SHAKEN/STIR Robocall Summit - July 11 2019 at FCC

Thu Jul 11 18:59:37 UTC 2019

Pretty simply - Sending caller ID to commit fraud. It's literally 
already illegal. The legislature has already defined it for us, even.

47 USC 227

https://www.law.cornell.edu/uscode/text/47/227

(B)
to initiate any telephone call to any residential telephone line using 
an artificial or prerecorded voice to deliver a message without the 
prior express consent of the called party, unless the call is initiated 
for emergency purposes, is made solely pursuant to the collection of a 
debt owed to or guaranteed by the United States 
<https://www.law.cornell.edu/uscode/text/47/227>, or is exempted by rule 
or order by theCommission 
<https://www.law.cornell.edu/uscode/text/47/227>under paragraph (2)(B);

(e)(1)In general

It shall be unlawful for any person 
<https://www.law.cornell.edu/uscode/text/47/227> within the United 
States <https://www.law.cornell.edu/uscode/text/47/227>, in connection 
with any telecommunications service 
<https://www.law.cornell.edu/uscode/text/47/227> orIP-enabled voice 
service, <https://www.law.cornell.edu/uscode/text/47/227> to cause 
anycaller identification service 
<https://www.law.cornell.edu/uscode/text/47/227>to knowingly transmit 
misleading or inaccuratecaller identification information 
<https://www.law.cornell.edu/uscode/text/47/227>with the intent to 
defraud, cause harm, or wrongfully obtain anything of value, unless such 
transmission is exempted pursuant to paragraph (3)(B).

All I'm asking is to make the carrier liable if it should have been 
obvious to a carrier using basic traffic analysis that the service was a 
robocaller (low answer rates combined with tons of source numbers, 
especially situations where the source and destination number share the 
first 6 digits) that the carrier be liable for failing to look into it.

Carriers already look at things like short duration in order to assess 
higher charges, and already investigate call center traffic. If they 
then look at the caller ID and it looks "suspect", and the customer then 
is contacted and barred from sending arbitrary caller ID until they can 
verify they own the numbers they're calling from, then they're good to go.

If the carrier continues to just ensure that call center traffic is a 
revenue stream they can bill higher without making sure they're 
outpulsing valid numbers, then they should absorb the social costs of 
what's going on.

Let's not get this confused - this isn't about customer PBXen outpulsing 
forwarded calls when they do it, it's about people shooting millions of 
calls a month, the carrier hitting them with short duration charges, 
making more money, and having zero incentive to question the arrangement.

-Paul

On 7/11/19 1:18 PM, Christopher Morrow wrote:
> 'illicit use of caller id' - how is caller-id being illicitly used though?
> I don't think it's against the law to say a different 'callerid' in the call
>   session, practically every actual call center does this, right?
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