I checked in with iconectiv to get a bit more clarification. iconectiv does not speak authoritatively as to what it takes to get a 499A filer ID, nor an OCN. Of course, I don't either. You should go to the respective authorities (USAC and NECA) to make your applications. There ARE foreign entities with 499A filer IDs. For example: https://apps.fcc.gov/cgb/form499/499detail.cfm?FilerNum=834713 Their address is in Singapore. You'll find that they have a SHAKEN token (listed by iconectiv as an Authorized Provider). Also this one in Hong Kong: https://apps.fcc.gov/cgb/form499/499detail.cfm?FilerNum=834534 And this one in Canada: https://apps.fcc.gov/cgb/form499/499detail.cfm?FilerNum=832443 Also both listed by iconectiv as Authorized Providers. iconectiv may ask you for a US address, but they won't send you any mail. Thus, you can see that foreign providers CAN get SHAKEN tokens. For 499A filing, you'll probably need a US address for legal service of documents; there are third party agents you can engage for this. Perhaps that address is also good for iconectiv. Point is, you can navigate this if you so choose, and I'm sure you can make it through the NECA process as well to obtain an OCN. I don't have any reason to believe that the examples given above were created through some nefarious process. The best reason I heard (really) for a foreign entity being "unable" to obtain a SHAKEN token: "We didn't attempt to get one." That said, there are also plenty of specious Robocall Mitigation Database filings, including false certification as to S/S implementation, and garbage filed as a Robocall Mitigation Plan. Those providers are presumably on thin ice, as the FCC has recently revised their own rules to make it easier for them to delist such filings from the RMD.