Thanks both to you and Mary Lou for your thoughtful responses.
Okay, so just to be clear, the remaining carriers for whom the June
2023 deadline applies to are providers who provide dialtone to
end-users via POTS, but who originate at least some of the calls from
those end-users to the PSTN via an IP peer/trunk, and it is
specifically those calls that they now need to start signing but were
exempt from doing so until a month from now? And the reason that they
didn't have to implement a year ago (but pure IP-based interconnected
VoIP providers with < 100K subs *did*) is because § 64.6304(a)(1)(i)
only applies to "non-facilities-based" providers, and if a telecom is
building and maintaining POTS circuits to end-users, they are
facilities-based by definition?
This gets us into the weeds on the definition of "facilities-based".
I assume that the "facilities" in question must be facilities with
traditional telecom switching equipment (either analog or TDM). So
even if you run your own pure IP network end-to-end with no underlying
leased circuits, and outright own your physical data centers where you
house and run all of your own routers and SIP proxies, if 100% of your
voice subscriber base is provisioned via VoIP, even if the end-user's
VoIP equipment is talking to a server that you own, run, and maintain
in your own data center "facilities", you still do not count as a
"facilities-based" telecom, correct?
Is there some "minimum" amount of actual TDM you can be running on
your network in order for you to meet the definition of -- or claim
for yourself the status of -- "facilities-based"? If someone had zero
POTS circuits built to any of their end-users & all of their users are
connected to their voice network via VoIP, but they have a single ICA
with a single LEC, a TDM trunk between them and that LEC (where they
immediately gateway the TDM traffic to/from IP as it ingresses or
egresses their network), and a presence on the SS7 network...are they
now considered to be "facilities-based"? And would they similarly
have had all of their IP-trunked origination (calls that weren't going
out via their TDM connection to the LEC) exempted until this year, if
they had under 100K subs?
As far as my question about white-labeling service goes, to be clear,
we aren't in this category and have been signing our customers' calls
with our own SHAKEN cert for the past year. But I know of plenty of
other providers of similar size & scale (regional ISP whose bread and
butter is internet connectivity, but with a small sprinkling of VoIP
on top) who want to have a VoIP offering for various reasons, but
simply outsource 100% of the VoIP component to a white-labeler. They
bill the customer for the service, and presumably have a 499 Filer-ID
and file As and Qs with USAC, but they have nothing to do with the
underlying voice service...ATAs get drop-shipped to customers from the
white-labeler when service is ordered, the ISP doesn't have any hand
in the provisioning, they don't operate a single SIP proxy or media
gateway, they have zero numbering resources of their own and zero ICAs
with other carriers, etc. It's like the interconnected VoIP
equivalent to reselling an ILEC analog POTS line...they're just a
middle-man when it comes to billing (and thus, as an indirect result,
to collecting and remitting USF) and front-line support.
Now of course, many wholesale origination providers these days support
having you house your SHAKEN cert on their server & will sign your
outgoing calls for you with your own cert, and even those that don't
do this will still pass your own signature/Identity header in the SIP
INVITEs you send to them unmolested. But to be able to do the latter,
you need to be running a SIP proxy or B2BUA somewhere between the
end-user and your wholesale provider, which these other providers I'm
talking about aren't doing. And it's not at all clear to me that
most?/many?/any? *white-label* interconnected VoIP providers are set
up to do the former...they're all STIR/SHAKEN compliant of course, but
I'd guess they are signing all of the calls they originate with their
own cert.
That's only an educated guess on my part, of course, since I've been
looking around even after asking here, and have yet to find any first-
or even second-hand accounts one way or the other.
-- Nathan
-----Original Message-----
From: David Frankel [mailto:[email protected]]
Sent: Thursday, June 1, 2023 1:45 PM
To: 'Mary Lou Carey'; Nathan Anderson
Cc: 'Voice Ops'
Subject: RE: [VoiceOps] All carriers must get their STIR/SHAKEN
certificate by June 30th!
I am not an attorney; this is not legal advice.
The (primary) purpose of STIR/SHAKEN was not to help the ITG. The
purposes
are to (at the terminating or called-party end of the call) identify
the
entity responsible for originating the call, and allow that entity to
signal
what they know about the association between the caller and the calling
number.
We are just about to the point (end of this month) where virtually all
providers are required to sign the calls they originate and send onward
via
IP. That includes providers that serve so-called POTS customers (when
those
POTS customers place calls sent via other providers). See 47 CFR §
64.6301(a)(2)
This applies to the ORIGINATING provider. The expectation, as made
clear in
the implementing specs and regulations, is that the originating
provider
KNOWS who the caller is. ATIS says (ATIS-1000088): "Has a direct
authenticated relationship with the customer and can identify the
customer."
