[VoiceOps] Update on STIR/SHAKEN guidelines

[Mary Lou Carey]

The actual fix has not been announced as far as I know. What I was able 
to find out is that the goal is for every company to have their own 
certificate/token and for the FCC to provide an alternative method of 
certification/waiver so every company that needs a certificate can get 
one.

I believe everyone will have to apply for a certification or waiver 
either way so my recommendation for the companies that don't want their 
own NXXs is to submit the FCC Numbering Authorization application with 
their existing DID provider agreement instead of a PSTN connection 
agreement. Then explain in the section that covers your business model 
and area of service that you are ONLY applying to receive a STIR/SHAKEN 
certificate. That way the FCC can figure out which type of certification 
/ waiver /etc you should be given. If they decide to create a new type 
of certification with a different docket number, then may have to modify 
your documents and submit everything under the new docket number but I 
don't foresee the basic requirements being much different either way.


I do help companies get set up to be an Interconnected VOIP provider 
and/or qualify for a STIR/SHAKEN certificate. I also help with the NXX 
ordering / Number Porting set-up and training / AOCN services but I do 
not handle the Certificate Authority. I refer that out to companies like 
TransNexus. I've been so inundated with new clients lately that I've had 
to hire someone to help me with the FCC Numbering Authorizations. I'm 
sure every other consultant that does this type of work is seeing the 
same thing so my suggestion to every carrier is to get the process 
started as soon as they can. It can take anywhere from 3-6 months to get 
your FCC Certificate depending on what you have in place already.

MARY LOU CAREY
BackUP Telecom Consulting
Office: 615-791-9969
Cell: 615-796-1111

On 2020-10-09 07:11 AM, Chris Wallace wrote:
> This was very helpful and confirms I am not the only one scratching my
> head at this requirement. I am current stuck in the registration
> process because our OCN is listed as a “VoIP Provider” and
> iConectiv is wanting to verify our _VoIP Numbering Resource
> Authorization _with the FCC.
> 
> Have you heard of any changes to this part of the process, it seems
> like a lot of hoops and wasted time/resources for something we will
> never utilize (regarding direct access to numbering resources).
> 
> - Chris
> 
> On Tue, Sep 29, 2020 at 2:29 PM Mary Lou Carey
> <marylou at backuptelecom.com> wrote:
> 
>> Just wanted to give everyone an update on the STIR/SHAKEN
>> certification
>> process because I know everyone has been confused about
>> it......including me which is pretty sad because I've spent the last
>> 20
>> years helping carriers turn up their networks and get access to
>> direct
>> numbering resources! I spoke with the FCC, STI-GA Director and NECA
>> to
>> figure out where the breakdown is for those telecom companies that
>> currently don't have direct access to numbering resources
>> (NPA-NXXs).
>> 
>> Since some carriers have come to me with an IPES OCN and some have
>> been
>> denied, my first question was "Why are some Interconnected VOIP
>> providers that don't have an FCC Numbering Authorization being
>> assigned
>> IPES OCNs when others are turned down?" I found out you can get an
>> IPES
>> OCN without the FCC Numbering Authorization if you submit an
>> Interconnect Agreement with your current wholesale DID provider.
>> However, the STI-GA won't approve you for a STIR/SHAKEN certificate
>> if
>> you don't have the FCC Numbering Authorization. Getting an FCC
>> Numbering
>> Authorization is where the breakdown occurs because even though IPES
>> 
>> providers aren't required to order their own NPA-NXXs, the FCC
>> requires
>> the applicant to submit an Interconnection Agreement with a PSTN
>> connection provider to get approved. After discussing this problem
>> with
>> both the FCC and STI-GA, I was told they are aware of the problem
>> this
>> requirement poses for carriers who don't have/want their own NXXs
>> and
>> are working to provide an alternative method for these companies to
>> acquire their own STIR/SHAKEN certificate. Their goal is for every
>> company to have their own STIR/SHAKEN certificate. At this point I'm
>> not
>> sure if the FCC will give an exemption to these carriers or assign a
>> 
>> different type of certification, but either way it seems every
>> company
>> will have to submit paperwork to the FCC to qualify for their
>> STIR/SHAKEN certificate.
>> 
>> In the meantime, I found out that those companies who ONLY order
>> DIDs
>> from a wholesale DID provider CAN use their DID provider's token IF
>> their wholesale DID provider agrees to let them. However, know that
>> Wholesale DID providers can just as easily get their STIR/SHAKEN
>> token
>> revoked. Maybe even more easily because if any of their customers
>> get
>> caught certifying bad traffic they are held responsible for passing
>> that
>> traffic. Since moving your DIDs / traffic to a new wholesale
>> provider is
>> not a simple or inexpensive process and getting certified yourself
>> if
>> not a quick process, I would recommend that this be an interim
>> solution
>> and not a long term fix. My suggestion for those who don't need
>> direct
>> access to numbering resources is to go ahead and apply for the FCC
>> numbering authorization with your existing wholesale DID provider
>> agreement and just explain that you only need authorization to get a
>> 
>> STIR/SHAKEN certificate. That way the FCC has all the information
>> they
>> need and can determine what to assign your company. At this time,
>> the
>> cut off date for getting your traffic certified is still June 2021.
>> It
>> takes anywhere from 2-6 months to get through the certification
>> process
>> (depending on what you already have in place), so it's not something
>> 
>> that you should wait until the last minute to start.
>> 
>> Hope this helps!
>> 
>> MARY LOU CAREY
>> BackUP Telecom Consulting
>> Office: 615-791-9969
>> Cell: 615-796-1111
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