[VoiceOps] All carriers must get their STIR/SHAKEN certificate by June 30th!

Thu Jun 1 16:01:01 EDT 2023

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:voiceops-bounces at voiceops.org] On Behalf Of
> Michael Graves via VoiceOps
> Sent: Wednesday, May 31, 2023 1:12 PM
> To: Mary Lou Carey; Alex Balashov
> Cc: voiceops at voiceops.org
> 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
> mgraves at mstvp.com
> o: (713) 861-4005
> c: (713) 201-1262
> sip:mgraves at mjg.onsip.com
> 
> -----Original Message-----
> From: VoiceOps <voiceops-bounces at voiceops.org> On Behalf Of Mary Lou
> Carey via VoiceOps
> Sent: Wednesday, May 31, 2023 2:46 PM
> To: Alex Balashov <abalashov at evaristesys.com>
> Cc: voiceops at voiceops.org
> 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
>>> <voiceops at voiceops.org> 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
>>> VoiceOps at voiceops.org
>>> https://puck.nether.net/mailman/listinfo/voiceops
> _______________________________________________
> VoiceOps mailing list
> VoiceOps at voiceops.org
> https://puck.nether.net/mailman/listinfo/voiceops
> _______________________________________________
> VoiceOps mailing list
> VoiceOps at voiceops.org
> https://puck.nether.net/mailman/listinfo/voiceops
> _______________________________________________
> VoiceOps mailing list
> VoiceOps at voiceops.org
> https://puck.nether.net/mailman/listinfo/voiceops