ACA and Industry Stakeholders Advance Advocacy with FCC on Call Authentication

FCC logo Comments outline addressing gap in FCC call authentication, including examples of lost calls on certain networks.

12/16/2022 1:45 P.M.

3.5 minute read

ACA International and its coalition partners from joint industry trade groups have filed comments supporting the Federal Communications Commission’s plan to implement caller ID authentication for networks that cannot support the STIR/SHAKEN industry standards, which digitally validates calls.

The FCC extended its comment request on the plan after ACA and its coalition partners ensured the standards will reflect concerns from callers and the impact they will have on callers, ACA previously reported.

The FCC sought more focused input on caller ID authentication technology for non-IP networks and how best to address the remaining gap in the FCC’s caller ID authentication plans.

Non-IP networks essentially don’t have the tools to accommodate the STIR/SHAKEN call authentication framework as required under the Telephone Robocall Abuse Criminal Enforcement and Deterrence (TRACED) Act passed to mitigate illegal and unwanted robocalls.

What happens if a network used by a voice service provider can’t support caller ID authentication? The provider needs to switch networks or come up with a comparable technology that can be used on a non-IP network, which was at the center of this comment request.

ACA and its coalition partners, the American Bankers Association, 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 the Student Loan Servicing Alliance, strongly support the FCC’s efforts to implement caller ID authentication solutions on non-IP networks to further prevent legitimate calls from being blocked, according to the comments (PDF).

This includes advocacy for a requirement that providers who don’t have modern IP networks (and hence can’t conduct STIR/SHAKEN call authentication) should adopt a commercially available workaround so that they too can generate or pass along call authentication information. This closes a gap that now prevents authentication information from being sent and thus enables spoofing.

ACA and its coalition partners found evidence showing that the presence of non-IP networks is substantially undermining the STIR/SHAKEN framework. For example, TransNexus (a provider of telecommunications solutions) found an increase between January and August 2022 in the number of providers “signing” calls under the STIR/SHAKEN call authentication framework.

However, each month during this time period, only 24% of calls delivered to recipients included STIR/SHAKEN call authentication information, according to the comments. For the remaining calls, either the call was not signed at origination or that signature was lost during the call’s transit, indicating that non-IP networks may be preventing the transmission of the attestation information. Both network providers and companies have invested resources to implement STIR/SHAKEN.

Additional comments include:

  • The coalition takes no position on which of the available technologies should be used, and it may be appropriate to allow non-IP providers to adopt a solution that works best for them, as long as the solution has the ability to transmit to the terminating carrier information regarding caller ID authenticity.
  • The requirement to implement a solution should apply to all non-IP providers in the call chain.
  • The coalition urges the FCC and voice service providers to ensure that calls placed by legitimate callers receive “A-level” attestation, which is the highest form of attestation available. As call authentication solutions are more fully implemented, it will be increasingly critical that legitimate callers receive A-level attestation, which will ensure that these calls are completed.

Call Authentication Goals

Congress has directed the FCC to separately address caller ID authentication for non-IP networks. The TRACED Act requires the commission to mandate that voice service providers take “reasonable measures” to implement an effective caller ID authentication framework in the non-IP portions of their networks, according to the FCC.

The FCC adopted rules implementing this statutory direction and, since those rules were adopted, industry technologists have made progress on standards for non-IP caller ID authentication. Specifics need to be hashed out with industry input collected through comments, including those from ACA and its coalition partners.

Comments are due by Jan. 11, 2023. To submit comments on the notice of proposed rulemaking, visit the FCC’s Electronic Comment Filing System and file under CG 17-59. For more information on the proposed rulemaking, click here.

If you have executive leadership updates or other member news to share with ACA, contact our communications department at [email protected]. View our publications page for more information and our news submission guidelines here.

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If you have executive leadership updates or other member news to share with ACA, contact our communications department at [email protected]. View our publications page for more information and our news submission guidelines here.




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