Rebekah Johnson: Welcome to Tuesday Talks, a live discussion series where we bring truth and shed light across the brand identity and communications industry. I'm Rebekah Johnson, Founder, and CEO of Numeracle. And I'll be co-hosting today's session with Anis Jaffer, Chief Product Officer at Numeracle. Anis, it's great to get the two of us back together again for the Season 2 kick-off! It's been a while. Anis Jaffer: Yes, it's great to be back! We finished off at the end of November, so it's good to have the break and be back on the podcast now. Rebekah Johnson: Yeah, there's a lot to cover. I thought when we took a break, maybe everything else would take a break, but that didn't happen. So we're going to cover all the activities that occurred between November and today. But one of those really fun activities, speaking of kick-offs, was the Super Bowl. Did you watch the Super Bowl Anis? Anis Jaffer: No, I did not, I think for the first time in many years. I did see the beginning of the game, but I didn't watch it through to the end. I wanted the Bengals to win, I wanted Joe Burrow to win. Rebekah Johnson: We were stacked up with LSU players on both sides, so it broke my heart when OBJ went down, that was not good. And with Joe, I wanted him to get that win, but I was happy either way. It was good to see some different teams fighting for that title. To me, one of the highlights and I think that goes for a lot of people was the halftime show. That's my jam and it brought me back to high school.
My only disappointment was I was expecting a hologram of Tupac, and what I really wanted to see was Biggie. Then it would have been awesome. But for teenagers today, all that music is coming back so I was able to at least connect with the teens because they know that's some cool music, and that's my music right there. I really shock them when I start rapping but we can save that for a different podcast.
Why don't we dive in? We've really got to cover a lot just to catch everybody up on what's occurred. In our last season, one thing that's going to be different is we talked a lot about STIR/SHAKEN, and that was relevant. That was the hot topic for 2021. We talked about the implementation, the Robocall Mitigation Plans, and started moving over into cross-border communications.
So for Season 2 of Tuesday Talks, we're going to broaden the show just a little bit and expand beyond the traditional telecom as being the main topic that we focus on. We're going to add some additional themes around brand identity as it applies to communications, not just voice. It's a little bit of a shift, but we started to lay the foundation, at least the industry did on the telecom side, for us to be able to get to this type of topic with brand identity.
Of course, we came up with this idea, and we decided we should poll people. The world isn't always the way that Rebekah and Anis see the world. So, in a recent poll on LinkedIn, we asked our Tuesday Talk viewers what they believed the biggest telecom achievement was for 2021. And no surprise STIR/SHAKEN implementation at 33%. 17%, said I'm not sure, so you know what, you should probably be watching Tuesday Talk so you can stay informed.
But look at the 50% for the rollout of branded calling, and we made sure to say roll out because it was only getting established with the carriers who were starting to get more comfortable with this concept. It makes sense that we're going to move on to branded calling. My only "AHA" moment is you might scratch your head and ask why nobody voted for the FCC Robocall Mitigation progress. I think the problem is that we titled this "achievement." It was a lot of activity, there was a lot involved. In fact, we're going to go into some statistics around that later, but I don't know if people would chalk it up to an "achievement" in the telecom industry. So, Anis, what are your thoughts on the results of that poll?
Anis Jaffer: I was intrigued in the sense that branded calling I thought would be more of a 2022 activity, but it's good to already see a number of enterprises adopting that in 2021. We saw that happening in the second half of last year. So it does makes sense. STIR/SHAKEN implementation is more applicable on the service provider side, so that makes sense. 2022, I think is going to be more focused on branded calling, and it's a reflection of that and in this call as well. Rebekah Johnson: I think it's awareness in the industry and in the market that enterprises can have some control over their identity. Once they're aware that they can do that, the next question they ask is, how? "How can I do this and where do I go to attain this control?" I think what's going to be interesting is how this changes trust and the consumer's trust of the provider, the carrier provider that they're using to deliver this branded information, and the trust of the information that's coming to them, that it is, in fact, who that entity says that they are. I think we're going to do a lot of talking around trust for 2022 because I think it goes hand in hand.
I've said it before, and I'll probably say it a lot this year, branded calling is one of the scariest things that we can implement because if we don't do it right, and "we" means everyone that is involved in delivering communications and getting that originating call down to the consumer. There are there's a lot of players involved. If we don't do this right and protect that channel to ensure that truly trusted entities are delivering communications, then the whole network and infrastructure becomes suspect by consumers.
