"Ringless Voicemail” Petition for Declaratory Ruling Withdrawn
On June 20, 2017, All About the Message, LLC withdrew its FCC petition seeking a declaratory ruling that “the delivery of a voice message directly to a voicemail box does not constitute a call that is subject to the prohibitions on the use of an automatic telephone dialing system (“ATDS”) or an artificial or prerecorded voice that are set forth in the Telephone Consumer Protection Act.” The letter did not explain the withdrawal, but the FCC received hundreds of comments from consumers and consumer advocates opposing the request. This marks the second time that a petition asking for a declaratory ruling regarding direct-to-voicemail technology has been withdrawn.
FCC Commissioners to Consider Call Authentication and Robocall NOIs at July Meeting
The FCC will consider two items aimed at reducing unlawful calls to consumers at its next open meeting on July 13, 2017.
Call Authentication NOI. First, the Commissioners will vote on a Notice of Inquiry on call authentication frameworks to allow telephone service providers to identify fraudulent calls. The authentication procedures are intended to allow subscribers and carriers to know that callers are who they say they are. The Commission seeks comment on the three-phase process put forward by the Alliance for Telecommunications Industry Solutions (ATIS) and SIP Forum. Phase one involves the development of the Secure Handling of Asserted information using toKENS (SHAKEN) framework, based on the protocols developed by the Internet Engineering Task Force (IETF) Secure Telephone Identity Revisited (STIR) working group. As the Commission explains, “in the SHAKEN/STIR model, a call is authenticated when it is signed with a digital signature by an authentication service, operating on behalf of the party originating the call.” Phase two will define how the authentication services are to receive certificates in the first place. Phase three is still being developed by ATIS and the SIP Forum.
The Commission seeks comment on what it should do, if anything, to promote adoption and implementation of authentication frameworks (such as the SHAKEN and STIR frameworks). The Commission asks for comment on the appropriate time frames and milestones for implementation of the frameworks. ATIS has suggested that the SHAKEN and STIR models require a “governance authority” and “policy administrator.” In the NOI, the Commission asks what entity or entities would best serve in those roles, recognizing that the Commission could serve some of the functions, but may not be best positioned to handle all aspects of the positions. Because the SHAKEN and STIR proposals apply to SIP-based, but not SS7-based systems, the Commission also seeks comment on the role of SS7 and other legacy technologies in this proceeding.
As with most items under Chairman Pai, the NOI seeks comment to inform a cost and benefit analysis. The Commission asks for high-level estimates of the costs of implementing call authentication, as well as estimates of the benefits of an authentication system. The Commission asks how these costs might be shifted among relevant stakeholders, and if end-user fees could be expected to cover service costs.
Second Robocall NOI. The second item on the Commission’s agenda is a Second Notice of Inquiry to gather feedback on using numbering information to create a comprehensive list that businesses can use to identify telephone numbers that have been reassigned from a consumer that consented to receiving calls to a consumer who has not consented to the calls. Approximately 35 million telephone numbers are disconnected each year.
The Commission begins with asking how service providers can report number reassignments in an accurate and timely manner, and what information the provider would need to report. The Commission asks if a report when a telephone number is disconnected and is now “aging” would be adequate, or if the provider should also report when numbers become classified as available, or when the...
