FCC Provides Caller ID Authentication Exemption Certifications Directions and Filing Information

On November 9, 2020, the Wireline Competition Bureau (“the Bureau”) released a Public Notice providing directions and filing information for caller ID authentication exemption certifications.  All certifications and supporting statements must be filed on or before December 1, 2020.  You may recall that in March 2020, the FCC adopted rules requiring providers to implement STIR/SHAKEN in the IP portions of their network, and that in September 2020, the FCC adopted requirements for voice service providers to work toward caller ID authentication with respect to the non-IP portions of their networks.  In September, the FCC also adopted exemptions from caller ID authentication requirements for providers that could demonstrate early implementation of caller ID technology.

 

TRACED Act Exemptions:  The TRACED act creates two exemptions, one for IP calls and one for non-IP calls.  The FCC has determined that in order to receive an exemption for its IP networks, a voice provider must:

  • Complete network preparations necessary to deploy the STIR/SHAKEN protocols on its network – this may include participating in test beds and lab testing, or completing network adjustments to enable authentication and validation of calls consistent with the STIR/SHAKEN framework;
  • Complete formal registration (including payment) and testing with the Policy Administrator – this demonstrates voluntary agreement to participate with other voice providers in the STIR/SHAKEN framework;
  • Complete the necessary network upgrades to at least one network element (e.g. a single switch or session border controller) to enable authentication and verification of caller ID information consistent with STIR/SHAKEN standards; and
  • Reasonably foresee that all necessary network infrastructure upgrades will be completed by June 30, 2021 enabling the provider to authenticate and verify caller ID information for all SIP calls exchanged with STIR/SHAKEN.

In order to receive an exemption for its non-IP networks, a voice service provider must:

  • Be working to develop a non-IP authentication solution; and
  • Reasonably foresee that all necessary network infrastructure upgrades will be completed to authenticate and verify caller ID information for all non-IP calls originating or terminating on its network as provided by a standardized caller ID authentication framework for non-IP networks.

 

Certification Requirements: Providers seeking to qualify for an exemption must submit:

  • One certification, stating that the provider meets the above criteria for IP Networks, non-IP networks, or both, signed by an officer of the provider, under penalty of perjury stating that the officer has personal knowledge that the provider meets each criterion.
  • A supporting statement explaining, in detail, how the provider meets each of the prongs of each exemption so the FCC can verify the accuracy of the certification.

 

All certifications and supporting statements must be filed on or before December 1, 2020 via ECFS in WC Docket No. 20-68.

 

The Bureau will review the certifications and issue a list of parties that will receive an exemption on or before December 30, 2020.  The FCC must obtain OMB approval for the certification process, and the rule on caller ID authentication exemption certifications will not become effective until the Bureau publishes notice of OMB approval in the Federal Register.

 

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