The KYUP reply round: 25 filings, 406 pages, 44% opposed

TransNexus read all 406 pages of reply comments on the FCC’s KYUP FNPRM and summarised each of the 25 submissions. Its tally: 28% supported the proposed rules, 44% opposed, with opponents arguing the rules are too prescriptive and short on flexibility. 12% asked the Commission to consolidate proceedings that overlap on these issues. 16% pushed for wider use of delegate certificates. 16% opposed giving the STI Governance Authority a stronger vetting role — including the STI-GA, which filed to that effect itself.

The filer list carries the argument. 49 state attorneys general and 52 state bankers associations for prescriptive requirements; AT&T, CTIA, NCTA and USTelecom against them. ATIS and the IP-NNI Task Force object to attestation requirements that diverge from ATIS standards. Somos argues responsibility should follow number assignment rather than routing. First Orion wants verified right-to-use and a ban on pay-for-attestation, and argues A and B attestations should not be treated as proof of legitimacy or shield a call from analytics, labeling or blocking.

16% of the filings came from TRS providers — ClearCaptions, Hamilton Relay, Sorenson, ZP Better Together — asking that their calls receive A-level attestation by default without authenticating them, on the basis that FCC certification already establishes who they are.

That is attestation read as a quality score rather than a statement about who vouched for the caller. Somos and First Orion argue against that reading from opposite ends, one from number assignment and one from analytics.

The STI-GA filed against being given a stronger vetting role. The body the rules would empower declined the job.