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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)
    <20><><EFBFBD>
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