[VoiceOps] Update on STIR/SHAKEN guidelines

Mary Lou Carey marylou at backuptelecom.com
Tue Sep 29 14:28:31 EDT 2020

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!

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

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