Update on STIR/SHAKEN guidelines
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! MARY LOU CAREY BackUP Telecom Consulting Office: 615-791-9969 Cell: 615-796-1111
This was very helpful and confirms I am not the only one scratching my head at this requirement. I am current stuck in the registration process because our OCN is listed as a ?VoIP Provider? and iConectiv is wanting to verify our *VoIP Numbering Resource Authorization *with the FCC. Have you heard of any changes to this part of the process, it seems like a lot of hoops and wasted time/resources for something we will never utilize (regarding direct access to numbering resources). - Chris On Tue, Sep 29, 2020 at 2:29 PM Mary Lou Carey <marylou at backuptelecom.com> wrote:
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!
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
The actual fix has not been announced as far as I know. What I was able to find out is that the goal is for every company to have their own certificate/token and for the FCC to provide an alternative method of certification/waiver so every company that needs a certificate can get one. I believe everyone will have to apply for a certification or waiver either way so my recommendation for the companies that don't want their own NXXs is to submit the FCC Numbering Authorization application with their existing DID provider agreement instead of a PSTN connection agreement. Then explain in the section that covers your business model and area of service that you are ONLY applying to receive a STIR/SHAKEN certificate. That way the FCC can figure out which type of certification / waiver /etc you should be given. If they decide to create a new type of certification with a different docket number, then may have to modify your documents and submit everything under the new docket number but I don't foresee the basic requirements being much different either way. I do help companies get set up to be an Interconnected VOIP provider and/or qualify for a STIR/SHAKEN certificate. I also help with the NXX ordering / Number Porting set-up and training / AOCN services but I do not handle the Certificate Authority. I refer that out to companies like TransNexus. I've been so inundated with new clients lately that I've had to hire someone to help me with the FCC Numbering Authorizations. I'm sure every other consultant that does this type of work is seeing the same thing so my suggestion to every carrier is to get the process started as soon as they can. It can take anywhere from 3-6 months to get your FCC Certificate depending on what you have in place already. MARY LOU CAREY BackUP Telecom Consulting Office: 615-791-9969 Cell: 615-796-1111 On 2020-10-09 07:11 AM, Chris Wallace wrote:
This was very helpful and confirms I am not the only one scratching my head at this requirement. I am current stuck in the registration process because our OCN is listed as a ?VoIP Provider? and iConectiv is wanting to verify our _VoIP Numbering Resource Authorization _with the FCC.
Have you heard of any changes to this part of the process, it seems like a lot of hoops and wasted time/resources for something we will never utilize (regarding direct access to numbering resources).
- Chris
On Tue, Sep 29, 2020 at 2:29 PM Mary Lou Carey <marylou at backuptelecom.com> wrote:
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!
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
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