You can obtain the IPES OCN without the FCC Numbering Waiver - I know
this first hand as that's exactly what we did
From the looks of it, the OCN process took about 48 hours for them to
issue it.
Jeff
On Tue, Jun 6, 2023 at 10:36 PM Nathan Anderson via VoiceOps
<[email protected]> wrote:
Hmm, so after going back and reviewing other things, including
re-reading some old posts (Mary's included!) from this here mailing
list, there seems to be some ambiguity and conflicting information.
I certainly don't want to be guilty of misinforming people, so I'll
just follow up & summarize here, presenting the one possibility I
see as a workaround to this problem:
I think the change Mary was referring to was in the STI-PA policy,
laying out requirements for service providers who want access to
STI-PA SPC tokens. Originally, they were:
1. Have a current (most recent complete calendar year) 499A filed.
2. Have an OCN.
3. Have direct access to numbering resources.
In Q2 2021, requirement #3 was removed and replaced with a new one:
3. List yourself in the RMP database.
Where the ambiguity comes in is that, despite the official STI-PA
policy removing this particular requirement, they still require an
OCN (#2), and as pointed out before, it can't just be an OCN of any
type. Only an OCN of a type "that is eligible for Numbering
Resource assignments" is acceptable to them, and what I took away
from this was that the numbering resource access requirement hasn't
actually been rescinded. It's seemingly still there, just no longer
explicitly spelled out in the top 3 requirements...if they intended
for that to not be a requirement any longer, they really biffed it
by creating this chicken-and-egg problem when they limited the types
of approved OCNs.
There seems to be some support for the idea (incl. from Mary!:
https://puck.nether.net/pipermail/voiceops/2021-May/008895.html)
that it is now possible to obtain an IPES OCN from NECA without
first petitioning the FCC for a VoIP numbering resource waiver.
NECA themselves seems to be of two minds about this: page 4 of
https://www.neca.org/docs/default-source/public---business-solutions/code-administration/na_procedures0422.pdf?sfvrsn=2b358470_8
only lists the requirements Mary stated in her May 2021 post that I
linked to, but the page at
https://www.neca.org/business-solutions/company-codes/company-code-request-instructions
says IPES is "only permitted with an FCC waiver".
Okay, so...which is it?
I suppose one way to resolve this ambiguity, in favor of the
argument that no FCC waiver is required for interconnected VoIP
providers, is thusly:
* STI-PA will only grant SPC tokens to providers who have a type of
OCN "that is eligible for Numbering Resource assignments"
* The list of specific OCN types that fall under this category are
presented at
https://www.neca.org/business-solutions/company-codes/company-code-request-instructions
and "IPES" is in the list
* But perhaps NECA will assign IPES OCNs without requiring that you
produce an FCC numbering waiver for your company, as long as you
provide the documentation outlined at
https://www.neca.org/docs/default-source/public---business-solutions/code-administration/na_procedures0422.pdf
* The parenthetical of "(only permitted with an FCC waiver)" on the
NECA page only means that if you hold an IPES OCN and *want* access
to numbers, you still have to separately petition the FCC for the
waiver...but is not meant to imply that you can only be *granted* an
IPES OCN after having first obtained such a waiver (another
ambiguity! the parenthetical could arguably be read either way!).
Meaning you can hold an IPES OCN *without* having access to
numbering resources, though you could *get* access at any time
simply by going through the waiver process with the FCC.
In which case, you could argue that none of these seemingly
contradictory requirements are actually in conflict: IPES OCNs are
*eligible* (key word) for numbering resources, even if you yourself
have not yet been granted that eligibility status by the FCC. So as
long as you come to the STI-PA with an IPES OCN, they won't also try
to confirm that you have the FCC waiver, and since the IPES OCN is
in the list of approved OCN types, you are good to go?
Ugh, the mental gymnastics required to arrive at such a conclusion
are exhausting...you'd think somebody with some authority (e.g.,
FCC, NECA, STI-GA) could unambiguously just state the facts in a
central, public location one way or the other.
Does anybody here have any first-hand experience with obtaining an
IPES OCN *and* being approved as a SPC-token-eligible carrier by
iconectiv *without* having obtained the FCC numbering waiver?
-- Nathan
-----Original Message-----
From: VoiceOps [mailto:[email protected]] On Behalf Of
Nathan Anderson via VoiceOps
Sent: Tuesday, June 6, 2023 5:54 PM
To: 'Mary Lou Carey'
Cc: 'Voice Ops'
Subject: Re: [VoiceOps] All carriers must get their STIR/SHAKEN
certificate by June 30th!
