FCC chairwoman: Fines alone aren't enough (Robocalls)

Tue Oct 4 20:42:32 UTC 2022

Inter-telco trunks aren’t all SIP, you might be surprised how much “traditional” trunking there still is.

> On Oct 4, 2022, at 3:18 PM, Michael Thomas <mike at mtcc.com> wrote:
> 
> 
> 
> 
>> On 10/4/22 11:58 AM, Tom Beecher wrote:
>>>  Honestly the root of a lot of the problems here is the bellheaded insistence of still using E.164 addresses in the first place. With SIP they are complete legacy and there is no reason that my "telephone number" can't be mike at mtcc.com.
>> 
>> You can do that all you want. You just don't get to interact with the PSTN.
> What is the "PSTN" these days? It's a bunch of interconnected SIP proxies where there is nothing special about the identifiers used. With end to end SIP (or middle to middle, etc), the routing is not being done with e.164 addresses like in the legacy PSTN. It's just bellheaded thinking that e.164 addresses mean anything these days.The only time they make any difference is if they need to off ramp to legacy signaling which is becoming rarer and rarer. 
> 
> Mike
> 
> 
> 
>> 
>> On Tue, Oct 4, 2022 at 2:53 PM Michael Thomas <mike at mtcc.com> wrote:
>>> 
>>>> On 10/4/22 11:31 AM, Mike Hammett wrote:
>>>> What's regulated or implemented is rarely the best course of action. Does this cause more good or harm?
>>> 
>>> Honestly the root of a lot of the problems here is the bellheaded insistence of still using E.164 addresses in the first place. With SIP they are complete legacy and there is no reason that my "telephone number" can't be mike at mtcc.com. In fact, that would be a huge win since I could just use my email address book to make a call. You could tell that STIR/SHAKEN really went off the rails when it has heuristics on how to scrape E.164 addresses in the From: field. At this point we should be mostly ignoring legacy signaling, IMO. 
>>> 
>>> 
>>> 
>>> Mike
>>> 
>>>> 
>>>> 
>>>> 
>>>> -----
>>>> Mike Hammett
>>>> Intelligent Computing Solutions
>>>> http://www.ics-il.com
>>>> 
>>>> Midwest-IX
>>>> http://www.midwest-ix.com
>>>> 
>>>> From: "Shane Ronan" <shane at ronan-online.com>
>>>> To: "Michael Thomas" <mike at mtcc.com>
>>>> Cc: "Mike Hammett" <nanog at ics-il.net>, nanog at nanog.org
>>>> Sent: Tuesday, October 4, 2022 1:21:41 PM
>>>> Subject: Re: FCC chairwoman: Fines alone aren't enough (Robocalls)
>>>> 
>>>> Except the cost to do the data dips to determine the authorization isn't "free".
>>>> 
>>>> On Tue, Oct 4, 2022 at 2:18 PM Michael Thomas <mike at mtcc.com> wrote:
>>>>> 
>>>>> On 10/4/22 6:07 AM, Mike Hammett wrote:
>>>>> I think the point the other Mike was trying to make was that if everyone policed their customers, this wouldn't be a problem. Since some don't, something else needed to be tried.
>>>>> 
>>>>> 
>>>>> Exactly. And that doesn't require an elaborate PKI. Who is allowed to use what telephone numbers is an administrative issue for the ingress provider to police. It's the equivalent to gmail not allowing me to spoof whatever email address I want. The FCC could have required that ages ago.
>>>>> 
>>>>> 
>>>>> 
>>>>> Mike
>>>>> 
>>>>> 
>>>>> -----
>>>>> Mike Hammett
>>>>> Intelligent Computing Solutions
>>>>> http://www.ics-il.com
>>>>> 
>>>>> Midwest-IX
>>>>> http://www.midwest-ix.com
>>>>> 
>>>>> From: "Shane Ronan" <shane at ronan-online.com>
>>>>> To: "Michael Thomas" <mike at mtcc.com>
>>>>> Cc: nanog at nanog.org