If you are a reseller and you are the one with the "direct
authenticated
relationship with the customer" then your (A- or B-) signature should
be on
the calls. As noted, you can get a SHAKEN token and delegate the
signing to
your underlying provider. But it will be your name, and your
reputation, on
the calls.
If you are an underlying provider and you do NOT know who the customer
is,
then insist that your reseller get a token and either sign the calls or
delegate that to you (with their token). If you do not know anything
about
the caller, then you are risking your reputation (and perhaps more) by
signing those calls.
More of my thoughts on this topic are here:
https://legalcallsonly.org/attestation-inflation-the-abcs-of-signing-calls/
If you find the regulations confusing, your best bet is to play it
safe.
That would mean signing calls with your OWN token when your direct
customer
is the one initiating the calls (that is, they are the "caller" for
legal
purposes and they are going to take responsibility for conformance of
the
calls to ALL the applicable regulations -- and there are many,
including
TCPA, TSR, fraud, and state statutes). You, as the originating
provider,
still have a set of responsibilities here -- see 47 CFR § 64.1200(n)(3)
as
ONE EXAMPLE. If the calls come to you from an entity that is not the
one
initiating the calls, then insist that the calls are signed when you
get
them (or that your customer provides you with their token so you can
affix
their signature).
As Mary Lou indicates, you are playing Russian roulette if you are
originating calls and they do not bear your signature. And your
underlying
provider is doing the same if they are accepting those calls unsigned
and
sending them onward.
The FCC has a Further Notice of Proposed Rulemaking that is open for
comment
RIGHT NOW on the topic of "Third-Party Caller ID Authentication." The
FNPRM
is available here:
https://docs.fcc.gov/public/attachments/FCC-23-18A1.pdf.
See starting at paragraph 97. Initial public comments on this FNPRM are
due
June 5 (Monday) and Reply Comments are due a month later. You'll be
able to
read (and file) comments here:
https://www.fcc.gov/ecfs/search/search-filings/results?q=(proceedings.name:(
%2217-97%22)). Once comments are filed the FCC will likely issue an
Order in
due course, which may be clarifying or confusing or both or neither.
David Frankel
ZipDX® LLC
St. George, UT USA
Tel: 1-800-FRANKEL (1-800-372-6535)
Visit My Robocall Blog
-----Original Message-----
From: VoiceOps <[email protected]> On Behalf Of Mary Lou
Carey
via VoiceOps
Sent: Thursday, June 1, 2023 2:01 PM
To: Nathan Anderson <[email protected]>
Cc: Voice Ops <[email protected]>
Subject: Re: [VoiceOps] All carriers must get their STIR/SHAKEN
certificate
by June 30th!
US telecom brain trust? Wow......I don't even know what to say, but I'm
thinking I should send my 21-year-old your way because he thinks he's a
lot
smarter than I am. LOL!
Im going to preface my response by saying I'm not sure anyone knows
exactly
what the ruling means because I've called the FCC and STI-GA multiple
times
to ask specific questions like yours. Any time my question gets too
detailed, I've been told to go read the ruling myself because they
aren't
attorneys and don't want to give legal advice that would steer me in
the
wrong direction. I don't know of any attorneys that have felt so
comfortable
discussing the details of the network that they have gone out on a limb
to
explain it to everyone either, so I can only tell you what I think
based on
what I've been told to date.
My understanding from talking to the FCC and STI-GA is that the purpose
of
STIR/SHAKEN was to help the ITG identify all the players in the
industry so
the ITG can more easily shut down the bad players and if necessary the
providers that enable those bad players. To me, that means regardless
of
whether a company has its own network, leases another carrier's
network, or
resells services, the FCC wants to identify every player in the
network. We
can debate which networks are exempt and which networks aren't, but
ultimately there's not a lot you can do if the powers that be decide
your
network should be compliant and it's not.
The choice to get a STIR/SHAKEN certificate is ultimately up to each
company. They can either play it safe and get a token or they can play
Russian Roulette with their business and not get a token. To date, I've
seen
the FCC/ITG give non-compliant carriers 30 days to become compliant,
but
that's not always enough time. I don't know if that is going to change
after
the deadline, but it could. It's not that difficult to get your own
certificate and if another carrier is already signing your calls it's
not
that much more cost-wise to have your own certificate. So to me it's
better
to be safe than sorry.
I hope that helps,
MARY LOU CAREY
BackUP Telecom Consulting
Office: 615-791-9969
Cell: 615-796-1111
On 2023-05-31 09:33 PM, Nathan Anderson via VoiceOps wrote:
I do find this a little confusing.
