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

[Mary Lou Carey]

NECA technically has 10 days to issue an OCN but as long as they have no 
problems with your documentation then it usually happens quicker than 
that.

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

On 2023-06-06 11:10 PM, Jeff Waddell wrote:
> 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
> <voiceops at voiceops.org> 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 actually been rescinded.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:voiceops-bounces at voiceops.org] 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:voiceops-bounces at voiceops.org] 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:marylou at backuptelecom.com]
>> 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: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
>>>>>>>>> _______________________________________________
>>>>>>>>> VoiceOps mailing list
>>>>>>>>> VoiceOps at voiceops.org
>>>>>>>>> https://puck.nether.net/mailman/listinfo/voiceops
>>>>>>> _______________________________________________
>>>>>>> VoiceOps mailing list
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>>>>>> _______________________________________________
>>>>>> VoiceOps mailing list
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>>>>>> _______________________________________________
>>>>>> VoiceOps mailing list
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>>>>> _______________________________________________
>>>>> VoiceOps mailing list
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>>>>> 
>>>> 
>>>> 
>> 
> ---------------------------------------------------------------------------
>>>> Peter Beckman
>>>> Internet
>>>> Guy
>>>> beckman at angryox.com
>>>> https://www.angryox.com/
>>>> 
>> 
> ---------------------------------------------------------------------------
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