SHAKEN implementations are evolving
We’re seeing a shift in the way SHAKEN implementations are being certified with the FCC. The numbers raise questions about what’s really going on in the SHAKEN ecosystem. Let’s have a look.
Busy seasons for SHAKEN
Robocall mitigation certification filings in the Robocall Mitigation Database (RMD) came in two waves, peaking at the certification filing deadline on June 30 and again with the September 28 effective date for refusing calls directly from unregistered providers.
The different colors in the stacked bars represent the types of certifications filed in each week. The stacked bars illustrate the total number of filings for the week.
Evolution of SHAKEN implementation types
Notice that there’s a difference in the proportions of implementation types leading up to the June 30 filing deadline versus the filings just before the deadline to refuse calls from unregistered providers. In June, there were more Partial SHAKEN filings (gray bars) than Complete SHAKEN filings (orange bars). In September, there were more Complete SHAKEN filings and fewer Partial SHAKEN filings.
We can see this reversal clearly in this illustration of cumulative filings by implementation type.
At the June 30 filing deadline, Partial SHAKEN implementations outnumbered Complete SHAKEN implementations by more than 2-1. Both grew slowly during July and August.
Around September 18, Complete SHAKEN filings took off like a rocket, with the largest increase taking place the week ending October 2.
Authorized SHAKEN service providers
Let’s compare the explosive growth of Complete SHAKEN implementations to the number of service providers authorized to use SHAKEN by the Policy Administrator (STI-PA).
Hmm. Not so much growth here. Not very many SHAKEN-authorized providers, either.
We’ve noticed before the disconnect between the number of SHAKEN implementations claimed in the RMD versus the number of SHAKEN-authorized service partners. Here it is again, and it’s big.
- On July 3, there were 1,122 SHAKEN implementations, Complete or Partial, in the RMD.
- There were 295 SHAKEN-authorized service providers.
- On October 9, there were 2,853 SHAKEN implementations in the RMD, an increase of 1,731.
- There were 378 SHAKEN-authorized service providers, an increase of 83.
To be fair, some of the difference between the RMD and the STI-PA lists is because the list of SHAKEN-authorized service providers is summarized by parent companies, while RMD certifications are sometimes filed by separate subsidiary companies.
However, that explanation doesn’t begin to explain the difference we see here. Looking through the RMD SHAKEN filings, it seems unlikely that many of these businesses are subsidiaries of SHAKEN-authorized service providers on the STI-PA list.
It seems that many of these businesses have claimed a SHAKEN implementation without having been approved to do SHAKEN.
Will these RMD filings be satisfactory? Is anyone checking? Or will filings only be examined during traceback or enforcement?
It will be interesting to follow this.
Follow the RMD
In case you missed it, the FCC issued a public notice to remind providers of the September 28 blocking deadline.
In this notice, they also announced an RMD updates email list. You must have login credentials on the RMD portal to subscribe.
After logging in, on the personal welcome page, there’s a place to subscribe to weekly updates. Sign up, and you’ll receive an email every Tuesday at 11:00 a.m. ET that lists changes to the RMD over the preceding 7 days.
The Commission is providing this as a way to ease compliance with the requirement to make sure that providers from whom you receive calls directly are in the RMD.
We provide an STI-CPS, the TransNexus CPS, which is available to any SHAKEN-authorized service provider free of charge. It’s part of the national network of STI-CPSs.
We can also provide a private STI-CPS, either hosted or on-premises, to service providers.
Contact us today to learn more.
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