Industry Urges Transition to IP Networks for Caller ID Authentication

The FCC should "adopt a forward-looking approach" that focuses on deploying IP-based solutions rather than "retrofitting non-IP networks and infrastructures in the overall pursuit of greater call authentication," said Verizon. Acting on non-IP network authentication is "unnecessary and ill-advised at this time," said USTelecom. The group cited Stir/Shaken deployment and industry efforts to deploy IP-based networks: “IP-based networks provide flexibility and efficiencies for future changes to the communications network that are simply not possible with TDM networks.” The Competitive Carriers Association agreed and said upgrading TDM tandem switches to IP-based networks would "boost caller ID authentication efforts much more significantly and efficiently than mandating non-IP authentication."

Efforts to authenticate calls are "thwarted, and the resources squandered, by the continuing presence of non-IP networks in the call path," said the Cloud Communications Alliance. The group backed ending the exemption for non-IP network providers to implement caller ID authentication. "Non-IP networks today are a serious impediment to deployment," said ZipDX. It recommended requiring providers carrying traffic over non-IP facilities to report specific information for the commission to assess progress on non-IP solutions it may adopt. ATIS standards for non-IP "have merit," ZipDX said, but the burden of implementing such standards "should fall on the providers that operate non-IP networks." If non-IP solutions are mandated, “every provider should be required to send onward only signed calls,” it said.

The FCC could require large incumbent LECs to accept traffic in IP from upstream IP voice providers, hand off traffic in IP and use Stir/Shaken "when the next network in the call path is IP-based," said NCTA. There's "no technological impediment" to transitioning from TDM equipment to IP, which could be implemented "much more efficiently and effectively" than non-IP authentication solutions, the group said. If the commission does adopt a non-IP solution, NCTA asked that TDM providers "compensate IP providers for any costs incurred in implementing the non-IP solution." Adopting non-IP solutions would "eliminate incentives for other providers to transition to IP solutions," said the Voice on the Net Coalition: If industry "cannot reach a consensus on solutions, the commission should take more proscriptive action."

Don't continue the extension of Stir/Shaken compliance for non-IP networks, said WTA, citing "fully developed and finalized" standards issued by ATIS. WTA noted many of its members also can't "effectively" implement Stir/Shaken because "they must hand off their originating voice calls to an intermediate service provider that uses a TDM access tandem that does not pass on the Stir/Shaken header." The group said ATIS' 2021 out-of-band standard is a "feasible and effective alternative" if an all-IP network "is not possible at this time."

Out-of-band (OOB) is "a better choice for most providers that rely on non-IP technology and are not yet ready or able to transition to IP," said TransNexus, adding there are "no compatibility concerns" between it and Stir/Shaken. Aureon said OOB would help small non-IP carriers "avoid expending limited resources to negotiate multiple in-band information exchange agreements with other carriers." It would also “reduce disputes among carriers regarding transport costs,” Aureon said. The FCC "should be skeptical of those arguing for further delay or continued work on these non-IP standards," said NTCA. The group also backed a "network edge" rule that would "operate as a default apportionment of costs among operators" and "promote widespread caller ID authentication" with IP interconnection.

The FCC should “require non-IP network providers to implement a commercially available solution as soon as practicable,” said American Bankers Association, ACA International, American Financial Services Association, Credit Union National Association, Mortgage Bankers Association, National Association of Federally-Insured Credit Unions, National Council of Higher Education Resources and Student Loan Servicing Alliance, in joint comments. The groups asked that calls placed by "legitimate callers" be given an A-level attestation, the highest form available: "As call authentication solutions are more fully implemented, it will be increasingly critical that legitimate callers receive A-level attestation."