Also note that not all OCN types are accepted by STI-PA. Whatever
OCN you supply to them MUST be of one of the types "that is eligible
for Numbering Resource assignments" (page 3 @
https://authenticate.iconectiv.com/sites/authenticate/files/2021-10/Service_Provider_Guidelines_Issue_6.pdf).
So, for example, none of the reseller OCN types (e.g., LRSL) would
be eligible.
NECA provides a list of specific OCN types that are eligible for
numbering resources here:
https://www.neca.org/business-solutions/company-codes/company-code-request-instructions
They list IPES among them, of course, but with the note that it's
"only permitted with an FCC waiver".
I believe it was this chain of logic (STI-PA only allows specific
OCN types, NECA lists them, IPES is among them but specifically says
you must get an FCC waiver) that led me to conclude that the FCC
numbering authorization waiver was *still a requirement*
specifically if you were going the *IPES* route. I have not been
able to find anything that specifically exempts / rescinds this
requirement.
Note that you don't have to actually *have* or even *seek* your own
numbering resources. You just have to be *eligible* to do so. The
OCN type you have been granted serves as proof to the STI-PA that
this is the case.
-- Nathan
-----Original Message-----
From: VoiceOps [mailto:[email protected]] On Behalf Of
Nathan Anderson via VoiceOps
Sent: Tuesday, June 6, 2023 5:39 PM
To: 'Mary Lou Carey'
Cc: 'Voice Ops'
Subject: Re: [VoiceOps] All carriers must get their STIR/SHAKEN
certificate by June 30th!
That note about RMP vs. numbering authorization might be
*technically* correct purely from the perspective of what the STI-PA
themselves requires. But my understanding is that to obtain an IPES
OCN, you still need to jump through the FCC numbering authorization
hoops. So effectively, the requirement to petition the FCC for
numbering authorization still applies to the vast majority of
interconnected VoIP providers, *unless* you apply for an OCN type
*other* than the IPES one. Would love to know if I'm misreading
this..(I'll try to go back and refresh myself on what led me to this
conclusion, too...perhaps the "9th hour" you refer to was so late
that this change you are talking about didn't happen until well
after June 1st of last year?)
Also yes, if you apply for CLEC OCN, then that is done state by
state and not nationally. We went this route because 1) we already
had obtained CPCNs from the states we operate in some time ago, and
just hadn't done anything with them 2) we have no plans to expand
our local coverage area anytime soon, 3) we were concerned enough
last year by the 30-day FCC comment period & whether we would get
approval "in time", that CLEC OCNs seemed like they would actually
be faster to obtain (since we could immediately apply to NECA for
OCNs and not have to wait on the FCC at all for anything).
The thing that made it a pain was just that initially NECA had
quibbles with us about the copies of the CPCNs that we provided to
them, and it took a bunch of back-and-forth communication and
argumentation to convince them to accept them. Which they finally
did, and in the end, it still took less than 30 days. And we had
enough time to spare after that, that we were able to apply to the
STI-PA, and finally to sign up with a SHAKEN CA and buy a cert, and
bring the tech stack online on our side to support all of this new
infrastructure, all before the June 30 deadline. Not sure we could
have made it if we had been forced to go the IPES route instead (it
would have been cutting it VERY close, assuming it would have even
been possible).
Again, this just had to do with our *particular* circumstances &
timing at the time, so I'm not trying to advise that anybody else do
it this way...in fact I'd actively join you in discouraging it. Go
the IPES route if possible. The main problem is that if there is
anybody at this point who isn't yet signing their calls, and they
don't even have an OCN yet, well...we're now already into the first
full week of June. So if my understanding is correct that
specifically the *IPES* type OCN does still require numbering
authorization thumbs-up from the FCC in order to obtain one, then it
would be absolutely impossible for such an entity to meet the June
30 2023 deadline while pursuing that strategy.
-- Nathan
-----Original Message-----
From: Mary Lou Carey [mailto:[email protected]]
Sent: Tuesday, June 6, 2023 2:23 PM
To: Nathan Anderson
Cc: Peter Beckman; 'Voice Ops'
Subject: Re: [VoiceOps] All carriers must get their STIR/SHAKEN
certificate by June 30th!
Just so you know there were a few changes made to the process in the
9th
hour of the deadline last year. The Robocall Mitigation plan took
the
place of the requirement to get a VOIP numbering authorization from
the
FCC. So you just need to file a Robocall Mitigation Plan - not the
FCC
Numbering Authorization.
