ABA/Joint Trades' Comment re: Call Authentication on Non-IP Networks

The American Bankers Association, ACA International, American Financial Services Association, Credit Union National Association, Mortgage Bankers Association, National Association of Federally-Insured Credit Unions, National Council of Higher Education Resources, and Student Loan Servicing Alliance (the Associations) appreciate the opportunity to comment on the Notice of Inquiry (Notice) in the above-captioned proceeding. In the Notice, the Federal Communications Commission (Commission) seeks comment on how best to implement a caller ID authentication framework for non-IP networks. In past actions, the Commission required telephone companies (Voice Service Providers) that make voice calls over non-IP networks to upgrade their entire network to IP and implement the "STIR/SHAKEN" caller ID authentication framework on the network, or participate in industry efforts to develop a caller ID authentication solution for non-IP networks.

The Associations strongly support the Commission's efforts to implement caller ID authentication solutions on non-IP networks. Bad actors illegally "spoof" phone numbers belonging to banks, credit unions, other financial service providers, healthcare companies, and other legitimate callers – i.e., they cause the call recipient's caller ID to display the name of a legitimate company instead of the name of the actual caller, who is seeking to defraud the recipient. This spoofing can lead the recipient to believe the call was placed by a company with whom the recipient does business and to induce the consumer to provide important information, such as account numbers or log-in credentials, to the fraudster. Bad actors also have illegally spoofed the phone numbers belonging to the Consumer Financial Protection Bureau and the Centers for Disease Control and Prevention, posing as employees of the agency in attempts to defraud consumers.

To prevent illegal number spoofing, the Commission requires IP-based originating Voice Service Providers to attest to the authenticity of the telephone number that will be displayed in the recipient's caller ID. Each intermediate provider in the call path that has an IP network must pass this STIR/SHAKEN attestation information to the next downstream IP-based Provider until the call reaches the terminating Provider. However, because STIR/SHAKEN only works on IP networks, any non-IP network in the call chain will prevent the STIR/SHAKEN attestation from being transmitted. There is evidence showing that the presence of non-IP networks is substantially undermining the STIR/SHAKEN framework. For example, TransNexus (a provider of telecommunications solutions) found an increase between January and August 2022 in the number of providers "signing" calls under the STIR/SHAKEN call authentication framework.

Yet, in each month during this time period, only 24% of calls that were delivered to recipients included STIR/SHAKEN call authentication information. For the remaining calls, either the call was not signed at origination or that signature was lost during the call’s transit, indicating that non-IP networks may be preventing the transmission of the attestation information. Both network providers and companies have invested resources to implement STIR/SHAKEN.

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