TIPS Robocall Mitigation Database

[ariban]

I registered my company with the FCC and i have a FCC Registration Number (FRN)
however, it says No STIR/SHAKEN Implementation - Performing Robocall Mitigation
my sip trunk provider said i might be cut off by the FCC soon. however, we hardly make any calls at all. we receive calls from customers etc... but outgoing calls are about 50 calls per month if that!
is there something i need to do within incrediblepbx to implement this?

 

[Samot]

I registered my company with the FCC and i have a FCC Registration Number (FRN)
however, it says No STIR/SHAKEN Implementation - Performing Robocall Mitigation
my sip trunk provider said i might be cut off by the FCC soon. however, we hardly make any calls at all. we receive calls from customers etc... but outgoing calls are about 50 calls per month if that!
is there something i need to do within incrediblepbx to implement this?

This isn't an Incredible PBX problem. Are you an actual provider? If so, you need to implement STIR/SHAKEN on **your** network. This means you need a token and certificate and need to do STIR/SHAKEN registration. Then you need to sign your outgoing calls with proper attestation and your cert.

 

[Tonyclewis]

I think first we have to establish if you are a Voice Provider. The FCC has been pretty clear a Voice Provider is anyone who takes voice services and resells or bundles it into an offering and invoices an end user for services.

 

[LitleBill]

we receive calls from customers etc... but outgoing calls are about 50 calls per month if that!

Is this message from around March 2023?
Just from the information you posted you are not a reseller right? You should also make sure your calls are not labeled as SPAM. otherwise you would have to work this out with the people your company calls, and beg them not to do that.

Check your CNAM as well, caller ID sometimes causes businesses getting blacklisted when mistaken for spoofing.

You can post or DM who is your SIP provider but I believe your SIP provider already implements STIR/SHAKEN

 

[ariban]

ya not a proovider or reseller, but they asked me to sign up. i spoke with the FCC and they told me to simply delete the entry and that solves it. thank you

 

[LitleBill]

Who is your trunk provider? If you don't mind me asking.

 

[ariban]

IDT, its super cheap, i had someone set me up about 15 years ago. i get crazy cheap prices. non monthly fees or DID, no channel restrictions, charge is $0.005 per min in and out.
but i think they set me up as a reseller account even though i dont resell anything and just have crazy cheap prices.

 

[LitleBill]

IDT, its super cheap, i had someone set me up about 15 years ago. i get crazy cheap prices. non monthly fees or DID, no channel restrictions, charge is $0.005 per min in and out.
but i think they set me up as a reseller account even though i dont resell anything and just have crazy cheap prices.

that sounds like a deal. Maybe they are like voip.ms offering reseller accounts to anyone, Their reseller prices are the same prices though.

is it idtexpress.com or idt.net

 

[ariban]

idt.net
however, i still dont know how i got this account lol. this was 15 years ago, a friend of a friend knew someone there who no longer works there and he set up this account for me. years later the new rep said if i dont spend a few hundred a month they will cancel it, but that never happened lol!

 

[Samot]

idt.net
however, i still dont know how i got this account lol. this was 15 years ago, a friend of a friend knew someone there who no longer works there and he set up this account for me. years later the new rep said if i dont spend a few hundred a month they will cancel it, but that never happened lol!

Yeah, I was going to ask about the usage since IDT stopped US-US traffic for about a year because they had to deal with Kari's Law and STIR/SHAKEN.

 

[ariban]

i havent had an issue no us to us traffic is working great!

 

[Samot]

i havent had an issue no us to us traffic is working great!

It was a few years back this happened. It's been fine now for some time.

 

[KNERD]

This isn't an Incredible PBX problem. Are you an actual provider? If so, you need to implement STIR/SHAKEN on **your** network. This means you need a token and certificate and need to do STIR/SHAKEN registration. Then you need to sign your outgoing calls with proper attestation and your cert.

Looks like that is not completely true

Correcting Misinformation: FCC’s “Third Party Rule” Does Not Apply to All VSPs and Compliance Deadline Is Not June 20, 2025 | The CommLaw Group

A lot of misinformation has been disseminated over the past few months about the “Third Party Rule,” mainly concerning which VSPs are subject to the Rule and the effective date of same.

commlawgroup.com

Despite this, some upstream providers have misled their downstream, exempt VSP partners, insisting that they must implement full STIR/SHAKEN compliance and threatening to withhold A-level attestation unless those demands are met. These upstream providers are misapplying the FCC’s rule and attempting to enforce their own internal policies that go beyond what the law requires.