Secondly, CLEC OCNs are assigned by state but if you're VOIP, one
OCN
(aka company code) is assigned for the whole country. The IPES OCN
covers both interconnected VOIP and non-Interconnected VOIP. Clearly
a
mistake in my opinion because you can't tell a non-interconnected
VOIP
from an Interconnected VOIP but that's the way it is.
You don't want to get a CLEC, Resale or ULEC OCN if you're a VOIP
provider. It's most advantageous to get the IPES OCN.
MARY LOU CAREY
BackUP Telecom Consulting
Office: 615-791-9969
Cell: 615-796-1111
On 2023-06-02 06:09 PM, Nathan Anderson wrote:
Mary's right: there are a lot of moving parts and "hidden costs"
to
doing this. What follows is largely a "brain dump" on what I know
based on what we went through last year.
Presumably if you are here on VoiceOps and asking about getting a
cert, you likely are a 499 filer already.
On top of that, though, as pointed out, you need a STI-PA token
issued
to you by the Policy Administrator in order to request a SHAKEN
cert
from one of the approved vendors...the STI-PA essentially "vets"
you
as an eligible telecom in advance, and then issues you a token,
which
you in turn have to submit to your SHAKEN CA vendor of choice when
you
apply to them for a cert. The CA has to validate the token you
submitted before they can issue the certificate to you. Unlike
with
the SHAKEN cert, which is similar to a SSL/TLS cert in that there
are
many certificate authorities competing with one another for your
business, the STI-PA contract has been awarded to a single
company:
iconectiv. You need to go to them and get set up in their system.
In order to be approved by the STI-PA, though, you need to have an
OCN
issued to your company if you don't have one already. The
STI-PA/iconectiv will ask you for this when you sign up with them,
and
you can't proceed without one. The company that administers all
OCN
assignments is NECA.
As far as costs go, the OCN allocation is a one-time fee, and the
prices are published here:
https://www.neca.org/business-solutions/company-codes ...the
STI-PA
fees are annual and based on your telecom revenues as reported on
your
most recent 499A filing. I can't remember the exact number, but I
want to say it's a very small percentage, perhaps even under 1%.
But
of course there is some "minimum" absolute $ number that it will
never
be lower than, heh. (Quickly looked that up; looks like that
minimum
annual figure is $825.) Then there are of course whatever costs
you
have to pay to consultants or lawyers to help you put all of these
puzzle pieces together, which I think was what Mary was largely
addressing.
I think what Peter was specifically asking about, though, was the
cost
for the actual SHAKEN certificate itself, and what vendor to use
for
that. iconectiv maintains an up-to-date list of approved SHAKEN
CAs
that you can pick from:
https://authenticate.iconectiv.com/approved-certification-authorities
Vast majority of them don't like to publish their prices & you
have to
ask. From the research I did last year, pricing basically starts
at
~$1,000/year, and that's on the LOW side: the average annual price
is
actually much higher than that from most CAs. What I can tell you
is
that we chose to go with Sansay. Theirs was not only the lowest
price
by far, but their system and policies were also the most
reasonable
out of all the SHAKEN CAs that I talked to by a *mile*. (As just
one
example, you essentially get unlimited cert reissues during the
year,
while many other CAs will charge you if you need to revoke a
compromised cert and request a new one.) They went WELL out of
their
way to help me get onboarded and running, too. Can't say enough
good
things about them; just everything about the experience of working
with them has been top-notch. It's almost like they actually
wanted
my business!! I recommend reaching out to Carlos Perez w/ Sansay
(you
can find him hanging out here @ VoiceOps)...he is the man.
From just a purely pain-in-the-tuchus perspective, the most
difficult
process to get through of all the aforementioned ones was
definitely
obtaining our OCN allocation. But that could just be because of
our
particular unique circumstances...we chose to tackle it ourselves
rather than farm it out, and we applied as a CLEC. If you are
purely
an interconnected VoIP provider, though, and not an actual CLEC, I
have to imagine that taking the IPES "golden path" is going to
prove
to be much less of a hassle. This will require that you apply to
the
FCC for a "VoIP Numbering Authorization" before you apply for your
OCN:
https://www.fcc.gov/wireline-competition/competition-policy-division/numbering-resources/general/voip-numbering
-- do note that this has an inherent 30-day built-in wait time,
since
the FCC requires that your application be open to public comment
for a
30 day period before they make a ruling. Which means,
unfortunately,
that if you haven't already started this process by this point,
you
aren't going to be able to obtain your OCN before June 30, much
less
an actual SHAKEN cert.
