Industry Seeks More Consistent Stir/Shaken Implementation

Voice service or downstream providers that “sign calls on behalf of an originating provider” should only do so “with the originating provider’s token, except in limited circumstances,” said USTelecom. The FCC could also clarify that a “customer” is an end user and not a wholesale upstream provider. “Doing so will ensure that when intermediate providers sign traffic, they do not apply A- or B-level attestations when they do not know who the actual end user caller is,” USTelecom said.

Don't base the efficacy of Stir/Shaken solely on “how well it effectuates the authentication of caller ID information,” said Voice on the Net Coalition. The FCC should instead mandate IP interconnection and eliminate TDM options, the group said. Stir/Shaken adoption “has been hindered by carriers that have not transitioned to IP,” said NCTA: “As a result of incumbent LECs’ failure to transition to IP, billions of calls continue to be exchanged without appropriate authentication information.” The group backed measuring how the “lack of progress in the IP transition has limited … Stir/Shaken’s effectiveness for consumers.”

Require “customer due diligence and know your customer requirements” for originating service providers and ask Congress to extend the commission’s authority over authenticated caller information presentation providers, said Numeracle. Providers "employ wildly different processes and procedures for the performance of know your customer and customer due diligence actions," Numeracle said: "These differences erode the trustworthiness and therefore the effectiveness of Stir/Shaken call signatures." It backed requiring all providers to submit detailed robocall mitigation plans regardless of their Stir/Shaken implementation status.

Don’t “revise the implementation extensions previously granted for the implementation of Stir/Shaken,” said Transaction Network Services. Any extensions should be coupled with “aggressive enforcement” to ensure implementation. TNS asked the FCC to investigate instances of “unsupported attestations” and take enforcement actions when necessary.

The “primary barrier to their participation is the use of TDM switches owned by other providers that rely on the non-IP Stir/Shaken extension,” said TransNexus. Many non-rural small providers "are interconnected VoIP providers that already have IP connections to the telephone network and therefore do not face the switching equipment issues anticipated by the small provider extension," it said. TransNexus opposed assessing Stir/Shaken's effectiveness based on "preventing illegally spoofed robocalls or preventing all illegal robocalls." Call authentication is "an important and necessary component of measures to prevent illegal robocalls," it said: "However, it is not sufficient to prevent illegal robocalls by itself."

The FCC should encourage full participation by focusing on deploying Stir/Shaken on portions of wireline voice networks where it “has yet to be deployed or deployed at scale,” said Neustar. The company noted some calls are given an A-level attestation without meriting it, making it "more difficult for analytics tools to separate good calls from bad calls." It urged the FCC to “encourage all voice service providers to follow the ATIS specifications when determining the proper attestation level to assign to a call.”