- [ ] RMD contact person changed (name, email, phone)
- [ ] Principal office address changed
- [ ] STIR/SHAKEN certificate authority changed
- [ ] SPC token renewed, revoked, or transferred
- [ ] Upstream provider changed
- [ ] Provider type changed (added/removed VSP/gateway/intermediate)
- [ ] Robocall mitigation program materially revised
- [ ] New analytics vendor deployed or existing vendor discontinued
- [ ] Trade names added or removed

### Step 3: Establish an Internal Notification Process

Create a simple workflow:

```
Change occurs (e.g., new upstream provider signed)
    ↓
Department head notifies RMD Compliance Officer (email/ticket)
    ���
Compliance Officer logs the change in the tracking spreadsheet
    ↓
Within 5 business days: prepare updated RMD filing content
    ↓
Within 10 business days: submit update to FCC RMD portal
    ↓
Confirm update accepted, save confirmation screenshot
```

### Step 4: Update the RMD Portal

To submit an update:

1. Log in to the FCC RMD portal at https://apps.fcc.gov/rmd/ (MFA required since Feb 5, 2026)
2. Navigate to your existing certification
3. Click "Update" or "Edit"
4. Modify the relevant fields
5. Re-upload your certification letter/Exhibit A if the mitigation plan changed
6. Submit and save the confirmation page

**Or:** Contact Performance West — we can submit the update on your behalf as your authorized filing agent.

### Step 5: Maintain an Audit Trail

Keep a log of all material changes and RMD updates:

| Date | Change Description | Notified By | Updated in RMD | Confirmation # |
|---|---|---|---|---|
| 2026-03-15 | New upstream provider (ABC Telecom) | VP Engineering | 2026-03-18 | RMD-UPD-12345 |
| 2026-04-01 | Contact email changed to new@company.com | HR | 2026-04-03 | RMD-UPD-12346 |

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## 4. Documenting Material Change Procedures in Your RMD Filing

Your RMD certification should include:

> "[Company Name] updates its RMD certification and CORES registration within 10 business days of any material change, including but not limited to changes in ownership, contacts, STIR/SHAKEN posture, upstream provider, or trade names, per 47 CFR § 64.6305. A designated compliance officer monitors for material changes and maintains an audit trail of all updates."

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## 5. Penalties for Non-Compliance

| Violation | Penalty |
|---|---|
| Failure to update within 10 business days | $1,000/day forfeiture |
| False or inaccurate information in filing | $10,000 base forfeiture |
| Failure to maintain compliant certification | Removal from RMD (downstream carriers must block your traffic within 30 days) |

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## 6. Common Mistakes to Avoid

| Mistake | Consequence |
|---|---|
| No material change language in RMD filing | Filing flagged as deficient |
| Updating only annually during recertification | Misses the 10-day requirement for mid-year changes |
| No internal notification process | Changes happen without anyone updating the RMD |
| Updating the filing but not the Exhibit A | Inconsistency between certification and plan |
| No audit trail | Cannot demonstrate timely compliance if audited |

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*This guide is provided for informational purposes as part of your RMD filing service. It is not legal advice.*

*Performance West Inc. — performancewest.net — 1-888-411-0383*