This is not something to rush out, from the industry perspective, and immediately rush out and do. There are some steps that we have to take, but the adoption is giving us opportunities as an industry to learn what works, what doesn't work, and how to improve this. That's what has been positive and I think our listeners are going to want to hear more about that as we go forward.
Anis Jaffer: Absolutely. With branded calling, as you said, it's important that we get the trust in place right from the beginning. We do not want to have another CNAM situation where it's free for everybody to put whatever name. That's why we ended up in the place that we are now. It's absolutely critical that we get the identity part nailed before branded calling gets more widely adopted. Rebekah Johnson: That's definitely one thing. I'm all about seeing the 90s music coming back, but I do not want 90s technology coming back. Please, let's not do that, we can move beyond databases. Before we dive deeper into brand identity, let's quickly pause and catch up on the activities that happened between our last episode, on November 16, up until, honestly, yesterday.
So looking at the FCC, they didn't take a break. We had comments and reply comments that were filed for the
Fourth and Fifth Further Notice for Proposed Rulemaking. The Fourth and Fifth centered around the gateway provider requirements for Robocall Mitigation. We did a Tuesday Talk on this last season with Mitch Roth of the ECAC (Enterprise Communications Advocacy Coalition), and we have not seen any other activities from the FCC thus far. But we'll definitely continue to watch and when rules are proposed, we will do another update.
Another hot topic that we're going to be covering in Tuesday Talks this season is around the
Sixth Further Notice for Proposed Rulemaking, which is related to error codes 607 and 608. It's interesting that we're talking about error codes. Yet again, we find the FCC stepping over into standards, which can wreak havoc for carriers and enterprises. And this is something we will absolutely be tracking and I expect we will have some experts to do some myth-busting. We're going to have to shed some light on the truth.
Being that this is standards-related, there is already in preparation for any rulings that come down, the
ATIS IPNNI has established a subgroup that are focused on the unwanted and rejected call blocking path forward and that's what the 608 and the 607 represent and we will go into a little bit more details of that. So a participant, Numeracle is a participant, and I can tell you that there are far more questions than there are answers. I just wonder, could this actually be a distraction from a more effective activity to stop illegal robocalls. It's starting to feel like it's just another exercise that the carriers have to go through and we're not really asking questions if this is achieving what the end goal is to achieve. The smartest people who can answer this problem are working on it, and I hope that the industry listens to what they have to say.
Switching gears from the FCC over to the FTC, they made a bold statement to VoIP providers on none other than Valentine's Day, February 14. And that statement is, "Turn over information for robocall investigations, or prepare to be sued in federal court." Well, that's one way to say 'be mine.' Definitely not feeling the love from the FTC to the VoIP providers. This does set the tone for future interactions and expectations from VoIP providers who received notices. We are definitely going to dive into that one. We've got the FCC from the rulemaking side and the FTC from the enforcement side, really focusing on the voice providers and gateway providers in 2022. I do believe that's on their list so we'll pay attention to that.
Moving over into other things that we're tracking, Numeracle just released our
STIR/SHAKEN Implementation Report and there are over 7,000 voice service providers that are now registered in the STIR/SHAKEN Implementation Database. And Anis, I know that you had some stats that you wanted to share with our listeners. Anis Jaffer: We did a deep dive into the Database, to look at the registered entities, and around 7,000 have registered. Out of that, about 1,800 have declared that they have fully implemented STIR/SHAKEN and around 1,300 have partial implementation. What we also found out was most of the voice service providers who have implemented are issuing an Attestation flag of A if they have a very direct relationship with their clients. If the provider knows their direct client and they know that the calls are being originated by a SIP server and an IP address that they can recognize, then they are issuing A. Everything else is C or sometimes B at this point. That's currently how the STIR/SHAKEN implementation has been.
Now, roughly based on numbers, if it is 1,800 and 1,300 that's about 3,000 so more than half are still trying to figure this out. So that's an ongoing thing. On the terminating side, calls are getting delivered so the fear that calls are not going to get delivered, we've talked about this before in our Tuesday Talks podcast, calls are not going to get dropped and will still get delivered.
Analytics are continuing to perform whatever they were doing before so they're still blocking and labeling calls. There was one instance, or a few instances towards the end of last year where we heard from enterprises that some of their calls were getting labeled more than usual and some of them are also getting blocked. That's something that we heard, but obviously, for our clients, we are working with them and the carriers to get that sorted, but that's something that we have heard.
