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

[Nathan Anderson]

Oh, I almost forgot...also on the tech stack side is the matter of getting your token from the STI-PA (which I should have mentioned is called an "SPC token"), and then getting your cert from your CA.

In brief, the STI-PA has an API for generating SPC tokens, but there isn't much in the way of public code out there.  Use of iconectiv's SPC token requesting API is a requirement...there is no friendly web interface you can use instead to perform a one-time manual request for an SPC token.  I had a proof-of-concept up and working, but haven't rolled anything out yet.  Sansay, though, will set themselves up to talk to the STI-PA and request SPC tokens on your behalf before generating your cert for you, at no extra cost.  This is what we are doing for the time being.

Many of the documents out there describing the whole STIR/SHAKEN ecosystem talk about using a slightly modified version of the industry-standard ACME API for requesting the actual cert from your CA (yes, the very same ACME API that e.g. LetsEncrypt uses for issuing TLS certs).  In practice, I found that very few SHAKEN CAs actually support this, and instead opted to implement proprietary RESTful APIs, or sometimes not provide any sort of API at all (either you have to manually generate a cert using their web portal, or take them up on one of their end-to-end STIR/SHAKEN products).  Yet again, Sansay to the rescue: they actually support ACME.  Yet again, I haven't gotten around to implementing this on our side, though that's on my to-do list.  So for the time being, I'm just using the Sansay web portal to manually generate our certs.  Note that you have to submit a valid SPC token with your ACME request, so you first have to clear the hurdle (above) of actually implementing an STI-PA SPC token request API client first...Sansay can't do this step for you if you choose to use ACME to automate your cert renewals.  Both a proper SPC token client and some kind of client for your particular SHAKEN CA provider (ACME, their proprietary API, etc.) would be a necessity if you wanted to pursue short-lifetime certs, which I believe is the long-term goal and the general recommendation made to providers by the STI-GA council (it's more difficult to compromise/steal someone's cert and use it long-term to sign a bunch of spam calls if the cert lifetime is measured in mere minutes...).  "libstirshaken" includes an ACME client (and a server for you to test against in a sandbox/dev enviro), and Sansay has their own ACME client as well that they can provide you with a copy of.

-- Nathan

-----Original Message-----
From: Nathan Anderson 
Sent: Friday, June 2, 2023 4:09 PM
To: Mary Lou Carey; Peter Beckman
Cc: 'Voice Ops'
Subject: RE: [VoiceOps] All carriers must get their STIR/SHAKEN certificate by June 30th!

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:marylou at backuptelecom.com] 
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:dfrankel at zipdx.com]
>>> 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 <voiceops-bounces at voiceops.org> On Behalf Of Mary Lou 
>>> Carey
>>> via VoiceOps
>>> Sent: Thursday, June 1, 2023 2:01 PM
>>> To: Nathan Anderson <nathana at fsr.com>
>>> Cc: Voice Ops <voiceops at voiceops.org>
>>> 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: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
>>>>>> _______________________________________________
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> Peter Beckman                                                  Internet 
> Guy
> beckman at angryox.com                                
> https://www.angryox.com/
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