Yeah the more I dig the more this looks to be the case.
I don’t think so. However, assuming you are using a version of Asterisk that supports pjsip, my understanding is that it is possible to configure both pjsip and chan_sip simultaneously. Therefore, you should be able to configure an endpoint to the STI-AS using pjsip that hairpins (302 Contact URI = Asterisk) the embedded Identity header and then leave your other endpoints on chan_sip. But we have not tested this. We have focused on Asterisk 18 with pjsip.
This topic sounds like we either need a #OSSLounge or have a Twitter Space discussion, so everyone understands this and can get questions answered.
Correction to my previous message: the described approach does work and we have tested this, I was just not aware.
Just got a email from Inteliquent today stating that all service providers must start signing their own calls with their own tokens Effective May 16th. So more and more carriers are now requiring all resellers to get their own tokens and sign their calls with that token. This is not just a VoIP Innovations requirement that others seem to think. The reason the service providers are pushing on this is if they use their own token to sign the reseller calls and it turns out the calls they are signing are not legit the Service Providers token can be revoked and they would not be able to sign any calls for anyone so the risk is just to great anymore.
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Honestly, this isn’t something that is solved in a community discussion. I really hope that people don’t miss the forest for the trees here with this. By that I mean, people are told they need to sign their own calls. In order to do that you need to be a 499 filer, have an OCN assigned and get a token to sign calls. As I have pointed out, and we are all well aware of, there are many that never even did the basics of becoming a 499 filer when they decided to sell VoIP.
Once people become 499 filers it will change how they do business. They must now pay the FCC directly and report to the FCC every quarter/annually on their usage. More importantly, they should be giving their FRN to their upstreams so they stop charging Federal taxes/fees. Then they need to start passing the taxes/fees on to their end users so they can remit it to the FCC. They should also be registered with the each states PUC they are selling services in along with be a tax authority in said state. The one thing to keep in mind here is that there are quite a few taxes/fees that 499 filers cannot pass on to the end users, meaning you have to still pay them on your own.
Also, the taxes/fees change on a regular basis. The FCC taxes/fees are assessed every quarter and could be lowered or raised depending on the quarter. State/local can change as well, perhaps even more frequently that quarterly. As well as different types of services are taxed differently. A SIP Trunk is not taxed the same as a full voice line, Fax lines are not taxed the same, DIDs, etc. they all have different tax levels and codes depending on your status. There are going to be ongoing costs to doing this. Keeping yourself in compliance with taxes and regulations is not cheap.
Taking actions to sign your own calls puts you in a position that makes you responsible for way more than just signing calls. Everyone needs to be aware of that and how it can impact their business. I mean this is a lot of work and responsibility for someone that has a dozen PBX systems connected to VI. Individuals need to make this determination. Cases like an MSP that doesn’t actively market or sell VoIP to consumers but can “throw it in” if the end user asks “Can you do VoIP too?” may not be the right fit for this. They may be better suited to get into a sales partner program where they get a cut/commission while the end user has a direct relationship with the provider.
Those who are doing flat rates because they weren’t charging taxes, how will they handle that now? Will the taxes now be inclusive of the price (which will hit the profit margin hard) or will they move to exclusive taxes so now that flat $19.99 is $19.99+tax meaning the customer could see invoices with up to 50% increase because the taxes/fees added another $10-$12 in costs to them.
There is a lot of administrative and regulatory baggage that comes with the decision of “Yeah, I’ll just do the things needed to sign my own calls”. It increases your responsibility and what you can and cannot do. It increases your admin side of work. It requires you to do more things to keep track of your traffic and usage.
I mean, something as simple as 7-digit dialing and 988. You can go through this forum and see posts on how people are still prefixing area codes in outbound routes so users can dial 7 digits. That’s all fine and dandy when you are just a PBX admin but as a provider the FCC mandates that 7 digit dialing must be rejected. Now if you are the PBX admin, the provider and do everything at the PBX level (like some have said they do) that means the PBX must reject 7 digits being dialed from the users because that is the only place you, as the provider, can block it. It is these little things I am worried many are going to glance over.
Oh if you also do the work to be a 499 filer and get an OCN but have also dragged your feet on proper E911 updates on your systems…get busy fixing that too because now you’re not just a PBX admin screwing up 911. You’re a provider screwing up 911.
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You are right about all of this but it seems as though VoIP providers have had some responsibility to make some things more clear to MSPs or small VoIP shops before just turning on services.
With VI you take a look at their home page, say “looks easy enough” and submit a form. Someone reaches out and you get an account. How did all these small voip providers get accounts with VI without following proper procedure? VI up to this point could have said “not our problem if the customer doesn’t comply” but now it is everyone’s problem.
Other places like Telnyx you don’t even need to tell them what you are doing, just sign up for an account and put a few dollars in and you can be a VoIP provider too. Why aren’t the providers putting this information out up front like you have been doing for the community?
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To add to this, Vitelity (not Inteliquent) in particular is maintaining that they will continue to sign calls for their customers. This includes their wholesale customers. This is obviously very misleading to those of us who understand the new regulations as requiring basically everyone to become a 499 filer and get an OCN.
Or maybe I am continuing to misunderstand the requirements of complete STIR/SHAKEN implementation.
Some of the conveniently left out stuff is bait and switch. Places like VI do have add-ons to handle some of the administrative overhead but by the time you pay the fees etc for those you will probably be losing money as a “provider”
Well technically everyone who resells VOIP is suppose to already be a 499 Filer. I know I keep hammering this but people seem to keep overlooking this part. This whole I need to sign calls all of sudden has truly brought to light that most people who are reselling VoIP to their customers are not setup as a 499 filer and already violating the law and things will only become harder for them.
My comment only tangentially has to do with being a 499 filer. Yes everyone should already have been filing their 499, de minimis or not. What I still haven’t gotten a clear answer is, even after speaking to multiple attorneys, whether or not I actually need to sign my own calls or if a carrier can do it for me. VI says I need complete STIR/SHAKEN implementation by June 30th. Vitelity says I’m fine without signing my own calls because they will do it for me.
With the government it is always best to CYA. I would err on the side of doing too much rather than too little. The guys with the “authority” like to build their budget and don’t care what some random sales dude says
Well that answer is really up to the carrier you work with. Some are saying they will sign for you and others say they will not. It is a risk tolerance for the carrier. For sure you can not use the fact that a carrier is signing your calls to answer to the Robocalling Database that you are signing all calls as you are not you are relying on someone else.
But that is also true for the 302 redirect method. The company sending the redirect is actually doing the signing. As I suggested, this might be considered an agency arrangement, but you would need to check that with your lawyer.
No using the 302 redirect service is not the same as some other carrier signing your calls. The 302 redirect is signing the call with your token. It does not matter what application system you use to sign the call if the call is signed with your own Token which is what the service above does.
Not necessarily an answer to how to solve it for all providers but it seems like Twilio has it setup so that they sign the calls for you.
Seems like they enable you to setup sub accounts for each client that you are reselling services to, which then allows you to provide the client’s information to assign to specific outbound numbers that the client uses which then enables them to sign those calls with their token.
If I am understanding the high level description correctly.
Hey Tom,
I’ve followed this discussion with concern. Have you been able to follow up with Bandwidth?
Did you get a definitive answer?
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