Then the 607 and 608 codes, as you mentioned, the Fourth and Fifth docs, had suggested that this needs to be implemented by the FCC, had suggested that carriers need to implement and there was a deadline. However, most of them are not implementing it at this point. There are some enterprises who have said that this could be a reason why their calls are getting dropped, but we're not sure first at this point. So there's more to come on that.
Rebekah Johnson: The Standards Group is still trying to write the standard for how and when to use 607 and 608 and there's definitely a lot more thought and consideration to come. Something I don't think we've had as a topic with the blocking of robocall initiatives that includes everything under the sun, from STIR/SHAKEN analytics to databases and whatnot, is privacy. And now we're asking questions of privacy for when a consumer marks a call unwanted or blocked.
I think it's going to have to go beyond just the Standards Group for us as an industry to define how to leverage these error codes, who is notified of these error codes, what information should be going back, and what information should not be going back? Who's the beneficiary of this information and what actions and activities and decisions do they make off of this? There are so many more questions than we have answers for.
It would be helpful, Anis, you and I live in this world, so we're going to say 607 and 608 and we know all the definitions of what that means, so for the benefit of the audience, can you give a real high-level definition of 607, 608, and 603.
Anis Jaffer: 607, 608, and 603 are all error codes, SIP response error codes that were defined by the IETF. The IETF standards body put out these error codes for when a SIP invite is received by a terminating entity, how they should respond back so that the originating entity would know what's going on with that particular session, or a call in this case.
When the FCC proposed the rulemaking, their purpose or intention was to provide a notification that's meaningful to the caller about what happens to a call when the call is not getting terminated. There is a delicate balance of how much information needs to be provided back to the caller, considering how much privacy and security considerations need to go into it. There are two codes that were proposed.
One is 607, which is basically marked as 'unwanted' by the receiving party or the called party. As a subscriber, if I'm receiving a call, if I block it for whatever reason or if I tag it as unwanted, that information can go back all the way to the caller. So that's 607.
608 is blocked by the analytics on the terminating side. So, for whatever reason, if the call gets blocked by the terminating analytics, then a 608 error code can let the caller know that that particular call did not terminate because the call was blocked by the network or the analytics on the network. So those are the two error codes that have been proposed or pretty much mandated at this point based on the Sixth NPRM.
There is a debate about its usefulness or if it is adding any additional details. There are some technical challenges that have been highlighted as well. One of the main things that have come up is this requires, like when implementing 607 and 608, it requires additional encryption and jCard, which goes on the SIP header. There is some additional work that needs to be done on the network nodes that are implementing and handling this error code, so that's one challenge.
The other challenge is what happens to the intermediate TDM networks? Because we think that calls are the only calls that are being placed. They get routed through TDM networks and the codes have to be translated between the SIP codes and the TDM SIP codes to what actually gets delivered back to the originating network, so there is an issue there.
And finally, the privacy concerns on 607. How much information do you want to give back to the originating caller if the call was actually blocked by the subscriber? Given all of this, there have been reports that 607 and 608 error codes have been implemented by some service providers, but it's definitely not widespread.
There are reports being filed back to the FCC arguing for and against this proposal and the IPNNI, as you said, is working on a potential solution or updating the Standards, so that's the working group taking that up as a work in progress, the result of which could give us direction on how this is going to be implemented.
Rebekah Johnson: USTelecom has filed a petition for reconsideration and clarification around these codes. There are challenges on when to mark something as unwanted by the called party, which is 607 and that's where the consumer has made a decision. Do we really want to share back that the consumer made that choice? This goes for not only if it's an enterprise that's delivering a mass amount of calls or if it's an individual calling somebody. Do we report back that your call has been blocked or unwanted?
We don't do that today but you kind of get the hint when your message stays green on an Apple device or when the numbers are blocked it'll otherwise just divert to voicemail as a way they might be treating it. Also, on the analytics side, who are we helping, and how informative is it if the decision is made by the analytics to do the blocking resulting in a 608?
When you look at the Fourth, Fifth, and Sixth Notices for Proposed Rulemaking and you allow for the gateway providers, who are told they must implement analytics, now you've got someone along the call path who's implementing analytics. Does their analytics make a decision to block the call resulting in 608 that gets delivered back to the originating carrier, whoever it is, to deliver it back down to the enterprise, who made this decision? Which analytics was being used? How do I remediate this? How do I get this unblocked because it was the distribution by the analytics, not necessarily the consumer?
