ATIS: FCC FNPRM Has Wrong Information About Rich Call Data and Caller ID
The Alliance for Telecommunications Industry Solutions said this week that the FCC's further NPRM seeking comment on tougher call ID rules gets the facts wrong on the issue of Stir/Shaken and the role that rich call data (RCD) could play. Other industry commenters said handing down rules now could chill industry progress addressing caller ID issues. In addition to proposed rules on caller ID, the FNPRM, approved in October, also seeks input on requiring labels for calls that originate outside the U.S. (see 2510280024). Comments were posted this week in docket 17-59.
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ATIS said that in the notice, the commission “states that, while the SHAKEN standards apply the determination of the attestation level only to the authenticating provider’s knowledge of its direct customer and that customer’s right to use the telephone number it transmits, the SHAKEN RCD standard requires the originating voice service provider to vet the caller identity information it transmits.” The statement about the RCD standard “is not accurate -- there are situations in which the originating service provider cannot and does not vet the caller identity information.”
The alliance also reminded the FCC that there's no industry testbed to examine RCD interoperability issues and that there are “multiple RCD specifications,” not all of which are “aligned.”
As branded calling rollouts progress, industry “still has critical work to do before the full promise of these technologies can be realized,” CTIA said. Reliably vetting digital ID enterprise callers -- “setting aside individual callers, which the FNPRM’s proposal does not distinguish -- is a monumental task, and the wireless industry is rapidly rising to meet the challenge.” The group said the FCC shouldn’t issue rules or mandates “that could disrupt the significant momentum” and “hinder the market from identifying the best solutions for enterprise callers and consumers alike.”
USTelecom warned that Stir/Shaken wasn’t “designed to identify callers or, on its own, determine call legitimacy, and proposals to mandate caller identity or verification requirements are premature.” Data now available shows that many illegal calls, including scams, “are signed and carry the highest level of attestation, underscoring that caller ID authentication alone is not a proxy for call legitimacy,” it said. The FCC should “preserve the integrity” of the Stir/Shaken framework “by maintaining a clear and consistent distinction between number authentication and caller identity or call legitimacy.”
NCTA argued that the FCC shouldn’t impose new regulations on legitimate call providers and should instead push industry to complete the IP transition. As the commission “is aware,” Stir/Shaken call authentication “only works when calls travel end-to-end in IP,” NCTA said. But a substantial portion of voice traffic today still “originates on or transits a legacy time-division multiplexing network, frustrating and even nullifying efforts and investments in IP-based robocall mitigation technologies.”
Incompas agreed that completing the IP transition is the most important next step for the FCC. The time-division multiplexing “gap” means that Stir/Shaken authentication information is stripped from about 61% of signed calls, the group said. Until the IP transition is complete, “enhancements to caller identity verification and branding will remain incomplete and unreliable, fundamentally undermining the Commission’s goals with its reopening of the record in this proceeding.”
Call labeling is “a complex, dynamic, and quickly evolving market in which the commission should allow more, rather than less, flexibility to innovate,” Verizon said. The carrier noted that it’s launching branded calling ID “at scale” this year, “which on its own will fundamentally enhance how our wireless customers experience receiving calls from trusted and verified businesses.”
T-Mobile also urged the FCC to take a cautious approach. "Consumers are more likely to answer a call when identity information is displayed (such as a name, logo, or reason for calling) and are similarly likely to avoid calls without caller identity information," it said. That means “inaccuracies or overstatements in the presentation of a caller’s identity can have real consumer-protection consequences.”