The FCC has sent two warning shots in the last two weeks.
One is directed at terminating carriers who have not yet implemented a way to verify the identity of call originators and present the verified information to the call recipient.
The other is directed at originating carriers who have not implemented a robust Know Your Customer (KYC) program to keep illegal traffic off the phone network entirely.
In recent years, many attempts have been made to improve upon Caller ID display by presenting the caller’s name, logo, and reason for calling, with visible confirmation that the identity-related data has been verified. Most of these efforts have been for the deployment of “branded calling,” a premium service where call originators pay to have this information presented to consumer mobile devices.
Unfortunately, the market for these services is fragmented. Many terminating carriers have chosen different, incompatible delivery methods and the multiple device makers have implemented these technologies in different, and sometimes confusing, ways. Prices are all over the board, and the levels of verification and security significantly vary.
Verified call information often displays the same way as unverified information, and once a call recipient is burned, they are unlikely to trust any identity presentation again.
The industry must work cooperatively to implement a consistent, effective solution available to all. The FCC (or “the Commission”) recognizes that the current path forward is not sustainable. Carriers have been working to prevent robocalls since 2016, but the problem remains.
The Commission’s Draft Order from last week says, “Fix this or else.”
The FCC continues:
“Although we do not adopt such a mandate, we urge providers to continue to develop next-generation tools, such as Rich Call Data (RCD), to ensure that consumers receive this information and welcome any updates industry has on its progress. We note that we may consider a mandate in the future, particularly if the timely deployment of such valuable tools does not occur without Commission intervention…
Though we decline to adopt a mandate at this time, we nonetheless believe that displaying caller name information, once a reliable solution is available, will provide significant benefit to consumers, particularly when combined with an indication that caller ID has been authenticated. We therefore strongly encourage industry to develop and standardize tools to ensure that this information is provided to consumers without additional charge to the call recipient. “
Numeracle has been advocating for Rich Call Data (RCD) in a trust framework for years. We strongly support the Branded Calling ID (BCID) system that CTIA is implementing with participation from one of the three major wireless carriers, and we hope to see the other two join soon.
Hopefully the Commission’s warning shot will be the impetus the others need. The terminating carriers will undoubtedly prefer an industry-led solution to a Commission mandate.
In other news, the Commission fined Telnyx $4.5 million for failing to implement an effective Know Your Customer process. A Telnyx customer provided incomplete and suspicious KYC information to Telnyx. The customer then placed thousands of phone calls falsely claiming to be from an FCC anti-fraud task force. In a stroke of bad luck (or good luck, depending on one’s perspective), several of the calls went to FCC staff members and their families.
Almost two years ago, Numeracle published a model KYC template. The Commission had mandated KYC, but did not flesh out the details of what was required. Numeracle filled that void and issued its KYC template to the industry for free, which gained Senate recognition at the “Protecting Americans from Robocallers” hearing in 2023. We are working on minor revisions in light of developments over the last few years.
Had Telnyx followed Numeracle’s model, the illegal caller would not have gained access to Telnyx’s network. Similarly, the FCC’s order in the Biden AI robocall case shows that following Numeracle’s KYC guidance is the best way to avoid fines and enforcement action in this tricky field.
While we’ve been advocating for robust KYC and Verified Identity presentation for more than five years, our focus remains on working together with the industry to create effective, affordable solutions. By doing so, we can better protect consumers from fraudulent calls while still ensuring legitimate, consented calls go through.
Feel like you’ve missed the boat on KYC implementation and are at a loss for where to get started? Check out our comprehensive guide for communications service providers seeking to develop KYC processes and procedures for conducting meaningful customer due diligence, or jump straight to our KYC Model Standards plug-and-play template.
