[VoiceOps] FCC RMD Naughty List

Fri Dec 13 12:04:10 EST 2024

Mary Lou,

I accidentally deleted the mail with the attachment. Could you resend?

Thank you.
Kili Land

________________________________
From: VoiceOps <voiceops-bounces at voiceops.org> on behalf of Mary Lou Carey via VoiceOps <voiceops at voiceops.org>
Sent: Thursday, December 12, 2024 5:25:50 PM
To: Jeff Bilyk <jbilyk at gmail.com>
Cc: Voiceops <voiceops at voiceops.org>
Subject: Re: [VoiceOps] FCC RMD Naughty List

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How is it fair that if you use your upstream carrier for analytics that you have to list their name? The FCC has no business asking that. Especially when they don't force everyone who uses a separate analytic provider to list their upstream vendor's name? I have no problem with explaining the processes used, but asking for any vendor name is just not appropriate.

MARY LOU CAREY
BackUP Telecom Consulting
Office: 615-791-9969
Cell: 615-796-1111

On 2024-12-12 05:15 PM, Jeff Bilyk wrote:

Perhaps I'm misunderstanding the verbiage, but that appears to relate only to vendors of call analytics 3rd parties, and not all upstreams?

On Thu, Dec 12, 2024, 6:03 PM Mary Lou Carey via VoiceOps <voiceops at voiceops.org<mailto:voiceops at voiceops.org>> wrote:

See the attached document. I highlighted the verbiage that states you must provide the names of your 3rd party vendors. A lot of companies have their upstream providers sign their calls and do their analytics for them.

MARY LOU CAREY
BackUP Telecom Consulting
Office: 615-791-9969
Cell: 615-796-1111

On 2024-12-11 07:23 PM, Nathan Anderson via VoiceOps wrote:

I agree with your stance on this, assuming this is in fact a requirement.  However...I must be dense, because I have now skimmed over the Sixth, Seventh, and Eighth "Caller ID Authentication Report and Orders", the "Improving the Effectiveness of the Robocall Mitigation Database" docket, the updated RMD deadlines and compliance info in DA 24-73 posted in January, and I re-read paragraph II.3 of the so-called "naughty list" document that kick-started this thread.  And I can find zero mention anywhere that supplying a detailed and accurate itemized list of your upstreams is any sort of requirement in one's RMD filing.  There seems to be plenty of talk about having "know your upstreams" procedures, but that is not defined as disclosing your upstreams.

So what am I missing?  I'm sure I am just ignorant about where I should be looking ("I'm a doctorengineer, not a lawyer, dammit!"), but this is a rather well-hidden requirement...

-- Nathan

From: Mary Lou Carey [mailto:marylou at backuptelecom.com<mailto:marylou at backuptelecom.com>]
Sent: Wednesday, December 11, 2024 09:09
To: Nathan Anderson
Cc: Voiceops
Subject: Re: [VoiceOps] FCC RMD Naughty List

The requirement to disclose who your underlying carriers and additional contact information were just added THIS YEAR. If you're up to date on everything else, you might not have made the list because there were so many less complaint than you, I wouldn't take that as a sign that the FCC won't ever contact you about missing information.

I'm a consultant so I'm exposed to a lot more problems than one company may run into. I personally spoke with the FCC and FBI about the scamming situation because someone approached us for help when they realized someone had contacted one of their upstream carriers and was impersonating them. The FCC and FBI had no answers......I'm the one that made the connection between the information scammers got and where they could have gotten it from.

I was helping carriers with STIR/SHAKEN compliance long before the RMD was required. The FCC came up with it as a work around because not every carrier could qualify for a STIR/SHAKEN certificate under the original requirements. (The original requirement the RMD replaced was having access to numbering resources. As in NXXs - not DIDs).

In my opinion what started out as a method to identify all the players in the industry has turned into an information grab that should not be happening. Not only because it would be a nightmare to keep the upstream carrier list updated, but because it creates way too much temptation for fraudsters and the anti-competitive to abuse it.

