Via Electronic Filing
Ms. Marlene H. Dortch, Secretary
Federal Communications Commission
445 12th Street, S.W.
Washington D.C., 20554
Dear Ms. Dortch,
On October 26, 2022, Rebekah Johnson, Sarah Delphey, and Pierce Gorman of Numeracle and KarlaMcKenna, Stephan Wolf, and Peter Warms with Global Legal Entity Identifier Foundation (GLEIF) met by conference call with the following FCC representatives: Pamela Arluk, Erik Beith, Janice Gorin, Jonathan Lechter, Liz Drogula, and Merry Wulff of the Wireline Competition Bureau; and Kristi Thornton, Jerusha Burnett, Karen Schroeder, and Aaron Garza of the Consumer and Governmental Affairs Bureau.
The purpose of this meeting was to discuss the Commission’s efforts to combat illegal and unwanted robocalls with authentication caller ID technologies. Numeracle and GLEIF made their presentation based on the attached slides.
Established by the international Financial Stability Board in June 2014, the Global Legal Entity IdentifierFoundation (GLEIF) is tasked to support the implementation and use of the Legal Entity Identifier (LEI).The foundation is backed and overseen by the Regulatory Oversight Committee, representing public authorities from around the globe that have come together to jointly drive forward transparency within the global financial markets. GLEIF is a supra-national not-for-profit organization headquartered inBasel, Switzerland.
GLEIF makes available the Global LEI Index, the only global online source that provides open, standardized, and high-quality legal entity reference data. By doing so, GLEIF enables people and businesses to make smarter, less costly, and more reliable decisions about who to do business with.
Numeracle and GLEIF requested the Commission revise the call authentication framework to includeKnow Your Customer and to deliver authenticated call information to the call recipient for an end-to-end call authentication framework.
Numeracle and GLEIF noted that while the Commission’s actions to combat robocalls are working solidly to authenticate calls from originating to terminating carrier, gaps remain at the beginning and end of the call flow. We stated that the current practices do not adequately vet who originated the call nor do they provide that information to the call recipient.
Specifically, we requested that the Commission require originating service providers to apply an A-level attestation for calls signed with an RCD PASSporT and a verifying certificate with a Legal Entity Identifier(LEI). With an LEI, the KYC process is already completed by a globally recognized and accredited vetting organization. Terminating service providers can achieve high confidence of trust in certificates backed by an LEI certificate. GLEIF shared precedents for the adoption of the LEI by other commissions and regulations in the financial sector. https://www.gleif.org/en/lei-solutions/regulatory-use-of-the-lei.
Based on Congress' statement in the TRACED Act, the FCC has the authority to address the gaps not addressed by STIR/SHAKEN. The two key areas outside of STIR/SHAKEN in need of Commission attention to bring an end-to end solution for call authentication are Know Your Customer and the presentation of authenticated information to call recipients. Congress empowered the FCC to go beyond STIR/SHAKEN if necessary to protect the public interest: “The Commission shall … based on the assessment under subparagraph (A), revise or replace the call authentication frameworks under this section if theCommission determines it is in the public interest to do so … “ TRACED Act Section 4(b)(4).
At the call termination end, little to no information is presented to the call recipient about the authenticated identity of the caller. With Apple iPhones, for example, the STIR/SHAKEN call verification status is not shown on the incoming call screen but rather is only shown in the call log after the call has been completed. The call recipient has no information in real time from STIR/SHAKEN about whether the identified caller is verified or not. While the analytics partners of the carriers purport to incorporateSTIR/SHAKEN call authentication into their algorithms, they do not disclose how this is done and the consumer has no information about whether and how call authentication information was used in displaying the name of the caller or the labeling of the call as spam or fraud.
Numeracle and GLEIF request that the Commission use the authority given to it by Congress to make a true end-to-end call authentication framework to protect American consumers.
CEO Numeracle, Inc.