Industry Seeks More Emphasis on Attestation Levels in Caller Authentication
Industry asked the FCC to place more emphasis on proper attestation levels when calls are authenticated, in reply comments posted Monday in docket 17-97 (see 2210040061). The FCC sought comments on caller ID authentication obligations under the Traced Act and the efficacy of Stir/Shaken for its first triennial assessment. Some companies said Stir/Shaken should be implemented on all portions of a provider's network, and sought additional oversight of carriers transmitting unsigned calls.
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Not all stakeholders are applying Stir/Shaken "consistently" and that "threatens to erode the framework’s value and trust," said CTIA. Use of "appropriate attestations" is "critical to ensuring that the full capabilities and value of the framework are achieved," the group said. CTIA asked the FCC to "encourage" providers to adopt "established ATIS standards" and "properly apply attestation levels." Too many calls receive an "A"-level attestation without justification, said Transaction Network Services: It "calls into question the reliability of the Stir/Shaken attestation provided by the originating carrier." The FCC should "use its authority to empower the industry to self-police improper attestations," TNS said, and removal from the robocall mitigation database should be "used judiciously."
Call attestations aren't effective in combating illegal robocalls "unless the commission ensures that they actually convey meaningful and reliable information," said Verizon. "C"-level attestations don't provide "actionable information" and "undermine the purpose of Stir/Shaken," the carrier said. Verizon backed focusing enforcement actions on providers who "improperly assign A or B level attestations" and encouraging providers to adopt a "robust" know-your-customer program.
It's "still premature to evaluate the efficacy" of the Stir/Shaken framework "in practice" until the FCC and industry "reach consensus on issues like token access and third party authentication," said Incompas. The FCC should allow the implementation extension for small voice service providers to expire in 2023 because it will result in "a better sense of the role the framework is playing in illegal robocall mitigation efforts," it said.
One of the "greatest challenges" continues to be the "lack of IP interconnection," Incompas said. Many providers "continue to face obstacles in reaching IP interconnection agreements with industry partners," it said, and the FCC should "focus on setting expectations that voice service providers will engage in IP interconnection negotiations for the purpose of achieving end-to-end caller ID authentication." The group also asked the commission to "reject any proposal to consider an alternative to the framework."
Stir/Shaken is "on the cusp of working extremely well," said ZipDX, and it's "imperative" the FCC's efficacy assessment includes a discussion of preventing all illegal robocalls in addition to caller ID authentication information. The "biggest impediment" to the framework's efficiency is that some providers ignore attestation rules, the company said. Another is that some downstream providers don't require all providers to "prevent the use of their network to originate illegal traffic," it said.
ZipDX recommended intermediate providers "insist that the calls come to them signed" so only "legitimately unsigned" calls receive "C" level attestation. Focus on deploying "end-to-end IP solutions wherever possible" said HD Carrier. The use of TDM in the call path "denies consumers the benefits of IP-dependent call authentication information," the company said: "The solution has always been, and continues to be, direct-connects in IP at reciprocal bill-and-keep."