The comments on USTelecom’s petition on behalf of voice service providers clarify the need for appropriate call blocking codes and notifications. Editor’s note: This article is available for members only.
6/8/2021 11:00
On June 4, ACA International and several industry trade associations filed comments stating partial opposition to a USTelecom petition seeking flexibility from the Federal Communications Commission for voice service providers “to select the appropriate code or tool to notify callers that their calls have been blocked.”
“Although we appreciate the good-faith efforts of voice service providers to design systems to provide notification of blocking, we oppose USTelecom’s request to eliminate the requirement to utilize the notification methods prescribed by the commission,” the comments from ACA, the American Association of Healthcare Administrative Management, 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, National Retail Federation and Student Loan Servicing Alliance state.
USTelecom filed its petition in response to the FCC’s fourth report and order on Advanced Methods to Target and Eliminate Unlawful Robocalls, which required telephone companies that block calls and their analytics engines (collectively, voice service providers or providers) to use specific Session Initiation Protocol (SIP) codes to notify the caller that its call has been blocked on an Internet Protocol (IP) network and a specific Integrated Services Digital Network User Part (ISUP) code to notify the caller that its call has been blocked on a time-division multiplexing (TDM) network.
ACA and the industry trade associations request that the FCC continue to require voice service providers to use established SIP and ISUP codes to notify callers about call blocking as required by the Telephone Robocall Abuse Criminal Enforcement and Deterrence (TRACED) Act.
“Should the commission conclude that voice service providers need additional time to implement the SIP Codes and map them to ISUP Code 21, the commission should identify one or more alternative standardized notification mechanisms that may be used pending implementation of the SIP codes,” the comments from ACA and the industry trade associations state. “The alternative mechanism should provide immediate notification and inform the caller which entity is blocking the call.”
If these codes cannot be finalized by the Jan. 1, 2022, deadline, the commission should require Voice Service Providers to use another standardized notification approach until the above referenced codes are finalized.
Caller ID Authentication and Preventing Unlawful Robocalls
In related news, at its May meeting the FCC the approved a Further Notice of Proposed Rulemaking (FNPRM) seeking comment on shortening the amount of time afforded to certain small voice service providers for implementing Caller ID authentication using the STIR/SHAKEN framework, ACA previously reported.
As a result, the deadline for those providers is now proposed to be June 30, 2022.
Update: Comments on the proposed rule are due by July 9, and reply comments are due by Aug. 9, according to the notice on the Federal Register.
To file comments on the FNPRM, ACA recommends using the FCC’s ECFS Express website and Docket Number 17-97.
Implementation of caller ID authentication technology—specifically, the framework known as STIR/SHAKEN—will reduce the effectiveness of illegal spoofing, allow law enforcement to identify bad actors more easily, and help voice service providers identify calls with illegally spoofed caller ID information before those calls reach their subscribers, according to the FCC.
During its June 17 meeting, the FCC will consider a Report and Order to implement Section 10(a) of the TRACED Act by adopting a streamlined process that will allow private entities to alert the FCC’s Enforcement Bureau about suspected unlawful robocalls and spoofed caller ID.