VP Regulatory and Government Affairs, West Telecom Services (WTS), LLC
The telecom industry landscape continues to rapidly change and get more complex. The advent of inexpensive Internet access enabled by voice over IP calling and coupled with relatively low-cost equipment that has powerful technological capabilities means that almost anybody can do things such as generate thousands of calls or illicitly spoof caller ID on a much larger scale than previously possible. The response to this new reality has resulted in a lot of recent regulatory and law enforcement action against individuals and companies.
FCC Chairman Pai says that combating robocalling is the FCC’s top consumer protection priority. Additionally, on December 30, 2019, President Trump signed into law the TRACED Act that, for example, increases potential fines and establishes increased responsibilities for providers nationally.
Illicit robocalling is pervasive with over a billion illegal robocalls placed annually. STIR (Secure Telephony Identity Revisited) and SHAKEN (Secure Handling of Asserted information using toKENs) are frameworks created to identify illegally spoofed Caller-IDs and to help prevent the completion of illicit robocalls.
Intrado employees are actively participating in many industry trade associations and standards bodies, and help guide and advise during the development of new regulations for the protection of customers and the industry as a whole in a dynamic environment. Intrado works closely with other industry leaders in a variety of ways to keep fraudsters at bay.
Intrado Industry Participation
Intrado was one of the early members of a trade association called the Industry Traceback Group (ITG). ITG was founded by trade association USTelecom over three years ago as a result of efforts through the FCC’s Robocall Strike Force. That Strike Force, which included several Intrado employees, determined that it would be helpful to have a coordinated effort among leading industry members to better manage and mitigate the illicit robocalling problem. ITG currently has over 30 members and has been quite effective in addressing illicit robocalling. ITG member companies include providers like AT&T, Verizon and CenturyLink in addition to Intrado and an array of other companies. Some ITG member companies are Voice Over IP providers.
ITG has the direct support of the Federal Communications Commission through its Enforcement Bureau, as well as other governmental and law enforcement agencies. ITG member companies can sometimes help identify the bad guys who are producing the illicit robocalls. Shutting down the bad guys is important but it’s also important to note that not all robocalling and robo-texting is bad. Many robocalls and robo-texts are desired by consenting consumers. Some examples of consumer-consented robocalls and robo-texts include school notifications to parents, emergency communications, prescription pick-up calls, or authorized telemarketing or debt collection. This makes it key to be able to distinguish between legitimate and illicit robo calling and texting.
Sharing Our Expertise Across the Industry
Several months ago, Robert McCausland, VP, Regulatory and Government Affairs, West Telecom Services (WTS), added a footnote about onboarding in a filing at the FCC. Onboarding refers to a best practice of carefully transitioning onto our telecom network new customers that are carriers generating large call volumes. Onboarding best practices help ensure that those new customers, about which we may know little, cannot introduce illicit calls onto our network.
For example, one onboarding best practice is to require the new carrier customer to provide extensive forecast information about call volumes that it anticipates for the traffic it will put onto our networks for us to complete on its behalf. This best practice includes advance identification of the types of calls and the approximate duration of the calls that are expected to be exchanged. Also, geographical termination points to the calls and other information are included. In other words, we gather a lot of information about the types of calls that they plan to send to our network, and that our network may subsequently pass to other networks. That way, when we establish the network connection and start allowing calls from them onto our network, we do it slowly and we ensure that the calls’ characteristics match what we were told.
We also watch for any reports of suspected fraud calling from other carriers to which we interconnect that trace back to the new carrier customer. By scaling-up slowly, carefully monitoring traffic characteristics, and taking action when the calls do not match what we were told, we can help ensure that the calls on our network, and those that we pass to other networks, are free from fraud.
Improving Suicide Prevention Efforts
Another important contribution from Intrado involves our support for the creation of a national three-digit dialing code for suicide prevention. Thanks largely to the extensive efforts of the FCC and the North American Numbering Council on which Mr. McCausland is an active member, the 988 dialing code will be deployed across the U.S. for suicide calling.
Intrado provided guidance and recommendations to the FCC last year following the passage of the National Suicide Hotline Improvement Act, and some of those recommendations contributed directly to the approach that the FCC included within its recent rulemaking. This Act, and the FCC’s rulemaking, are aimed at addressing the critical need for access to suicide prevention help by service members (both active and retired), teens, and other at-risk groups across all ages and all communities in the country. This three-digit dialing arrangement will ensure that those potentially life-saving calls complete the same way as 911 calls complete.
The telecom landscape is sure to continue to change and fraudsters will no doubt continue to evolve their tactics in an effort to game the system to their advantage. Intrado is committed to participating in industry and government efforts to work across organizational borders to keep consumers and networks safe.
Robert McCausland is VP of Regulatory and Government Affairs for West Telecom Services (WTS), LLC, and an appointee of FCC Chairman Pai to the North American Numbering Council as well as various committees, and is co-chair of the Numbering Administration Oversight Working Group.
Mr. McCausland is an expert on a wide array of topics concerning robocalling issues, such as unauthorized Caller-ID Spoofing, CPNI, STIR/SHAKEN, and more. He has participated on behalf of WTS in producing recommendations to the FCC that have helped move forward the deployment of the STIR/SHAKEN framework for Caller-ID authentication.
West Telecom Services (WTS) LLC started as a wholesale telecom services provider as its primary focus. The WTS network connects different telecom networks together for the completion of voice calls. For example, WTS provides connections between telephone networks on the east coast and telephone networks on the West Coast of the United States. This means that if you’re in Washington D.C., and you’ve placed a call to grandma in California, you may use a provider such as AT&T Wireless to place the call. AT&T Wireless may pass that call to WTS to switch through our WTS tandem switches and to transport through WTS transport network to the local telephone company in a rural area of California where your grandma lives. WTS would then hand that call off to the rural local exchange carrier that would complete the call to grandma. So, in this instance, AT&T Wireless was used in Washington D.C. to originate the call and then handed the call off to WTS all the way to California. WTS passed the call to the rural local exchange carrier in California to complete the call to grandma. During this call the WTS network would be used for the voice communication.
