On August 5, 2022, the Wireline Competition Bureau (“WCB”) released a Public Notice seeking comment on two TRACED Act obligations related to STIR/SHAKEN. The Notice seeks comment on the following:
- STIR/SHAKEN Implementation Extensions
You may recall that the Commission granted three categorical extensions of the STIR/SHAKEN implementation mandate in the Second STIR/SHAKEN Report and Order to: (1) small voice service providers; (2) voice service providers that cannot obtain the Service Provider Code (“SPC”) token necessary to participate in STIR/SHAKEN; and (3) services scheduled for section 214 discontinuance. The extension for services scheduled for section 214 discontinuance ended on June 30, 2022. The WCB seeks comment on whether the remaining two extensions should be revised or extended as part of its annual review. Specifically, the WCB seeks comment on:
- The Commission’s Extension for Facilities-Based Small Voice Service Providers: The small provider extension was shortened to June 30, 2022 only for providers likely to be the source of illegal robocalls. For the remaining small providers, the extension is set to expire on June 30, 2023. The WCB seeks comment on the burdens and barriers to facilities-based small voice service providers implementation and whether their STIR/SHAKEN extension should be extended for all or some of these providers.
- The Commission’s Extension for Voice Service Providers that Cannot Obtain a SPC Token: The Commission granted voice service providers that could not obtain SPC Tokens due to a Governance Authority policy an extension until they were able to obtain the necessary token. The policy was revised in 2021, which the WCB found had resolved the main concerns underlying the extension. The WCB retained the extension in its 2021 review, however, due to the necessity of obtaining a token before STIR/SHAKEN cold be implemented. The WCB seeks comment on this extension and whether it remains necessary.
2. Efficacy of STIR/SHAKEN for Triennial Assessment Report
The TRACED Act requires the Commission to assess the efficacy of the technologies used for the call authentication frameworks no later than three years after enactment of the Act, to “revise or replace the call authentication frameworks” if the Commission determines it is in the public interest to do so, and to submit a report to Congress on its assessment findings and any revisions or replacements of the call authentication frameworks. In preparation for that report, the WCB seeks comment on the efficacy of the STIR/SHAKEN caller ID authentication framework. Specifically, the WCB seeks comment on:
- The standards used to assess the efficacy of STIR/SHAKEN: WCB proposes to assess the efficacy of STIR/SHAKEN based on how well it effectuates the authentication of caller ID information. WCB seeks comment on this proposal and if there are other ways to assess the framework.
- The efficacy of STIR/SHAKEN under this standard: Specifically, WCB seeks comment on whether STIR/SHAKEN has proven to effectively authenticate caller ID information, if there are ways it could be more effective, if there are specific factors that limit the efficacy, and whether it is still premature to assess the efficacy of STIR/SHAKEN in practice due to limited implementation.
- Whether the Commission should revise or replace the STIR/SHAKEN framework: Specifically, WCB seeks comment on whether it is premature to replace the framework, the costs of revision or replacement compared to the benefits, and whether it is in the public interest.
Comments will be due 30 days after Federal Register publication and Reply Comments will be due 50 days after Federal Register publication.
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