Last week the FCC issued the Sixth Report and Order related to STIR/SHAKEN – and you may need to take some actions as a result.
This update is not particularly controversial – and sadly it doesn’t yet address the issue of TDM calls – but it does contain a few sensible improvements to the rules:
- There’s a new requirement that the first intermediate provider who receives an unsigned SIP call should sign that call before passing it further into the network. At first glance this doesn’t do much – because all an intermediate provider can do is sign with Attestation C, and this provider has no real knowledge about the legitimacy of the caller ID. However, this is actually very sensible – it increases the proportion of calls on the network that are signed, and in a traceback scenario (hunting down an illegal robocaller) it allows investigators to quickly identify the intermediate provider, who can then identify the originating service provider who sent them the call. So traceback efforts become much more effective.
- There’s now a blanket requirement that basically everyone needs to file a robocall mitigation plan in the robocall mitigation database – whereas before you weren’t actually required to file a robocall mitigation plan if you had fully implemented STIR/SHAKEN. It makes sense that the FCC now wants all service providers to explain how they’re going to prevent robocalls from originating in their network.
- The last big change, is that the FCC has given more details on what it expects to find in the robocall mitigation plan. The overall requirement is still to take reasonable steps to avoid originating illegal robocall traffic, but the FCC has now given guidance on what information you need to include in your plan – see the quote below for more details.
What exactly did the FCC say?
In paragraph 40 of the new Report and Order, the FCC writes:
We now impose specific additional requirements for the contents of robocall mitigation plans filed in the Robocall Mitigation Database. Specifically, as part of their obligation to “describe with particularity” their robocall mitigation techniques,
FCC Sixth Report and Order in the matter of Call Authentication Trust Anchor
(1) voice service providers must describe how they are meeting their existing obligation to take affirmative, effective measures to prevent new and renewing customers from originating illegal calls;
(2) non-gateway intermediate providers and voice service providers must, like gateway providers, describe any “know-your-upstream provider” procedures in place designed to mitigate illegal robocalls; and
(3) all providers must describe any call analytics systems they use to identify and block illegal traffic, including whether they use a third-party vendor or vendors and the name of the vendor(s).
To comply with the new requirements to describe their “new and renewing customer” and “know-your-upstream provider” procedures, providers must describe any contractual provisions with end-users or upstream providers designed to mitigate illegal robocalls. We conclude that the obligation to describe these procedures is particularly important for voice service providers without a STIR/SHAKEN implementation obligation.
There’s a lot more information in there – including some additional requirements for the information you need to include in your updated filing – so be sure to check out the original document, and run this past your regulatory consultant / legal team. The FCC has given a deadline of 30 days after publication of these rules in the Federal Register. As far as I can tell this hasn’t happened yet, but presumably will happen soon – so if you need to submit a new filing you should act promptly.
STIR/SHAKEN Deadline: June 30, 2023
Finally, I would be careless not to remind you that June 30, 2023 is an important day in STIR/SHAKEN land. If you are a service provider with fewer than 100K lines, then you qualified for a two year extension beyond the original deadline (June 30, 2021) – but those two years are almost up. If you don’t yet have a plan to implement STIR/SHAKEN, this would be a really good time to make that plan.
For more general background, please check out my three YouTube videos on the subject, and feel free to contact us directly if you’d like some advice on your options.