Once you finally have your OCN, you also need to make sure you
have a
documented robocall mitigation plan filed with the FCC at
https://fccprod.servicenowservices.com/rmd?id=rmd_welcome before
iconectiv will get you set up on the STI-PA side. Also, once you
finally have your SHAKEN cert and are actively signing calls, you
need
to go back to the FCC robocall mitigation database and update your
entry in the database to reflect the fact that you are now
STIR/SHAKEN
compliant.
On the tech stack side, you need to host your SHAKEN cert on a
public
server so that other telecoms who receive calls from your users
can
validate that the calls that you are signing are indeed authentic.
And your outgoing calls need to include a new field within the SIP
headers called "Identity", which is a Base64-encoded version of
the
signature for that particular call (signed by your private key),
along
with the URL pointing at your public cert (which is also embedded
within the encrypted signature, so when it's decrypted and the two
match, that validates that the public cert located at that URL is
indeed yours). The payload of the "Identity" header is called a
PASSporT (yet another in a series of groan-worthy backronyms...)
Virtually all of the SHAKEN cert providers also offer end-to-end
solutions for VoIP providers that take care of all of this for
you:
they'll host your public cert for you on their servers, and many
even
offer a cloud API or SIP proxy service that will sign your calls
for
you (by also storing your private key in a secure location on
their
side & either generating the Identity header for your and sending
it
back to you so that you can include it in the call, or by having
you
send your SIP INVITEs to their proxy where they'll just add it to
the
SIP header for you before they pass the INVITE on to your
termination
provider). Of course, all these extra services often have
additional
costs associated with them. Once again, we elected to implement
our
own solution, and I based it largely on Signalwire's open source
"libstirshaken" codebase:
https://github.com/signalwire/libstirshaken
-- this can integrate directly with FreeSwitch if that's what you
use,
but in our case I just built the included command-line
"stirshaken"
demo utility, and shell out to that to generate the PASSporTs
which
then get added to the SIP header for our outgoing INVITEs.
Hope that at least some part of this proves helpful, and good
luck,
-- Nathan
-----Original Message-----
From: Mary Lou Carey [mailto:[email protected]]
Sent: Friday, June 2, 2023 1:16 PM
To: Peter Beckman
Cc: Nathan Anderson; 'Voice Ops'
Subject: Re: [VoiceOps] All carriers must get their STIR/SHAKEN
certificate by June 30th!
I can only give you a ballpark price because it depends on what
you
need
to be done. You need to have an OCN, 499 filer ID, and Robocall
Mitigation plan in place before you can apply for the STI-PA. If
you
have those in place already the cost is obviously less.
I have someone that does the filings for my clients. If a company
needs
everything she charges between $1200-$1500 range not including the
NECA
fee for the OCN. If the company already has everything except the
STI-PA
registration then you're looking in the $300 - $500 range. The
variance
in cost just depends on whether or not there are any issues with
your
499 status.
MARY LOU CAREY
BackUP Telecom Consulting
Office: 615-791-9969
Cell: 615-796-1111
On 2023-06-02 02:48 PM, Peter Beckman wrote:
What is the most affordable and fast way to get a cert? E.g. how
much
should one pay, and to whom?
On Fri, 2 Jun 2023, Mary Lou Carey via VoiceOps wrote:
VOIP carriers were not typically considered facilities-based
because
they didn't have their own switch, circuits, or NXXs connected
to the
ILECs. Now they can get their own NXXs if they get numbering
authorization from the FCC, but their PSTN connections still
have to
ride another carrier's network to be connected to the ILEC so
they
still fall under non-Facilities based like resellers do.
The only companies that are still exempt are the ones whose
entire
networks are completely operated via SS7 trunking. The only
reason
they are allowed to be exempt is that STIR/SHAKEN doesn't work
well
on
an SS7 network. Since no one has been able to figure out a way
to
solve that problem, they can't require them to be compliant. So
if
any
portion of your network operates on VOIP, then you need to get a
STIR/SHAKEN certificate for that portion of your network.
Sucks I know, but
MARY LOU CAREY
BackUP Telecom Consulting
Office: 615-791-9969
Cell: 615-796-1111
On 2023-06-01 09:23 PM, Nathan Anderson via VoiceOps wrote:
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
_______________________________________________
VoiceOps mailing list
[email protected]
https://puck.nether.net/mailman/listinfo/voiceops
---------------------------------------------------------------------------
Peter Beckman
Internet
Guy
[email protected]
https://www.angryox.com/
---------------------------------------------------------------------------
_______________________________________________
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
