The STIR/SHAKEN Deadline Is Next Week - Then What?
Communications Service Providers (CSPs) of all sizes have been tasked with the responsibility of implementing STIR/SHAKEN call authentication and robocall mitigation solutions, and must file certifications about what they are doing to stop robocalls in the Federal Communications Commission’s (FCC) new Robocall Mitigation Database, by June 30, 2021. That will help begin the process of restoring trust in the calling ecosystem.
However, with multiple reports issued by the FCC, it’s tough to keep up with the latest regulations. As the industry continues to evolve with changing rules and technical developments, many CSPs are finding it tricky to keep up and are left confused*.
Here’s a sample of some of the questions we’re hearing from the industry.
Q1. What will happen to calls that are not signed after June 30?
The TRACED Act requires that all carriers that were not granted an extension must implement STIR/SHAKEN on the IP portion of their networks, and begin signing and verifying calls, by June 30, 2021. Our expectation is that most transit carriers who receive an unsigned call from an interconnect partner will sign those calls, and apply a “C” level gateway attestation to those calls prior to sending to the terminating carrier, although methods of implementation and call treatment policies may vary.
Q2. What happens to calls signed with ‘B’ attestation?
Calls with a “B” level attestation will likely be processed as normal calls and terminated to subscribers with a verstat of “No-TN-Validation”, depending on the policy of the terminating carrier. This means that the end subscriber receiving the call will not get a visual indication that the call is verified. For example, a call with an “A” attestation and a very negative (“Spam Risk”) robocall score might be treated worse than a call with a “B” attestation and a very positive robocalling score, if that’s how the terminating carrier defines their policy.
Additionally, after June 30, analytics providers who are responsible for applying spam/threat tagging to terminating calls may include the attestation value as a factor in determining if a tag should be added, and what that tag should indicate.
So, a call with a high robocall score and a “B” attestation may be treated differently from a call with a high robocall score and an “A” attestation. Call treatment strategies will continue to evolve as the industry matures on this matter.
Q3. When will carriers start dropping or rejecting calls based on lack of attestation?
Some carriers will not implement STIR/SHAKEN by June 30, 2021, for a variety of reasons. There are extensions granted for smaller carriers, carriers who are still running SS7, etc. Due to this, it is not expected that carriers will drop or reject calls solely due to lack of signature or attestation value.
However, all carriers are required by law to have an approved Robocall Mitigation and/or STIR/SHAKEN solution filed (which can be STIR/SHAKEN, robocall mitigation analytics, or some other program/solution) in the FCC’s Robocall Mitigation Database by June 30, 2021.
After September 28, 2021, intermediate and Terminating Service Providers (TSPs) are prohibited from accepting traffic from any carrier without an approved plan registered in the FCC database.
Q4. When will tracebacks go into effect?
The Industry Traceback Group (ITG) is technology-agnostic, and membership is open to any service provider. The group’s authority to refer uncooperative or non-compliant providers to the FCC, Federal Trade Commission (FTC), or Department of Justice (DOJ) for enforcement action is expected to begin as of June 30, when most calls to mobile subscribers will be presented with an identity header.
The ITG is likely to work collaboratively to identify the originators of illegal robocalls and refer them to the government for enforcement. The FCC, FTC, and DOJ already have enforcement power to pursue civil, criminal, or commercial remedies against offending carriers, and indeed have already begun to do so.
For more information, visit the STIR/SHAKEN Resource Hub.
*These materials and opinions are for informational purposes only and not for the purpose of providing legal advice. One should contact an attorney to obtain advice with respect to any particular issue or problem.