Reply comments on caller ID authentication progress
A few organizations have filed comments on the progress of caller ID authentication implementation, as required by the TRACED Act. Here’s a summary.
The TRACED Act requires the FCC to report by the end of the year its analysis of the extent to which voice service providers have implemented STIR/SHAKEN in their IP networks and non-IP caller authentication in their non-IP networks. This request for comments and reply comments was issued on October 1, 2020 with WC Docket 20-323.
The FCC received nine comments and two reply comments.
Alliance for Telecommunications Industry Solutions (ATIS)
- ATIS has received a significant number of contributions from members proposing mechanisms that could support non-IP authentication, including:
- Out-of-Band SHAKEN, which is defined to be compatible with classic STIR/SHAKEN using the same governance authority, STI certificates, and PASSporT specifications
- TDM-based, which proposes the use of existing ISUP parameters.
- They’re using STIR/SHAKEN on VoLTE wireless and consumer VoIP services.
- They’re expanding this to business VoIP service.
- They’re expanding bandwidth on their network to support transmission of STIR/SHAKEN information in SIP.
- They think it’s premature to assess the effectiveness of STIR/SHAKEN. Although some large carriers are using it, deployment is not sufficiently widespread.
- Comcast signs all calls originating from residential and small- and medium-sized business voice customers.
- They’re receiving signed calls—about 18% of inbound calls in September 2020; 31% of calls to business customers.
- All residential customers are served by the STIR/SHAKEN enabled network.
- Have plans to improve call blocking based on STIR/SHAKEN results combined with data analytics.
- Expect to have the majority of business customers served by STIR/SHAKEN by end of November 2020.
- Encourages the FCC to closely monitor progress toward permitting all service providers to participate in STIR/SHAKEN in light of the indefinite extension granted to service providers that are unable to obtain a certificate.
- INCOMPAS has championed certificate delegation and encourages the Commission to reconsider its decision to require standards for certificate delegation.
- Concerned about the ability of foreign service providers using NANP numbers to certify that they’re using a reasonable robocall mitigation program.
- Service providers should publicly post their contact information to arrange STIR/SHAKEN interop testing.
- Many voice providers cannot register as a Service Provider because they do not access numbering resources directly. This creates two problems:
- The very parties that may be sending unlawful robocalls are not required to attest to their calls. This undermines call authentication.
- Good actors originating calls are unable to play their part.
- The FCC should encourage a system whereby non-carrier voice service providers and enterprise end users could sign their own calls.
- Lumen is signing all IP-originated calls and transiting signed calls to providers that can receive them.
- Equipment availability and software updates could delay Lumen’s implementation timeline.
NTCA – The Rural Broadband Association
- The FCC report to Congress should cover progress and barriers that remain.
- The lack of end-to-end IP interconnection is a barrier to efficient deployment of STIR/SHAKEN.
- Rural customers face a “reverse rural call completion issue.” Their calls will be considered suspicious because of the lack of end-to-end IP interconnection.
- Out-of-Band signaling holds significant promise.
- The Commission should make clear to Congress that completion of the OOB standard is necessary to ensure that consumers nationwide can access caller ID authentication.
- T-Mobile exchanges STIR/SHAKEN calls with 14 service providers.
- Call blocking and labeling is accomplished using a combination of STIR/SHAKEN authentication and reasonable analytics.
- Replied to NTCA comments about how the need to exchange voice traffic in IP is a barrier to ubiquitous deployment of STIR/SHAKEN.
- USTelecom acknowledges the importance of this issue but urged the FCC to focus on positive momentum in its report to Congress.
- Difficulties faced by smaller providers have been addressed with the two-year extension.
- Work continues in the ATIS Non-IP Call Authentication Task Force.
- Verizon uses STIR/SHAKEN on all of their wireless traffic and bilaterally exchange STIR/SHAKEN traffic with 14 other service providers.
- Verizon has begun to sign some wireline traffic for some enterprise customers.
- Verizon is expanding the scope of use cases that can be handled and introducing concepts beyond the initial baseline.
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