The rule applies only to VSPs that are currently subject to STIR/SHAKEN compliance requirements. This includes facilities-based providers that have control over their SIP signaling and can technically implement STIR/SHAKEN on their networks.

VSPs that are exempt from STIR/SHAKEN—for example, those that lack control over the network infrastructure necessary to sign their own calls—remain exempt from the Third-Party Rule’s requirements. These VSPs are not required to sign their own calls and do not need to obtain SPC tokens or certificates.

 

[ariban]

interesting, i will talk with IDT and this law firm, maybe there is something i can do more.
for now they raised me from level c to b as i am just the third party and cant implement stir shaken
thank you for the post.

 

[Samot]

interesting, i will talk with IDT and this law firm, maybe there is something i can do more.
for now they raised me from level c to b as i am just the third party and cant implement stir shaken
thank you for the post.

How are you just the third party? That plays into this. Plus being exempt from STIR/SHAKEN doesn't exempt you from the RMD or other requirements.

 

[ariban]

i mean i am the end user. i dont resell their services, i dont have the ability to implement stir shaken (IDT does that for us)
i signed up and registered for RMD, then they fined me for not implementing Stir Shaken, so they emailed me if i am the end user i dont need to be in the RMD database and guided me how to remove my filing and removed the fine.

 

[Samot]

i mean i am the end user. i dont resell their services, i dont have the ability to implement stir shaken (IDT does that for us)
i signed up and registered for RMD, then they fined me for not implementing Stir Shaken, so they emailed me if i am the end user i dont need to be in the RMD database and guided me how to remove my filing and removed the fine.

So what more can IDT or this law firm do? If IDT is signing your calls then you're already all set.

 

[ariban]

IDT only set me up to Level B (i was on Level C) and everyone was getting spam likely. after arguing they raised me to Level B. but they said they cant raise me to Level A unless i stop forwarding calls to my cell when we dont answer. or i dont forward the caller ID of the incoming call when the call forwards to my cell. they said they can only raise me to Level A when all caller ID are from IDT and not third parties.

 

[Samot]

IDT only set me up to Level B (i was on Level C) and everyone was getting spam likely. after arguing they raised me to Level B. but they said they cant raise me to Level A unless i stop forwarding calls to my cell when we dont answer. or i dont forward the caller ID of the incoming call when the call forwards to my cell. they said they can only raise me to Level A when all caller ID are from IDT and not third parties.

That is 100% accurate. They are following how STIR/SHAKEN should be done.

 

[Samot]

Looks like that is not completely true

Let's cover what that article is talking about, it is talking about *exempt* VSP's. That means they have an exemption on file with the RMD.

In order to be exempt the VSP must tick off certain checkboxes. The VSP must, in detail, outline why they are exempt from STIR/SHAKEN within their RMD certification filing. If the RMD filing is incomplete or doesn't outline exemption for STIR/SHAKEN, then they are not exempt. Keep in mind that all RMD entries are audited and reviewed by the FCC on a regular basis. A review could nullify your exemption. Additionally, any other provider in the RMD or STIR/SHAKEN ecosystem can challenge an exemption in the RMD. VSPs must now also renew their RMD certification/filing *every year* moving forward. 2025 was the first year we all had to re-file, even with no changes, because now all certification gets renewed yearly.

And no, just having a bunch of PBX systems that trunk directly to an upstream isn't automatic exemption. The point of origination to the PSTN is a factor and it is based on the end user's perspective.

Example 1:
You sell a PBX (cloud) to an end user and also resell BulkVS to them. If the end user has complete control over the PBX (even if you're managing it) and can make routing changes, add trunks, etc. then the point of origination is BulkVS and as the reseller you are could be exempt from STIR/SHAKEN (not the rest of the stuff like RMD, filing with the FCC, etc).

Example 2:
You sell voice services to the end users, reselling BulkVS. You install a PBX per end user and the end user has no control over the PBX. They do not have choices in how the calls route to and from the PSTN. In some cases the end user doesn't even know they have a stand alone PBX just they are getting services from you. At this point the point of origination isn't BulkVS (or any of your upstreams), its you. The end user must rely on you for their connection to the PSTN. At this point you are no longer exempt from STIR/SHAKEN requirements.

So just connecting a bunch of PBXes to an upstream like BulkVS, IDT or Flowroute doesn't mean automatic STIR/SHAKEN exemption. As well, if your upstreams are trying to force the Third-Party rule on you but you have a legitimate STIR/SHAKEN exemption filed in the RMD. You just point to the RMD and your exemption, which they could see and verify since the RMD is public.