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FCC Takes Next Steps on STIR/SHAKEN Implementation and Combating Illegal Robocalls

The Federal Communications Commission (FCC) has released its next initiative “to continue the FCC’s work to implement the TRACED Act and promote the deployment of caller ID authentication technology” (i.e., STIR/SHAKEN). This next step would “adopt rules implementing many of the proposals [the agency] made in the First Caller ID Authentication Report and Order and Further Notice. Among other things, [the proposal would] adopt rules governing intermediate providers and caller ID authentication in non-IP networks, we implement the exceptions and extensions established by the TRACED Act, and we prohibit line-item charges for caller ID authentication.”

In a proposed Second Report and Order circulated on September 9, 2020, Chairman Ajit Pai is asking his fellow Commissioners to approve the following additional requirements to combat illegal robocalls:

  • Require voice service providers to either upgrade their non-Internet Protocol (IP) networks to IP and implement STIR/SHAKEN, or work to develop a non-IP caller ID authentication solution.

  • Establish extensions of the June 30, 2021 caller ID authentication implementation deadline for small voice service providers, voice service providers that are currently incapable of obtaining a “certificate” necessary to implement STIR/SHAKEN, services scheduled for discontinuance, and non-IP networks.

  • Require voice service providers subject to an extension to implement a robocall mitigation program on the non-STIR/SHAKEN-enabled portions of their networks.

  • Require all voice service providers to file a certification in a Commission database showing how they are acting to stem the origination of illegal robocalls.

  • Establish a process by which providers that make early progress on caller ID authentication implementation can obtain an exemption from the June 30, 2021 deadline, as required by the TRACED Act.

  • Prohibit voice service providers from adding any line item charges to the bills of consumer or small business customer subscribers for caller ID authentication technology, as required by the TRACED Act.

  • Require intermediate providers to implement the STIR/SHAKEN caller ID authentication framework in the IP portions of their networks by June 30, 2021.

The full FCC is expected to vote on the proposal at its meeting on September 30, 2020. In the meantime, for the next two weeks, interested parties can engage the Commission staff and Commissioners to seek changes.

© Copyright 2020 Squire Patton Boggs (US) LLPNational Law Review, Volume X, Number 255



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