MARY LOU CAREY
BackUP Telecom Consulting
Office: 615-791-9969
Cell: 615-796-1111

On 2024-12-10 08:09 PM, Nathan Anderson via VoiceOps wrote:

Wait, say what now?  I'm not even sure I understand how that kind of hijacking is possible.  You'd have to be able to deduce who that provider's underlying carriers are before you could attempt to engage in that kind of social engineering with them, and as an IPES, there's nowhere either in our 499 filings or in the RMD filing where we are required to disclose that, either publicly or privately/redacted.  (Unless I'm missing something?  We have never disclosed that in any FCC filings, and yet we didn't get added to this "naughty" list.  Furthermore, a read through of the required information listed in this notice under II.3 absolutely does not say anywhere that you are required to itemize who your specific upstreams are.)  I suppose you could voluntarily disclose it in your RMD plan write-up, but...why would you, as that just unnecessarily ties your hands and results in a bunch of self-inflicted busy work (if you're going to list it, then you either have to maintain that list, avoid bringing up new or tearing down old SIP trunks with various underlying carriers, or risk having the disclosure become "stale").

Also, on a different but related note, this whole incomplete-RMD-filing issue is a problem that the FCC kinda/sorta created themselves, and then decided shirk their responsibility for doing so and saddle all of us with the downstream consequences and threats.  Just to remind everybody of the history here, this database as originally conceived by the brilliant minds in Washington required that filers EITHER certified themselves as being wholly S/S compliant, OR if not, then they had to supply a written mitigation plan.  If you selected the "I am 100% S/S compliant" checkbox, it would NOT allow you to upload a document attachment with any kind of written plan.  And if you first filed as only partially compliant or not-yet-compliant, and added such a document/attachment to your filing, and then after finishing your S/S implementation you went back and UPDATED your filing to reflect your new compliance, the system would DELETE your previous attachment from your filing, and not give you any option to submit a new one.  If you filed as 100% compliant, you could not add an attachment, PERIOD.  100% compliance and document attachments were mutually exclusive.

Then one day they decided that maybe that was a bad idea, and required everybody who was 100% complaint to drop everything & go back and add written mitigation plans to their filings.

So far in the (admittedly few) minutes I've taken to check out a handful of companies on this "naughty" list, virtually all of them are in the boat of having checked the "100% compliant" checkbox, but not having gone back after the rule change to submit a written RM plan document attachment to their filing.

-- Nathan

From: VoiceOps [mailto:voiceops-bounces at voiceops.org] On Behalf Of Mary Lou Carey via VoiceOps
Sent: Tuesday, December 10, 2024 14:08
To: voiceops at voiceops.org<mailto:voiceops at voiceops.org>
Subject: Re: [VoiceOps] FCC RMD Naughty List

The requirements for RMD changed and you now need to add a lot more information. You only have 14 days to respond to the FCC, but MAKE SURE YOU FILE YOUR 499 CONFIDENTIALLY! We have already learned of incidents where scammers got ahold of company information and attempted to get the company's underlying carriers to change the IP addresses for their SIP trunks so they could hijack their network. We've brought this to the attention of the FBI and FCC, but the FCC's only offer was to file them confidentially. I personally think they're asking for way too much information and stupid to allow anyone's information to be listed on a public site, but until they fix the problem its up to carriers themselves to make sure their information is secure.

Ashley (with Equitel Compliance) and I (BackUP Telecom can help anyone that needs to update their RMDs or get STIR/SHAKEN certified.

MARY LOU CAREY
BackUP Telecom Consulting
Office: 615-791-9969
Cell: 615-796-1111

On 2024-12-10 03:42 PM, Dave Russo via VoiceOps wrote:

Here is the FCC order & list mentioned: https://docs.fcc.gov/public/attachments/DA-24-1235A1.pdf

Also somewhat related, I'm curious how some companies that claim to be STIR/SHAKEN compliant and are listed on iconectiv's authorized provider list get away with not being fully FCC compliant?

For example when we were looking for a new provider it came to my attention that Atheral is 5 years behind on its FCC 499 filings... Looks like it last filed in 2019: https://apps.fcc.gov/cgb/form499/499detail.cfm?FilerNum=832820

Does this mean it can get shut down any time the FCC decides to do that? Will resellers that use them be at risk of losing service or subject to some FCC action themselves?

-dr

On Tue, Dec 10, 2024, at 2:17 PM, Mike Hammett via VoiceOps wrote:

How many of you are on the Robocall Mitigation Database naughty list that the FCC just sent out?

It'd be nice if they told you *WHY* your filing was deficient. Instead, they just generically list broad categories that you may or may not fit into.

-----

Mike Hammett

Intelligent Computing Solutions

http://www.ics-il.com

Midwest Internet Exchange

http://www.midwest-ix.com

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