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Stir/Shaken 201


Breanna Fernie

Stir Shaken

New FCC Requirements Creating Quite a STIR for Telecom Providers, Leaving Many SHAKEN.

There has been lots of buzz in the United States telecom industry around the smackdown of robocalls by the FCC. We have been receiving lots of calls from Partners, Service Providers, and Resellers feeling very confused and looking for advice and guidance. Recently, our CEO, Tony Lewis, teamed up with Chris Sherwood of Crosstalk, in a produced video on Youtube discussing the challenges that come with these new rules and requirements. Based on the number of views and feedback, a discussion followed with Tony to clarify further. See the links below to watch:

As the FCC attempts to reduce the number of robocalls in the US, many small telecom providers are understandably concerned. Our most recent short video addresses the top six questions our Partners are asking about. While Tony answered those questions, there was not enough time to go over all of the necessary information. So I thought I’d put together this second blog to expand on the STIR/SHAKEN 101 Blog and place all of the links and info you need in one place.


CrossTalk ‘STIR/SHAKEN and the Death of the Small VoIP Carrier’

Chris Sherwood on STIR SHAKEN
Tony Lewis on STIR SHAKEN


ClearlyIP ‘STIR/SHAKEN Clarification’

Mike Dunham
Tony Lewis


How ClearlyIP Adheres to STIR/SHAKEN

ClearlyIP has our own Certificate, and we sign all of our calls with an A, B, or C classification depending on how calls are being placed to us. Most calls get signed with an A or B depending on the caller ID and what we can attest to on a call. Not many are signed with ‘C’ as ClearlyIP is not a heavily relied upon International Intermediate Provider.

Our Attestation service is a free service that assists businesses to find out what their carrier is signing their calls. If you want to verify your business number and what your carrier is signing you can call from that number to our free testing number and it will read out to you what is being received.

ClearlyIP’s STIR/SHAKEN Attestation Test Number

Call: 920-666-1392

It is important to note that ClearlyIP is not an expert in STIR/SHAKEN but we do try and provide valuable guidance and instructions for our Partners. The first question to ask yourself is if you qualify as an ‘Originating Service Provider’?


Are You an Originating Service Provider?

There is no responsibility for a customer. Customers can not sign their own calls, they are all dependent on the originating service provider. Customers, however, do need to use a service provider who is doing STIR/SHAKEN.

YES – If a Reseller is charging a customer for Voice Services. Eg. SIP Trunking, UCaaS, HostedPBX billing for seats/users which include minutes or usage for users. The Reseller must therefore sign customer calls with their own certificate to be STIR/SHAKEN compliant.

NO – if the Reseller is not charging a customer for Voice Services OR if the reseller is receiving commission for voice calls in a ‘Agent’ model.

YES – if a Provider is an Originating Service Provider. Whoever is originating a call onto the network working with the end customer is responsible for signing the call.


So, if you ARE a Reseller or a Provider that does qualify as a ‘Originating Service Provider’, the next question is, did you receive an FCC Extension to implement STIR/SHAKEN Call Authentication?

The bottom line is that all Originating Service Providers must document what actions they’ve taken in the FCC’s Robocall Mitigation Database (RMDB) or face the consequences. If you are non-compliant, as of September 28, 2021, other carriers were prohibited from accepting your calls.


Request an FCC Extension to Implement STIR/SHAKEN

We’ve broken it down for you here in our Quick Reference Extension Guide.

View Guide



ClearlyIP Partner Originating Service Provider Steps

If you have qualified as an Originating Service Provider, let’s say you are reselling ClearlyIP’s Sip Trunking to customers and charging the end customer, technically, you will be required to sign those calls. You must go thru the process of getting your own certificate. You will need to get a US FCC 499-A Filer and OCN Number, the work towards your STIR/SHAKEN token and certificate.




Obtain a FCC 499 ID Number



Get an Operating Company Number (OCN) Number

An OCN (Operating Company Number) is a 4 character ID for North American phone companies.



Get your iconectiv Token



Partner with a Certificate Authority (CA) to get a Certificate Issued


Start Signing Calls.

*Must have an SBC in place or use someway through a PBX to sign calls. ClearlyIP is presently working on a new service to host Resellers Certificates.


Future ClearlyIP Solutions

Engineering is working on a new service for our Partners/Resellers who have their Certificates. Partners will be able to provide us with their Certificate, and we will then sign all of their calls from their Customers (that belong to the Partner) with their own Certificate. This will be announced in the coming weeks.

Cost to Be Compliant?

We get asked by our Partners what the overall expense is to become STIR/SHAKEN compliant. But the more important question they should be asking is, what are the ongoing costs? The scariest piece of this is not the STIR/SHAKEN compliance initial process and expense, but it is the ongoing expense and the tax compliance. Providers that are now 499 Filers will be required to meet nationwide telecom tax compliance for the various regions and areas, which is beyond complex and time-consuming. Most Providers will require a 3rd party Billing and Tax Compliance to assist them to collect and remit.

Year 1

A Provider should be expecting to spend a significant amount of time and expense, approximately $4-5k in costs to become STIR/SHAKEN Compliant.
There is also potential for a telecom back tax audit, these costs are impossible to forecast.

Year 2 & Beyond

Following years will be approximately $2-3k/mo for tax collecting and remittance and compliance. Then another $300+/mo to maintain your STIR/SHAKEN compliancy. Expect a budget of $30k annually minimum.

Plan B?

Look at our Agent Program- if you are an Originating Service Provider and decide you don’t want the hassle of going through the complicated process and significant expense of being STIR/SHAKEN compliant nor the ongoing headaches with tax compliancy. This is a great option we support Partner’s voice business to be transitioned to our ‘Agent’ model where ClearlyIP takes over the responsibility of signing the calls with our certificate and now billing the end customer directly, and the Partner moves to an Agent model. This provides a solution where ClearlyIP does all the heavy lifting and the Partner collects the commission check.

This is the direction Chris Sherwood of Crosstalk took and speaks about in his video. His customers remain in a relationship with Crosstalk for the PBX but on the voice services, the responsibility is with ClearlyIP.

ClearlyIP will work with the customer to get all the billing information, so rather than ClearlyIP billing the Partner, they simply move to bill the Customer direct. ClearlyIP will take care of all the hard work….all the taxation, the STIR/SHAKEN compliance, and offer a monthly commission evergreen on the customer voice business. We will honor the customer rates. The benefit here is that a customer is being handled properly and compliant.