After researching the issue, Pasquale has become convinced the customer’s name and not the telephone number has become the “de facto” trusted standard of caller ID, and the problem needs to be addressed. Because of this, he appeared before the FCC to detail his findings and propose a solution. Pasquale shed light on how calls from Unified Office customers have been marked as potential spam, leading to mistrust and subsequent non-answering of the calls, damaging legitimate businesses’ branding and reputation. He noted the problem seemed to be escalating since March. Unified Office identified an apparent inconsistency in how third-party analytics companies and terminating carriers determine which calls are spam and which are to be re-labeled. The company underscored the lack of a clear process for resolving complaints. Pasquale emphasized the need for restoring trust in the public phone network and recommended that as part of the STIR/SHAKEN attestation process, customer names (or rich call data when available) should be authenticated by the originating service provider. He proposed that once authenticated and attested, transit and terminating carriers should be prohibited from altering the name in the caller ID field. In addition, he advocated for an alert system where if authenticated calls are labeled as spam, the originating service provider should be notified and given an opportunity to resolve erroneous spam labeling or fix the issue with its customer. Pasquale also suggested that originating carriers that abuse the process should risk losing their STIR/ SHAKEN certification. To resolve the issue, Unified Office suggested amending the STIR/SHAKEN protocol to include end-to-end customer name verification and authentication, along with phone number authentication. The company also outlined a series of implementation steps for its proposed remedy, including acquiring a digital certificate from Neustar, attesting and signing the number and the name, preserving customer name, and providing reason codes and feedback loops. Trust & Confidence According to Pasquale, the situation he took to the FCC seems to have coincided with the implementation of the STIR/SHAKEN mandate. “This issue is particularly problematic for consumers who are reluctant to answer calls from unknown sources, potentially missing important calls from entities such as vendors, medical offices or airlines with critical updates as examples,” Pasquale said. “This practice, which has very quietly become prevalent in the last year, is a point of consternation for channel partners and service provider customers who rely on this service to engage with their customers.” The erosion of trust and confidence in the public communications network is a top concern for the FCC, Pasquale continued. “Service providers have in the past year noticed customer complaints about business names being inaccurately displayed in the CID as only a city and state or even labeled as spam. Legal and technical solutions are being explored to address this issue, which is under consideration in an FCC docket.” Pasquale explained that the problem really centers around the reputations of legitimate businesses and a calling party. “The heart of the problem is the deletion and mislabeling of customer name in caller ID and the mislabeling of calls as ‘Spam Likely’ by unregulated third-party service providers and analytics companies as they process calls through the networks to their ultimate destination,” he said. Furthermore, the practice interferes with the FCC’s stated purpose, “to make available … a rapid, efficient … communication service … for the purpose of the national defense, for the purpose of promoting safety of life and property …” Pasquale backed up his concern with an example at Unified Office which began to receive complaints from its customers that their phone calls were appearing as potential spam to their customers. “These were complaints from dentists, auto dealers and others who rely on the availability of caller ID to reach their customers,” Pasquale said, “Our originating and terminating partners that we work with weren’t clear as to what was occurring or how to remedy it.” After much Google searching, “we discovered third-party companies such TNS, HiYa and First Orion that were being used by the terminating carriers to detect spam and robo-calling. Upon contacting these companies, we were able to clear up many of the incorrect calls marked as spam, but the effort was far from conclusive,” he said. Caller identification from legitimate callers were being dropped and replaced with other labels such as city, state name or “SPAM Risk.” Pasquale said originating service providers can work with terminating carriers on how to remedy incorrect markings, spam callers and or robocalls. “If the originating service provider is found to be in violation of fraudulent name presentation, they can be red lighted until the issue is cured,” Pasquale offered. “If an originating service provider knowingly is enabling robocallers and spammers, then they lose their STIR/SHAKEN certificate, and the terminating provider drops the calls. The FCC 64 CHANNELVISION | SEPTEMBER - OCTOBER 2023 CORE COMMUNICATIONS
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