It's already clear that POTS service has been made exempt "until
further notice". So when the small operators exemption deadline was
pushed up from end of June 2023 to end of June 2022, that -- by
logical deduction -- could only have included small interconnected
VoIP operators (which I believe was made explicitly clear anyway, but
even if it had been ambiguous in the language, ...).
So, out of all the interconnected VoIP operators in the States large
OR small...who the heck is left who HASN'T already been required to
have it implemented on their network by this point?? I don't
understand who this June 2023 deadline applies to: the POTS circuit
providers aren't covered by it, and all sizes of interconnected VoIP
providers should have already implemented it a year ago at the latest.
Another question that occurs to me (I could probably find the answer
to this question with a little searching, but since I'm already here
talking to the U.S. telecom brain-trust): would a provider who merely
supplies white-labeled service from another interconnected VoIP
provider and slaps their own name on it be required to obtain their
own SHAKEN cert, and have the underlying VoIP provider sign any of
their customers' calls with that cert instead of a cert belonging to
the actual VoIP provider, even if the white-labeler/reseller has
literally nothing to do with the network at all that services the
calls?
-- Nathan
-----Original Message-----
From: VoiceOps [mailto:[email protected]] On Behalf Of
Michael Graves via VoiceOps
Sent: Wednesday, May 31, 2023 1:12 PM
To: Mary Lou Carey; Alex Balashov
Cc: [email protected]
Subject: Re: [VoiceOps] All carriers must get their STIR/SHAKEN
certificate by June 30th!
There was an extension for "small" providers (under 100k lines) ends
on June 30, 2023.
That extension was basically was targeting rural LECs. It was amended
so it only included those who have physical infrastructure to their
clients.
Those who do not operate such legacy infrastructure are supposed to be
signing their calls as of June 30, 2022.
There are further "gateway" orders about how any operator is supposed
to handle calls arriving on their network that are not signed.
Michael Graves
[email protected]
o: (713) 861-4005
c: (713) 201-1262
sip:[email protected]
-----Original Message-----
From: VoiceOps <[email protected]> On Behalf Of Mary Lou
Carey via VoiceOps
Sent: Wednesday, May 31, 2023 2:46 PM
To: Alex Balashov <[email protected]>
Cc: [email protected]
Subject: Re: [VoiceOps] All carriers must get their STIR/SHAKEN
certificate by June 30th!
Importance: High
Any carrier that provides originating VOIP or a combination of
originating VOIP / PSTN / Wireless VOICE services needs to get its
own certificate. My understanding is that only those who provide
PSTN-only voice services do not need to have their own STIR/SHAKEN
token because the technology still does not support it.
Mary Lou Carey
(615) 796-1111
MARY LOU CAREY
BackUP Telecom Consulting
Office: 615-791-9969
Cell: 615-796-1111
On 2023-05-31 02:11 PM, Alex Balashov wrote:
Hi Mary Lou,
Thank you for this.
A stupid - and certainly belated - question: how exactly is a carrier
defined, in the letter of the regulations underlying this deadline?
Or to put it another way: who, as a VoIP service provider of one sort
or another, _doesn't_ have to get their own token?
-- Alex
On May 31, 2023, at 1:46 PM, Mary Lou Carey via VoiceOps
<[email protected]> wrote:
Hey all,
I just wanted to send out a reminder that the drop dead date for all
carriers to get THEIR OWN STIR/SHAKEN certificate is coming up on
June 30th. You can still have an underlying carrier sign your calls
for you, but they must sign with YOUR token......not their own! You
have to register with the STI-PA to start the process at this link:
https://authenticatereg.iconectiv.com/register
You must have your own IPES Company Code (aka OCN) and 499 filer ID
to get a STIR/SHAKEN certificate. Just getting the certificate can
take up to several weeks so please don't wait until the last minute
to get one. I would hate to see anyone's network get shut down
because they aren't signing their calls as per the FCC guidelines.
MARY LOU CAREY
BackUP Telecom Consulting
Office: 615-791-9969
Cell: 615-796-1111
_______________________________________________
VoiceOps mailing list
[email protected]
https://puck.nether.net/mailman/listinfo/voiceops
_______________________________________________
VoiceOps mailing list
[email protected]
https://puck.nether.net/mailman/listinfo/voiceops
_______________________________________________
VoiceOps mailing list
[email protected]
https://puck.nether.net/mailman/listinfo/voiceops
_______________________________________________
VoiceOps mailing list
[email protected]
https://puck.nether.net/mailman/listinfo/voiceops
_______________________________________________
VoiceOps mailing list
[email protected]
https://puck.nether.net/mailman/listinfo/voiceops
_______________________________________________
VoiceOps mailing list
[email protected]
https://puck.nether.net/mailman/listinfo/voiceops