I don't think we can get into an area where we can say we want the consumer to be unblocked. I think if a consumer says don't call me and they block it, they block it, just leave it at that. But I think things get a little more confusing with 608. Then when we talk about the traceback, this is going to be the trace forward, so the enterprise will ask, "Who's the one that's blocking my messaging? Because I have no idea."
I think it adds confusion and I still have to ask myself, what are we achieving with this? How is this blocking illegal robocalls? Because I don't know that it is if the exact same analytics that we're using on the terminating side are now going to be used to deliver this error code.
Anis Jaffer: The reason, or the intent, was to provide that information back to legal or legitimate enterprises so they can do something with it. For example, if the call gets blocked because of a 608, then they know that it's network blocked and for whatever reason, they cannot use that number, or the originating number, and have to use a different number. Now, that could be if the originating enterprise is a good actor, then it helped.
But the same scenario could work against the whole thing if there's a bad actor and then they can rotate numbers. So there are still a lot of questions, and there are more questions than answers with the current proposal. So, 603 is the existing error code. There is a valid argument to expand that rather than introducing new codes, that's one of the arguments for not going down this path. There's more to come on this, but it's an evolving situation.
Rebekah Johnson: One area that we also covered towards the end of Season 1 of last year was our good friends to the north of us, Canada. There have been some activities from the CRTC with regards to allowing carriers to implement analytics. We know how this story goes. Yes, I definitely think that we are going to see the same challenges for enterprises in Canada with regards to calls being labeled 'fraud' or 'spam' by analytics. Analytics are occurring more at the carrier level. They're making the decisions on how that will be determined and established, but remediation is definitely going to be a challenge for enterprises. Anis, I know you've got some thoughts on what's happening in Canada. Anis Jaffer: We know that the CRTC is allowing carriers to implement the analytics for terminating, I'm not sure where they are and how it's going to get implemented, this is something that we have to get a featured guest for to come in and weigh in on this particular topic. Rebekah Johnson: As we come close to the end here, I want to have a little bit of time to cover the topics that we're going to be looking at for this season. As we've stated, we are going to cover branded calls and there will be a current state for AT&T, T-Mobile, and Verizon, and we can't forget our good old friends over there at Google and the activities that they are doing. We'll keep everybody up to date on that, we're hoping to have some really nice guests from each of those providers.
On that note, as an update, on January 18, T-Mobile announced that they partnered with the
CTIA to implement branded caller ID best practices. What I take from this is that each carrier, although they are on board with branded calling, they're probably going to set some of their own standards for how this works within their environment. We'll definitely be focused on that and bringing that news to you. As Anis mentioned, we're going to cover the SIP error codes and Canada and beyond because we know there are some other activities that are going on in other countries.
But another area that's going to get a lot of attention, especially since we are less than 15 days away, is the 10DLC throttling registration. It's a little bit of a hot mess from what we are hearing from enterprises. Apparently, whether you registered or didn't register, come March 1st of 2022, there will be some throttling that will occur to the messages delivered into the T-Mobile and the AT&T networks. We do not see that Verizon is enforcing anything yet, but this is very concerning. It really gets me upset whenever I hear that, for businesses, legal, valid, compliant, consented messaging is being blocked or throttled by the carriers. This is not good.
So there are some challenges with the deployment of 10DLC. Let me make the point that March 1st is a goal post, it is a goal post that has moved for the last couple of years. We'll see if that goal post stays put for March 1st or if it yet again gets moved, but it's definitely something that we're going to focus on and hopefully get some streamlined processes around this for the sake of the enterprises.
Anis Jaffer: I think so, I think this is going to be a big topic for us in addition to branded calling, the 10DLC, and messaging side of things. As we are hearing, March 1st is supposed to be the deadline for AT&T and T-Mobile to implement any unregistered campaign to get throttled. But we are hearing, even before that, that even the registered campaigns are getting throttled. That's something to really be aware of and we should definitely spend time on it this season. Rebekah Johnson: We'd like to thank all of you for joining us today for our first episode back of Tuesday Talks this year. We're looking forward to another great season together. We appreciate you all for your support and participation along the way and we hope to see you all in the next session on Tuesday, March 1st when we'll be joined by Gerry Christensen, the VP of Business Development and Partnerships at our friends over at YouMail to discuss predictions and best practices for safe voice communications and what's watch for and 2022 and beyond. Thanks, everyone. Take care.