Apply for an OCN and Seek FCC Waiver of Telephone Numbering Rules Now!
The CommLaw Group Offers VoIP Providers a “STIR/SHAKEN Compliance Preparation Bundle” for U.S. $5,000 Fixed Fee
Marashlian & Donahue, PLLC, The CommLaw Group has responded to the business need for Interconnected VoIP providers (and One-Way VoIP providers) to participate in the STIR/SHAKEN call authentication process by offering to prepare and file two applications/filings, one with NECA (the National Exchange Carriers Association) and a second with the Federal Communications Commission (“FCC”), as currently required by the non-governmental body responsible for administering the STIR/SHAKEN robocall mitigation regime. The two applications/filing are:
Operating Company Number (“OCN”) Application (through NECA); and
Petition for Waiver of the Direct Telephone Numbering Access Rules (filed with the FCC)
All IP-based voice service providers serving more than 100,000 lines on a holding company basis must implement the STIR/SHAKEN call authentication framework by June 30, 2021. Smaller operators have an extra year. In order to implement STIR/SHAKEN, a voice provider must obtain a “certificate” from a designated authority. The certificate allows the provider to authenticate the calling number as valid. Only those providers that have an Operating Company Number (“OCN”) and direct access to telephone numbers can obtain such certificates (they must also file USF 499 forms).
Since many VoIP providers use CLEC partners to obtain their telephone numbers (e.g., through purchase of DIDs), they do not qualify for certificates under current requirements/rules. Therefore, such VoIP providers will be unable to authenticate their own calls, which could result in their call traffic being blocked by terminating carriers that have implemented STIR/SHAKEN protocols in their switches. This presents a material risk to VoIP providers, as the consequence of having otherwise legitimate and lawful traffic blocked at the PSTN-termination end of the call could be devastating.
Under today’s rules and policies (which may change), a VoIP provider seeking to become “certificated” and thereby authorized to authenticate their own calls must do several things. First and foremost, it must offer interconnected VoIP services, not merely One-Way VoIP, but two-way, PSTN interconnected VoIP is required. Second, it must have a Filer ID issued by USAC, the Universal Service Fund administrator. Once these basic pre-requisites are fulfilled, the interconnected VoIP service provider must:
1) Obtain an OCN from NECA. In order to obtain an OCN from the National Exchange Carrier Association (“NECA”), an interconnected VoIP provider, which is not also a licensed CLEC in at least one state, must file an OCN application as an Internet Protocol Enabled Services a/k/a “IPES.” They must also demonstrate “proof of service and customers, e.g., interconnection agreement (or evidence of an interconnection order pursuant to an approved tariff) and contractual agreements with end-user customers. Or, regulatory administration approval, if applicable”; and
2) Obtain numbering authority from the FCC. Unless an interconnected VoIP provider is licensed as a CLEC in at least one jurisdiction, it must seek FCC authorization to obtain direct access to telephone numbering resources from NANPA (the North American Numbering Plan administrator). Essentially, a provider must have obtained an OCN and demonstrate that it is currently capable of providing interconnected VoIP service. To demonstrate readiness to provide service, the VoIP provider must demonstrate proof of facilities readiness by:
(a) providing a combination of an agreement between the interconnected VoIP provider and its carrier partner and an interconnection agreement between that carrier and the relevant local exchange carrier (LEC),or
(b) proof that the interconnected VoIP provider obtains interconnection with the PSTN pursuant to a tariffed offering or a commercial arrangement (such as a TDM-to-IP or a VoIP interconnection agreement) that provides access to the PSTN. The interconnected VoIP provider need not demonstrate that the point where it delivers traffic to or accepts traffic from the PSTN is in any particular geographic location so long as it demonstrates that it is ready to provide interconnected VoIP service, which is by definition service that “[p]ermits users generally to receive calls that originate on the public switched telephone network and to terminate calls to the public switched telephone network.”
(The FCC has historically granted these applications in approximately three to four (3 or 4) months).
The CommLaw Group will work with Interconnected VoIP providers to prepare and file both the NECA OCN application and the FCC Waiver Petition seeking direct access to telephone numbers for a fixed U.S. $5,000 fee (subject to the provider delivering all required information and documents in a timely manner). Our fee includes any email or telephone communications with the NECA or FCC staff. Additional fees may apply to One-Way VoIP service providers in need of guidance and/or assistance qualifying as an interconnected VoIP provider.