[stir] Re: [art] Re: For those of you who follow this kind of stuff.

[Brett Nemeroff <[e-mail]>]

Roman,
I appreciate your perspective. In a perfect world, I tend to agree with you. However, we’ve seen across thousands of US service providers, that many can be complicit in fraud. The RMDB is an imperfect system and KYC practices are all over the board.

Establishing KYC practices at the near end, and expecting implicit trust over those practices at the far end is impractical. Additionally, assuming the FCC is providing some role in evaluating processes is not likely as well. This is how, and why, ecosystems are developed to ensure and prove specific rigor and compliance. It also allows for a separation of roles and avoidance of conflicts of interest.

The commercialization of these needs and requirements supports the development and incents carriers to participate. The ecosystem defined rigor gives both the network operators and the handset manufacturers guidance on the expected level of trust.

As an industry, we have ONE shot to get this right. If we develop a method to deliver identity and a presentation that consumers understand.. and then if this method is abused by bad actor service providers (who we know exist), consumers will quickly learn that this is just a new avenue for abuse. Cryptographic identity is not a new thing. Just look at what’s happening in the EU. We need to learn from other industries who have already solved this problem.

Our solutions should be more than an avenue for enforcement (which we already see is weak). Yes, yes.. complicit actors put their fingerprints on everything. That’s only good for enforcement. RCD is a great vehicle, but we need means to ensure the presented data is legitimate.

-Brett


Brett Nemeroff
VP of Engineering - Voice
[e-mail]<mailto:%7BE-mail%7D> | 1-512-203-3884

[Logo.png]<https://www.numeracle.com/>

Empowering Calls with
Identity Management<https://www.numeracle.com/insights/entity-identity-management-to-empower-your-calls>


CONFIDENTIAL

From: Roman Shpount <[e-mail]>
Date: Wednesday, October 8, 2025 at 12:18 AM
To: Brett Nemeroff <[e-mail]>
Cc: Richard Shockey <[e-mail]>, IETF STIR Mail List <[e-mail]>, [e-mail] <[e-mail]>
Subject: Re: [stir] Re: [art] Re: For those of you who follow this kind of stuff.

Brett,

FCC was very deliberate in not specifying the KYC requirements. This being said, all carriers introducing traffic to the US phone network should have a KYC policy described in the RMD database. Carriers that did not provide an adequate policy have been removed from the RMD database and are no longer permitted to originate traffic. Additionally, if, as a carrier, I can set the A-level attestation for the call based on my KYC policy, I should be able to specify the Rich Call Data accordingly, especially if this is required when A-level attestation is provided.

I have a strong feeling that certain providers care more about creating new sources of revenue for themselves through regulatory arbitrage than about creating a healthy infrastructure to prevent robocalls. A glaring example is iConnectiv providing SPC tokens, but not the signing certificates, which artificially creates business for specialized certificate authorities. Ironically, this business opportunity is so small and labour-intensive that no one actually wants to do it, trying to shepherd carriers towards the hosted signing solution.

To summarize, if, as a carrier, I am entrusted with an SPC token, I should be trusted to provide the Rich Call Data. If I am not trusted to provide Rich Call Data into the network, I should not be introducing any traffic into it. If the FCC mandates Rich Call Data, it should mandate that carriers accept it without creating walled gardens, with each carrier charging a fee to actually accept the data.

Finally, if we intend to mandate the transmission of personally identifiable data with every call, we need to update SIP with a scalable and secure transport protocol. Most current carrier SIP implementations still use UDP. SIP-over-TLS suffers from head-of-the-line congestion issues. SIP is in dire need of a secure datagram-based protocol, such as QUIC. I am surprised that no one from the STIR group brought this to the SIPCore, so that a more scalable and secure protocol capable of carrying Rich Call Data could be standardized.

Best Regards,
_____________
Roman Shpount


On Tue, Oct 7, 2025 at 8:42 PM Brett Nemeroff <[e-mail]<mailto:[e-mail]>> wrote:
Hello Roman,

In my opinion, US Carriers are unlikely to accept vanilla RCD data because of the lack of defined KYC.  RCD is a very good vehicle for delivering the RCD, but it depends upon implicit trust of the originating service provider. “Vanilla” RCD offered like this to terminating service providers gives no assurance to the terminating service provider that the originator performed any specific KYC.

