Safe Voice Communications: What to Watch for in 2022 and Beyond...

How much of this come to pass, how much is yet to be, and what will never occur?

1. Blocking vs. Labeling and Redirection: As intermediate network service providers gain efficacy in blocking telephone numbers that are associated with illegal calling campaigns, fewer unlawful calls will reach downstream networks. This will place a greater emphasis on the need for effective call treatment of legal, but unwanted calls on the part of terminating networks.

2. Impact of STIR/SHAKEN Ubiquity: There will be substantial acknowledgement that S/S is not enough. Once, there is ubiquitous S/S deployment across networks, broad recognition of its shortcomings will become readily apparent. This will catalyze action in other areas such as KYC and telephone number behavior monitoring.

3. Enterprise Identity: Number owners and custodians will be increasingly compelled to register telephone numbers for vetting and employ various validation methods such as out-of-band authentication as an alternative to S/S. Branded calling will begin to have a positive impact, even prior to RCD availability as consumers begin to recognize that branded calls are also authenticated calls.

4. Number Allocation Policy: Procedures and policy guidance and directives are anticipated such as vetting of number leasers, call originators and monitoring of phone number behaviors. The FCC has already initiated an NPRM focused on Numbering Policies for Modern Communications. Additional work is anticipated here to identify optimal policies and administration.

5. KYC Best Practices: There is an industry need for Know Your Customer guidelines for voice call originators. Just as the Mobile Marketing Association was instrumental in the development of SMS best practices for A2P messaging, there is a need for call originators to adhere to certain customer onboarding and administration policies focused on business vetting, phone number behavior monitoring, threat detection and response.

6. UI Best Practices: The voice communications user interface has not changed much since the introduction of SS7 and enhanced caller ID. With the advent of enterprise identity and authentication, there is a substantial opportunity for training consumers to recognize completely safe voice communication vs. non-trusted calls. There is a need for UI best practices for everything from display of S/S calls to branded call content placement and more.

7. STIR/SHAKEN Policy Best Practices: There is a keen need for S/S attestation best practices. This includes how attestation levels are set by call originators as well as how intermediate networks and terminating communication service providers handle B and C attested calls. There is also a need to link S/S policy and administration with KYC and telephone number behavior monitoring.

8. Additional Regulatory Action: Agencies are poised to engage in rulemaking in many areas including numbering administration, international gateways, and more. One emerging area of focus is brand impersonation. For example, the FTC has recently announced Advance Notice of Proposed Rulemaking to Combat Government and Business Impersonation Fraud

9. Enforcement: While "reasonable analytics" is sufficient to support FCC safe harbor policies for call treatment, more is required to enforce regulatory rulings and applicable federal and state laws. Supported by evidential proof of wrongdoing, the efficiency and effectiveness of legal actions and law enforcement is likely to increase.

10. Broad Recognition of Content Based Analytics: As a result of intermediate network provider call blocking, regulatory and enforcement actions, it is anticipated there will be substantially increased awareness across carriers, enterprise and government agencies that content-based analytics definitively identifies fraudulent robocalls.