Numeracle

Numeracle FCC Comment: STIR/SHAKEN & Identity Governance

FCC Filing
August 9, 2023

Numeracle submitted formal comments in FCC proceedings CG Docket 17-59 and WC Docket 17-97, urging the Federal Communications Commission to incorporate structured identity governance (KYC) principles into caller authentication policy. The filing argues that authentication frameworks should move beyond semantic attestation and analytics-driven signaling to establish verified identity as the primary control layer for consumer call presentation.

The comments emphasize that A-level attestation should not be interpreted as a substitute for actual identity verification. Instead, Numeracle advocates for KYC-vetted enterprise identity data to directly support Rich Call Data (RCD) payloads and verified display outcomes, ensuring that the identity shown to consumers is grounded in documented proof of authorization and use-rights. The submission cautions against excessive reliance on analytics-based blocking or labeling mechanisms as standalone governance tools, recommending that such methods be treated as supplementary risk signals rather than primary decision authorities.

KYC Relevance

Know Your Customer governance should be embedded at the center of caller authentication policy. Identity verification must extend beyond network transport security and explicitly support consumer-facing display integrity.

Numeracle’s Perspective

Identity governance should function as the primary trust control within communication ecosystems. Analytical scoring, behavioral monitoring, and reputation models are valuable but should operate as supporting inputs rather than primary arbiters of legitimacy.

This content was developed by Numeracle, the leader in Number Reputation Management and Branded Caller ID solutions for enterprises, contact centers, and service providers. As part of our mission to restore trust in communications, Numeracle creates educational resources to clarify complex topics in telecom, compliance, and call delivery.

Our platform empowers organizations to manage branded calling, improve caller id reputation, and stay compliant with evolving regulatory and industry standards. FAQs like this are designed to provide clear, actionable guidance backed by our expertise in verified identity, call labeling mitigation, and spam prevention.

To explore how Numeracle supports trusted and effective outbound communications, visit www.numeracle.com.
Not sure where to start?
Ready to take control of how your identity is presented to consumers? 
Let us help you choose the right combination of tools based on your industry, goals, and call volume.