CTIA’s BCID is based on RCD but details an ecosystem with specific KYC requirements. Participating in this ecosystem will allow for the delivery and native presentation of RCD.

It’s worth noting that without a defined ecosystem for RCD such as BCID, RCD provides little (trust)  benefit over traditional CNAM other than the fingerprints of the originating service provider for enforcement purposes.

-Brett




Brett Nemeroff
VP of Engineering - Voice
[e-mail]<mailto:%7BE-mail%7D> | 1-512-203-3884

[Logo.png]<https://www.numeracle.com/>

Empowering Calls with
Identity Management<https://www.numeracle.com/insights/entity-identity-management-to-empower-your-calls>


CONFIDENTIAL

From: Roman Shpount <[e-mail]<mailto:[e-mail]>>
Date: Tuesday, October 7, 2025 at 7:24 PM
To: Richard Shockey <[e-mail]<mailto:[e-mail]>>
Cc: IETF STIR Mail List <[e-mail]<mailto:[e-mail]>>, [e-mail]<mailto:[e-mail]> <[e-mail]<mailto:[e-mail]>>
Subject: [stir] Re: [art] Re: For those of you who follow this kind of stuff.

You don't often get email from [e-mail]<mailto:[e-mail]>. Learn why this is important<https://aka.ms/LearnAboutSenderIdentification>
In my day job, I see a lot of robocalls coming through the LEC local switches as TDM, as local re-origination with spoofed ANI.

I would also love to sign Rich Call Data with my SPC token and not have wireless carriers discard this data. If I provide the information about my customer, I am unsure why I need to pay someone else to sign this information.
_____________
Roman Shpount


On Tue, Oct 7, 2025 at 8:11 PM Richard Shockey <[e-mail]<mailto:[e-mail]>> wrote:

It wont . You mean the legacy TDM/SS7 crap…this is the beginning of mandating all SIP in the US realtime US voice network as the British have done.

I would not want to own a Tandem Access network.

The US industry is pretty clear on this.  You only need to read the FCC 17-97 docket at the FCC ECFS website to understand where the players actually are.

This again is my day job.


Richard Shockey
Shockey Consulting LLC
Chairman of the Board SIP Forum
www.shockey.us<http://www.shockey.us/>
www.sipforum.org<http://www.sipforum.org/>
richard<at>shockey.us<http://shockey.us/>
Skype-Linkedin-Facebook –Twitter  rshockey101
PSTN [phone]


From: Roman Shpount <[e-mail]<mailto:[e-mail]>>
Date: Tuesday, October 7, 2025 at 7:37 PM
To: Richard Shockey <[e-mail]<mailto:[e-mail]>>
Cc: IETF STIR Mail List <[e-mail]<mailto:[e-mail]>>, <[e-mail]<mailto:[e-mail]>>
Subject: [art] Re: [stir] For those of you who follow this kind of stuff.

How would this work with PSTN links?
_____________
Roman Shpount


On Tue, Oct 7, 2025 at 6:59 PM Richard Shockey <[e-mail]<mailto:[e-mail]>> wrote:

The United States government is going to mandate Rich Call Data in the network.

https://docs.fcc.gov/public/attachments/DOC-415059A1.pdf


Richard Shockey
Shockey Consulting LLC
Chairman of the Board SIP Forum
www.shockey.us<http://www.shockey.us/> <http://www.shockey.us<http://www.shockey.us/>>
www.sipforum.org<http://www.sipforum.org/>

richard<at>shockey.us<http://shockey.us/>
Skype-Linkedin-Facebook –Twitter rshockey101
PSTN [phone]






_______________________________________________
stir mailing list -- [e-mail]<mailto:[e-mail]>
To unsubscribe send an email to [e-mail]<mailto:[e-mail]>
_______________________________________________ art mailing list -- [e-mail]<mailto:[e-mail]> To unsubscribe send an email to [e-mail]<mailto:[e-mail]>