Comment Deadlines Established for Proposed New STIR/SHAKEN Rules
As stated in our previous client advisory, the Federal Communication Commission (“FCC” or “Commission”) in March 2023 released a Notice of Proposed Rulemaking (“NPRM”) seeking comment on two important proposed STIR/SHAKEN rules. When the NPRM was released, the comment and reply comment deadlines were not established. On May 5, 2023, the NPRM was published in the Federal Register, which set the comment deadline at June 5, 2023 and the reply comment deadline at July 5, 2023. The proposed rules are delineated below.
Third-Party Caller ID Authentication
The FCC seeks comment on the use of third-party solutions to authenticate caller ID information and whether any changes should be made to the Commission’s rules to permit, prohibit, or limit their use. The Commission specifically seeks comment on the different types of third-party authentication arrangements that are currently being employed by providers, address how prevalent each type of third-party authentication arrangement is in the STIR/SHAKEN ecosystem and provide any available data substantiating how effective they are at facilitating the authentication of caller ID information. The FCC also seeks comment on whether, and under what circumstances, a third party may authenticate calls on behalf of a provider with A- or B-level attestations consistent with the ATIS standards.
Eliminating the Implementation Extension for Providers Unable to Obtain a STIR/SHAKEN Token
The Commission seeks comment on whether to eliminate the STIR/SHAKEN implementation extension for VSPs that cannot obtain a token. The FCC is particularly interested in comments concerning: (1) the benefits of, or drawbacks to, retaining the extension (2) if some VSPs remain unable to obtain a token, are there other ways the Commission could account for these providers in our rules, apart from an implementation extension; and (3) other solutions that would allow any VSPs who remain unable to obtain a token to participate in the STIR/SHAKEN framework.
NEED HELP WITH ROBOCALL MITIGATION, COMPLIANCE AND LITIGATION SUPPORT/DEFENSE AGAINST BUSINESS & LEGAL CHALLENGES?
The CommLaw Group Can Help!
Given the complexity and evolving nature of the FCC’s rules, regulations and industry policies & procedures around Robocall Mitigation and Compliance issues (e.g., Stir/Shaken, TRACED Act, FCC Rules & Regulations, US Telecom Industry group, ATIS, NECA, VoIP Numbering Waivers, Know Your Customer and the private sector ecosystem), as well as the increased risk of business disputes, consumer protection enforcement by state attorneys general, and even civil litigation, and anticipating the potential torrent of client questions and concerns, The CommLaw Group formed a “Robocall Mitigation Response Team” to help clients (old and new) tackle their unique responsibilities.
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