>>>>> Sent: Monday, October 3, 2022 9:54:07 PM
>>>>> Subject: Re: FCC chairwoman: Fines alone aren't enough (Robocalls)
>>>>> 
>>>>> The issue isn't which 'prefixes' I accept from my customers, but which 'prefixes' I accept from the people I peer with, because it's entirely dynamic and without a doing a database dip on EVERY call, I have to assume that my peer or my peers customer or my peers peer is doing the right thing.
>>>>> 
>>>>> I can't simply block traffic from a peer carrier, it's not allowed, so there has to be some mechanism to mark that a prefix should be allowed, which is what Shaken/Stir does.
>>>>> 
>>>>> Shane
>>>>> 
>>>>> 
>>>>> 
>>>>> On Mon, Oct 3, 2022 at 7:05 PM Michael Thomas <mike at mtcc.com> wrote:
>>>>>> The problem has always been solvable at the ingress provider. The 
>>>>>> problem was that there was zero to negative incentive to do that. You 
>>>>>> don't need an elaborate PKI to tell the ingress provider which prefixes 
>>>>>> customers are allow to assert. It's pretty analogous to when submission 
>>>>>> authentication was pretty nonexistent with email... there was no 
>>>>>> incentive to not be an open relay sewer. Unlike email spam, SIP 
>>>>>> signaling is pretty easy to determine whether it's spam. All it needed 
>>>>>> was somebody to force regulation which unlike email there was always 
>>>>>> jurisdiction with the FCC.
>>>>>> 
>>>>>> Mike
>>>>>> 
>>>>>> On 10/3/22 3:13 PM, Jawaid Bazyar wrote:
>>>>>> > We're talking about blocking other carriers.
>>>>>> >
>>>>>> > On 10/3/22, 3:05 PM, "Michael Thomas" <mike at mtcc.com> wrote:
>>>>>> >
>>>>>> >      On 10/3/22 1:54 PM, Jawaid Bazyar wrote:
>>>>>> >      > Because it's illegal for common carriers to block traffic otherwise.
>>>>>> >
>>>>>> >      Wait, what? It's illegal to police their own users?
>>>>>> >
>>>>>> >      Mike
>>>>>> >
>>>>>> >      >
>>>>>> >      > On 10/3/22, 2:53 PM, "NANOG on behalf of Michael Thomas" <nanog-bounces+jbazyar=verobroadband.com at nanog.org on behalf of mike at mtcc.com> wrote:
>>>>>> >      >
>>>>>> >      >
>>>>>> >      >      On 10/3/22 1:34 PM, Sean Donelan wrote:
>>>>>> >      >      > 'Fines alone aren't enough:' FCC threatens to blacklist voice
>>>>>> >      >      > providers for flouting robocall rules
>>>>>> >      >      >
>>>>>> >      >      > https://www.cyberscoop.com/fcc-robocall-fine-database-removal/
>>>>>> >      >      >
>>>>>> >      >      > [...]
>>>>>> >      >      > “This is a new era. If a provider doesn’t meet its obligations under
>>>>>> >      >      > the law, it now faces expulsion from America’s phone networks. Fines
>>>>>> >      >      > alone aren’t enough,” FCC chairwoman Jessica Rosenworcel said in a
>>>>>> >      >      > statement accompanying the announcement. “Providers that don’t follow
>>>>>> >      >      > our rules and make it easy to scam consumers will now face swift
>>>>>> >      >      > consequences.”
>>>>>> >      >      >
>>>>>> >      >      > It’s the first such enforcement action by the agency to reduce the
>>>>>> >      >      > growing problem of robocalls since call ID verification protocols
>>>>>> >      >      > known as “STIR/SHAKEN” went fully into effect this summer.
>>>>>> >      >      > [...]
>>>>>> >      >
>>>>>> >      >      Why did we need to wait for STIR/SHAKEN to do this?
>>>>>> >      >
>>>>>> >      >      Mike
>>>>>> >      >
>>>>>> >
>>>>>> >
>>>>> 
>>>> 
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