I just ported over a couple of accounts to Telnyx. I then got a generic announcement from them that:
Dear customer,
You may be required to register in the FCC’s Robocall Mitigation Database (RMD) by September 28.
I tried to wade through the included information and links provided in the email but still am unclear whether or not these regulations would apply to my situation. I essentially run a handful of FreePBX instances on behalf of my clients. From what I read, it sounds like I would be considered a provider and need to (somehow…) register in the database.
Can anyone provide clarification and what is being required and whether or not someone such as myself needs to take any action?
This is the downside of signing up with a wholesale provider. They are now going to treat you as such which means you have to comply with all FCC rulings. This has been happening to a lot of people with providers like Telnyx, BulkVS and even VoIP Innovations. They can and should be blocking anyone originating through/from their network that doesn’t have proper RoboCall Mitigation.
Now the fact many of these places allow you to connect directly on their platforms, I’m pretty sure that filing with the lowest level will still suffice but I’m guessing this is something you’re going to have to do if you are going to use these types of providers.
They are cracking down on VoIP and if you present yourself as a VoIP provider, i.e. “sign up with me and pay me for your voice services”, then you need to do what the rest of us have to do.
Coincidentally these are the guys who ‘rode out the storm’, if you don’t consider yourself as a provider, you can just claim ‘section a’ , that should get you through the next few months. . .
If you seriously want to help and mitigate the problem, then you can do that also by adding valid ‘certified headers’ to your calls
You can only claim section A if your calls are actually being signed in some manner. You just randomly can’t pick it.
Again, how will they do that? You have to be an OCN and active with the FCC even before you get the tokens needed to sign your own calls.
Also, the RoboCalling Mitigation Database is an additional thing if you don’t sign your own calls. Upstreams can start blocking those not in the RMD legally now.
Generally i have found that after complying with the robocall registration and so informing the carrier, they will sign your calls with A if both DID and route belongs to them, depending on the carrier you might get a B if using a ‘third party’ DID if they trust you, there is a need for the carriers to form a ‘federation of trust’ to make this work better . ,
That is STIR/SHAKEN and was being done before the RMD population. The RMD happens before that. So Bandwidth is my ULC and they can block my calls if I wasn’t in the RMD. So no STIR/SHAKEN will happen, call is rejected before even being concerned about the presented callerid
Well this sounds like way more than I bargained for. I just moved 3 clients from VOIP.ms to Telynix because of the ongoing service issues. I picked Telynix just because they were the easiest to setup and get a working SIP connection. I had no idea there would by any of these sorts of complications.
Can you shed any light on the actual application process? I got as far as the FCC site and then got lost in the details.
Wondering now if I should try and port back to voip.ms since they seem to be stabilizing. Not sure how frequently numbers can be ported.
Although I agree with that, it is only a stop gap measure.
Long term the carriers need to ‘federate’.
With some effort both technically and paperworky things , you could add your own certs in the headers, which if the certs are veritably good and your carrier accepts and passes them and get an A (but likely you will need to move to TCP/TLS)
I mean becoming an Operating Carrier is both technical and paperworky things. So if you want to sign your own calls there is already a laid out method to do so.
What does that mean? As an Operating Carrier you would either have your own direct peering with other OCs or a transit carrier who does and will pass your STIR/SHAKEN details through.
Just an observation that even the biggest peer carriers seem to be dropping like ten-pins lately. Presumably one routes around broken peers , best have lots of them lined up.
I will note, that over the last couple of weeks, although we have very few failed calls Our MOS scores are slowly decreasing, we rarely saw < 4.8 , we now see < 4.6 commonly.
