Accelerated SHAKEN deadline effective date set
The FCC Fourth Order on SHAKEN was published in the Federal Register on Tuesday, January 25, 2022. This sets its effective date 30 days later, on Thursday, February 24, 2022, which is important for other deadlines. Let’s have a look.
New rules in the Fourth Order
- The SHAKEN deadline is moved forward to Thursday, June 30, 2022, for non-facilities-based small voice service providers.
- A voice service provider is non-facilities-based if it offers voice service to end-users solely using connections that are not sold by the provider or its affiliates.
- Any small voice service provider that fails to mitigate illegal robocalls after notification by the Enforcement Bureau will be required to implement SHAKEN within 90 days.
The order states that a “voice service provider readily knows whether it is offering voice service that relies on its own (or its affiliates’) facilities or not, and therefore can easily determine whether it is subject to this definition.”
In addition, the order explains that FCC Form 477 data can help determine whether a provider may be non-facilities-based, but is not as an automatic trigger for a shortened extension. This is because interconnected VoIP service providers are required to indicate on Form 477 the following:
- The number of interconnected VoIP service subscriptions sold bundled with a transmission service
- Voice service not bundled for sale with a transmission service.
However, Form 477 filings are not a perfect indicator that a provider is subject to the rule. For example, one-way interconnected VoIP providers are not required to file FCC Form 477, but they are subject to the Fourth Order rules.
Robocall Mitigation certification filing requirements
The Fourth Order doesn’t change the filing requirements for the Robocall Mitigation Database (RMD). The rules currently in place require providers subject to the new rules to update their certification filings as follows:
- Within 10 business days of the effective date of this order, providers must disclose in their filing that they are subject to a shortened extension.
- The effective date is February 24, 2022, so this filing update is due Thursday, March 10, 2022.
- Within 10 business days of implementing SHAKEN, providers must update their filing to indicate their SHAKEN implementation.
The Fourth Order directs the Wireline Competition Bureau to send the following written notices to small voice service providers in the RMD that did not update their filing if their FCC 477 filing indicates they might be non-facilities based or that did not file a 477.
These notices will ask these providers to explain why they did not update their filing and appear to be out of compliance. Providers found to be out of compliance will be referred to the Enforcement Bureau.
Those are the main highlights that small voice service providers relying on the small provider extension need to know about. We encourage you to review the full order listed in the Federal Register for all the details.
We provide an STI-CPS, the TransNexus CPS, which is available to any SHAKEN-authorized service provider free of charge. 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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