Via Electronic Filing
Ms. Marlene H. Dortch, Secretary
Federal Communications Commission
445 12th Street, S.W.
Washington D.C., 20554
Dear Ms. Dortch:
On June 4, 2019, Rebekah Johnson, CEO of Numeracle, Inc., Doug Ranalli, Founder and Chief Strategy Officer of NetNumber, Inc. met with the Arielle Roth, legal advisor to Commissioner O’Rielly. We discussed specific aspects of implementing the call authentication provisions of the TRACED Act, including Numeracle’s concern regarding the need of guidance to voice service providers for enterprise solutions that promote end-to-end trust.
Numeracle is the pioneer of call blocking and labeling visibility and control in the new calling ecosystem, providing actionable strategies for businesses whose legal calls have been improperly blocked or labeled as illegal robocalls. By working with major carriers, analytics companies, app developers, device manufacturers, and industry leaders, Numeracle delivers a path to call labeling control for call originators across the healthcare, retail, safety, government, utility, broadcast, financial, and resort industries.
NetNumber, Inc. brings nearly 20 years of experience delivering core network signaling technology that powers global telecom and enterprise networks. Its software-based signaling-control solutions accelerate delivery of new services like STIR/SHAKEN call signing, Signaling-firewalls, the 5G core, PrivateLTE and IoT/M2M solutions across multi-gen networks, dramatically simplifying the network core and reducing operating expenditures. These solutions span a range of network types from 2G-3G-4G-5G to future G delivered on the industry’s first All-G signaling platform called TITAN. In addition, NetNumberData Services are essential for global inter-carrier routing, roaming, voice and messaging.
We discussed how service providers will comply with the TRACED Act’s authenticate caller ID requirement. To authenticate caller identification information through SHAKEN, the originating voice service provider will determine which of the three attestation levels it will assign to the call. The SHAKEN standards for assigning attestation level requires the originating voice service provider to determine the identity of the calling party and its authorization for use of the number before determining whether to assign A, B or C. Based on SHAKEN standards, the originating service provider will establish a rigorous policy to identify the entity of the caller and authorization for the use of the number to sign with A attestation. Due to the available data in the current standard, the industry expects a flood of legal enterprise calls to be downgraded to a C level attestation.
After reviewing the attestation levels, we compared and contrasted two proposed solutions for elevating signing to A level attestations for enterprises through Delegated Certificate and CentralTelephone Number Database (Central Database) from the ATIS SIP Forum IPNNI Joint Task Force, Study of Full Attestation Alternatives for Enterprises.
Utilizing either the Central Database or Delegate Certificate, the originating service provider can access the number and identity information to provide A level attestation. Both approaches advocate for a“Know You Customer” (KYC) process on the identity of the caller and a process for the authorized use of the telephone number.
We asked the FCC to encourage rigorous policies for voice service providers to obtain reliable, traceable and secure enterprise vetted data for signing with A-Level attestation. We believe the spirit of the TRACED Act demands that enterprise customers who originate calls be vetted before receiving A-level attestation and identified accurately on a call-by-call basis so that accurate traceback can be performed. The information obtained in this rigorous vetting process should be transferable and highly trusted by the end subscriber.
Rebekah Johnson, CEO
Cc (via email)
To view diagrams enclosed, please refer to: https://ecfsapi.fcc.gov/file/1060823732115/FCC_ORielly_ExParte_642020.pdf