Call Authentication NPRM Gets Mixed Industry Reaction

The commission should require all originating and intermediate providers to implement and certify robocall mitigation programs in the robocall mitigation database, said USTelecom. The group backed requiring all providers to implement a robocall mitigation program "regardless of whether they have implemented Stir/Shaken." The FCC should "focus on enhancing existing requirements that are proving effective," it said: "Chasing new, unproven solutions … will only take resources away from continuing to implement and refine the approaches that are working.” The Cloud Communications Alliance agreed and backed requiring non-IP providers to "adopt a commercially available call verification solution."

Require intermediate providers to "authenticate unauthenticated calls they receive," said NCTA. The group said requiring all providers, "including those that have already implemented Stir/Shaken," to adopt non-IP call authentication would be "counterproductive" because many IP-based providers have "dedicated substantial time and resources to implementing Stir/Shaken."

Do a "thorough assessment" of how existing requirements affect illegal robocalls and providers when issuing new rules, Incompas told the FCC. Intermediate providers should be given at least 12 months to comply with any requirement to implement Stir/Shaken, it said, because a six-month deadline would “impose unnecessary burdens on the personnel and resources of intermediate providers.”

Expanding robocall mitigation rules to include intermediate providers is "an essential step in preventing unlawful robocalls from being completed," said the New York Public Service Commission. Implementation costs for those providers “would be greatly outweighed by the benefits afforded to end-user customers,” the PSC said. All providers should be required to "engage in effective mitigation," with "clear, enforceable financial consequences" on those that "knew or should have known that they were transmitting illegal robocalls," said the Electronic Privacy Information Center and National Consumer Law Center in joint comments.

"Rules need to be refined and then followed," said ZipDX, backing the FCC's proposal to require all providers to authenticate calls. The FCC should "compel any U.S. provider over which it has jurisdiction to sign such calls, even with C-level attestation," it said. A C-level attestation "likely will be the appropriate attestation level for U.S. intermediate providers authenticating unsigned calls," said Comcast, saying providers should be allowed to "apply a higher level of attestation if and where possible."

Requiring intermediate providers to "attest to unsigned calls might do more harm than good," said Telnyx. "If more calls begin to reach terminating networks with C attestation, we fear that more legitimate calls … could be inappropriately labeled or blocked," it said. Telnyx said it's "vehemently opposed to any [North American numbering plan] resource access restrictions or service restrictions for VoIP providers." Extend Stir/Shaken obligations "indefinitely" for a "limited universe" of satellite providers that "rely principally or exclusively on non-NANP" resources, said the Satellite Industry Association.

The FCC could require that voice resellers confidentially file robocall mitigation database certifications with the "identity of any wholesale provider that authenticates some or all of their voice calls," said ACA Connects. The group said it isn’t “convinced there is a need for formal robocall mitigation filings from facilities-based small voice service providers that are fully Stir/Shaken-compliant and have not been identified as a source of illegal robocalls.” Don't let a downstream provider’s Shaken authentication "satisfy an upstream provider’s obligation to authenticate calls with Stir/Shaken," said TransNexus. It asked the FCC to phase out the non-IP Shaken caller ID authentication exemption.

Don't adopt a "rigid 24-hour traceback response time," said the Voice on the Net Coalition: It "will likely result in increased enforcement activity and expenses for good actors who for legitimate reasons ... may not respond in a timely manner." VON said it doesn't back requiring providers to take additional steps to prevent illegal robocalls because the "obligation to implement Stir/Shaken is barely two years old." The FCC "should continue to allow voice service providers the flexibility to determine how best to comply" with Stir/Shaken until it has "had more time to determine what is and is not working," it said.