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Troubleshooting: RMD filing lifecycle failures

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How the lifecycle moves (and where it jams)

draft ──▶ submitted ──▶ active ──▶ remediation_required ──▶ active
  │           │            │              │
  ▼           ▼            ▼              ▼
withdrawn ◀── any non-terminal state ──▶ withdrawn ──▶ draft (re-open)

1. active flagged deficient — a carrier or the FCC reports a problem; the filing sits in remediation_required until you resolve it.
2. active past the review date — the recertification verdict flips to overdue and, under enforce, origination blocks with a 403 RMD_RECERT_OVERDUE at call time.
3. Withdrawn by mistake — withdrawn is reversible; re-POST /compliance/rmd re-opens the same registration to draft.
4. Draft will not submit — mandatory fields (usually the mitigation plan) are missing; the response’s details array names every blocker.
5. 409 on re-file — RMD_LOCKED, RMD_INCOMPLETE, and RMD_INVALID_TRANSITION each mean a different wrong move.

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Symptom → cause → fix

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Symptom 1: filing flagged deficient (the “filed but flagged” state)

curl "https://api.orbit.devotel.io/api/v1/compliance/rmd" \
  -H "Authorization: Bearer $ORBIT_API_KEY"

1. Treat the cause — re-file with the FCC RMD portal once the filing content is corrected (a bounced contact email, a stale mitigation plan, an incomplete address).
2. Resolve the flag:

curl -X POST "https://api.orbit.devotel.io/api/v1/compliance/rmd/resolve" \
  -H "Authorization: Bearer $ORBIT_API_KEY" \
  -H "Content-Type: application/json" \
  -d '{"notes": "Contact email corrected and re-filed with the FCC."}'

3. If your enforcement mode is enforce, origination unblocks the moment the resolve lands; in warn, the flag clears on the next call.

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Symptom 2: certified-but-expired (silent recertification lapse)

{
  "data": {
    "registration": {
      "status": "active",
      "certified_at": "2025-08-31T14:00:00.000Z",
      "recert_interval_days": 365,
      "recertification": {
        "due_at": "2026-08-31T14:00:00.000Z",
        "status": "due_soon",
        "days_remaining": 12,
        "overdue": false,
        "reason": "The RMD certification review date is approaching; recertify to keep the filing current."
      }
    }
  }
}

1. Re-attest with the FCC (periodic review / re-certification of a current filing).
2. Restart the clock by re-certifying. Two routes reach active and set a fresh certified_at:
   • if you walked the filing through a deficiency, POST /compliance/rmd/resolve;
   • if the filing is still plain active, withdraw it and re-file it as below (Symptom 3) — the re-file path mints a new certified_at when you re-certify.
3. Watch recert_interval_days when you next edit a draft: set the review cadence your counsel requires instead of the 365-day default. The field applies at draft time and survives for the life of the registration.

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Symptom 3: withdrawn filing still being originated (guard defaults)

{
  "data": {
    "registration": {
      "status": "withdrawn",
      "withdrawn_at": "2026-08-28T09:41:00.000Z"
    },
    "enforcement": { "mode": "off", "updated_at": null }
  }
}

1. Re-open the withdrawn filing to draft:

curl -X POST "https://api.orbit.devotel.io/api/v1/compliance/rmd" \
  -H "Authorization: Bearer $ORBIT_API_KEY" \
  -H "Content-Type: application/json" \
  -d '{
    "company_name": "Acme Communications LLC",
    "business_address": "100 Market Street, San Francisco, CA 94105",
    "stir_shaken_status": "partial",
    "mitigation_plan": "…",
    "contact_name": "Jordan Lee",
    "contact_email": "compliance@acme.example"
  }'

2. Correct the mandatory fields (see Symptom 4 if you get a 409 RMD_INCOMPLETE).
3. POST /compliance/rmd/submit (records the FCC filing reference), then POST /compliance/rmd/certify when publication is confirmed. The recertification clock restarts from that new certified_at.
4. Review the enforcement mode before you turn the filing back on: if the withdrawal was a deliberate pause of origination, putting the guard straight back to enforce re-blocks calls the minute certify lands. Set it with PUT /compliance/rmd/enforcement (see RMD registration) — and remember off is the tenant-owned default; nothing platform-level forces you into a gate.

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Symptom 4: draft won’t submit — incomplete mandatory fields

{
  "error": {
    "code": "RMD_INCOMPLETE",
    "message": "The RMD registration cannot be submitted yet.",
    "status": 409,
    "details": [
      "a robocall-mitigation plan is required unless STIR/SHAKEN is fully implemented (stir_shaken_status = 'complete')"
    ]
  }
}

1. POST /compliance/rmd with the missing field filled in (only allowed while the filing is still draft or withdrawn — a filed registration is mutated through the lifecycle endpoints).
2. Re-POST /compliance/rmd/submit. The same four calls always succeed once every blocker resolves.
3. If the filing is already past draft (submitted or active), stop editing it in place — 409 RMD_LOCKED is the surface telling you to go through submit / certify / remediation / resolve / withdraw instead.

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Symptom 5: 409 conflict on re-submit or re-file

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Error-code quick reference (RMD endpoints)

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What not to do

• Do not re-activate the withdrawn filing without reviewing the guard. If enforcement.mode is enforce or warn, bringing the filing back to active flips the origination verdict instantly. A deliberate pause becomes an accidental block, a warn becomes a quiet resume. Review the mode with the same care you review the filing.
• Do not PUT "certified" manually. The only route to active is POST /compliance/rmd/certify (or POST /compliance/rmd/resolve) after a real submitted state — a hand-edited record would carry a certified_at that no filing ever supported, and every downstream check trusts that timestamp.
• Do not try to edit a filed registration. 409 RMD_LOCKED is the surface refusing in-place mutation; it is intentional. Walk the lifecycle endpoints instead.
• Do not treat a poll-loop on GET /compliance/rmd as a substitute for counsel. The filed data stays with you; the platform records it. This page is operational guidance, not legal advice.

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See also

• RMD filing lifecycle — the full happy path, the recertification verdicts, and the endpoint reference.
• Send gates — the outbound gate stack the origination guard reads alongside.
• STIR/SHAKEN attestation — the level you assert on the filing and what callers see.
• ITG traceback — the companion obligation once your traffic is attributable.
• Troubleshooting — the rest of the fault-finder pages if this symptom list didn’t cover yours.