Letter to the FCC on the Proposed Call Authentication Requirement for Non-IP Networks

Dear Chairman Carr,

The American Bankers Association (ABA) commends the Federal Communications Commission (Commission) for scheduling a vote to issue a proposal that would require voice service providers that use a non-IP network – i.e., a legacy Time Division Multiplexing (TDM) network – to implement a caller ID authentication framework for that non-IP network within two years (Proposal). We urge the Commission to vote to issue the Proposal.

Voice calls that impersonate banks and other legitimate businesses harm consumers and undermine those businesses' ability to communicate with their customers. The Commission, at the direction of Congress through the TRACED Act, has made significant strides to limit criminal access to our calling network by requiring voice service providers to implement the "STIR/SHAKEN" call authentication framework. That framework requires calls to be signed at origination and attested through the call pathway until the call reaches the recipient. But STIR/SHAKEN only works over IP networks. If a call passes through a non-IP framework, the STIR/SHAKEN attestation is dropped. There is evidence that criminals exploit this gap in our caller ID authentication framework to perpetrate fraud on consumers.

Since 2022, ABA and other trade associations have urged the Commission to require voice service providers to implement caller ID authentication solutions on non-IP networks. And to combat the ever-increasing incidence of fraud, ABA is calling for a "whole-of-government" effort to stop it. By voting to issue the Proposal, the Commission could bring us one step closer to that goal. We urge the Commission to vote to issue the Proposal to require implementation of caller ID authentication frameworks across all IP and non-IP networks.

Sincerely,

Jonathan Thessin
Vice President/Senior Counsel
Consumer & Regulatory Compliance
Regulatory Compliance and Policy