Industry Disagreement Continues on Gateway Robocalls FNPRM

Voice resellers have "made the reasonable decision to file a certification in the robocall mitigation database" despite not being obligated to do so, said ACA Connects in docket 17-97. Making it a requirement "could promote transparency and improve the consistency of the data contained in the database," it said. ACA Connects opposed imposing forfeitures on providers "acting in good faith" for failing to block calls on a "per-call basis" after commission notice. Don't impose "prescriptive mandates industry-wide," the group said, including a "hard-and-fast 24-hour deadline to respond to traceback requests."

The "ultimate success of Stir/Shaken depends on widespread implementation of the framework," said NCTA. The FCC should "prioritize broader use" of it and "encourage all providers to transition to IP interconnection," the group said. Requiring use of non-IP authentication frameworks would "divert resources from the transition to IP ... and undermine the efficacy of Stir/Shaken," NCTA said.

Extend Stir/Shaken authentication rules to all intermediate providers, said 51 state attorneys general in a letter. "Illegal robocallers depend upon a relatively small number of unscrupulous VoIP providers who integrate their call traffic into the larger body of legitimate call traffic where it becomes more difficult to detect and stop," the letter said. The AGs asked the FCC to "require voice service providers along the call path to implement Stir/Shaken without delay."

Close the "intermediate provider loophole" and require all providers to implement a robocall mitigation plan regardless of their Stir/Shaken implementation status, said USTelecom. The group also said the FCC should require originating providers to have a token for downstream providers and other third parties to use if they're signing traffic. "If the commission pursues additional regulatory changes" beyond this, it would "ultimately detract from more productive efforts," USTelecom said.

Extend robocall mitigation requirements "in a technology neutral manner without singling out" VoIP providers, said the Cloud Communications Alliance. The group opposed requiring intermediate providers to sign calls because it "will lead to an increased infusion" of C-level attestations and "provide no indication of whether a number has been unlawfully spoofed." Don't hold providers "strictly liable" if illegal calls are transmitted through their networks, the alliance said, which would have "extremely negative consequences for enterprises that lawfully send higher volume traffic," it said.

Some providers are "typically not in compliance with one or more rules that are already in place," said ZipDX. The FCC "must not open a gaping new loophole by allowing calls to be signed with a certificate other than one that identifies explicitly the originating provider," it said. All providers should "follow the rules we already have," ZipDX said, and new rules "must encourage the transition to IP." Providers should be required to "obtain their own Shaken certificate from a STI Certification Authority" and "have their calls signed using Stir/Shaken with their own Shaken certificate," said TransNexus. The group backed phasing out the non-IP Shaken exemption.

The American Bankers Association urged the FCC to allow banks and "other legitimate callers" to make calls using an A-level attestation. Some calls placed by banks "have been wrongly blocked by analytics engines used by telephone companies and their third-party service providers," the bankers said, adding the FCC shouldn't "impose additional restrictions on authenticated calls originated abroad as it would degrade customer service and increase the risk of customer harm." The Satellite Industry Association repeated its call to "indefinitely extend" the Stir/Shaken deployment obligation deadline for satellite providers that "rely principally or exclusively on non-North American Numbering Plan" resources.