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-boun...@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@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
mgra...@mstvp.com
o: (713) 861-4005
c: (713) 201-1262
sip:mgra...@mjg.onsip.com

-----Original Message-----
From: VoiceOps <voiceops-boun...@voiceops.org> On Behalf Of Mary Lou
Carey via VoiceOps
Sent: Wednesday, May 31, 2023 2:46 PM
To: Alex Balashov <abalas...@evaristesys.com>
Cc: voiceops@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@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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