Burden of Proof


government mandate for VoIP providers to use third-party verification for confirming orders or even E911 notifications. Yet, an increasing number of VoIP providers are using these services and, with recent FCC action foreshadowing increased regulation of VoIP players, experts say the numbers are likely to grow.

It is our position that as VoIP continues to become more of a mainstream product, the FCC will continue to step in and apply more of the standard telecom rules, including consumer protection and thirdparty verification, says David Brinkman, CEO of 3PV – Third Party Verification Inc.

In fact, the FCC already is starting down this path. In late June, the agency determined that providers of interconnected VoIP services are providers of interstate telecommunications and, therefore, must contribute to Universal Service Fund. The ruling also requires interconnected VoIP providers to register with the FCC as providers of domestic, interstate services. Previously, the FCC extended Communications Assistance for Law Enforcement Act (CALEA) obligations and E911 requirements to VoIP providers.

Indeed, the rulings are beginning to build on one another. In mid- August, for example, The Missouri Public Service Commission cited the FCCs June 27 definition of interconnected VoIP services in denying Time Warner Cables motion to reconsider the Oct. 13, 2005, suspension of its filed tariff because its VoIP services were not subject to state regulation according to the FCC in its Vonage Order. Its one more of the dominos thats falling, says Brinkman.

Until they do fall, many VoIP providers already are using third-party verification services for business reasons. Where we see TPV playing an active role in the world of VoIP is with local number ports, says Brinkman, describing the process of moving a local number from one provider to another. Having that third-party or electronic letter of agency is almost required.

While VoIP providers are mostly unregulated, the carriers that have to port the numbers are regulated and must abide by the FCCs instructions to obtain customer authorization to do so. Brinkman says 3PVs VoIP customers have reported not being able to complete transactions with carriers without such authorizations being provided with third-party authentication.

Larry Leikin, general manager for VoiceLog, a division of BSG Clearing Solutions, says this potential problem is just another byproduct of regulatory uncertainty. VoIP providers are operating almost in a state of limbo because they are not carriers and yet they have to interact with carriers all the time, he says.

Leikin adds, the overriding motivation for VoIP players to use thirdparty verification services is to safeguard their customer bases.

One example of that practice is using third-party verifiers to deliver E911 notification. The FCC requires VoIP customers be notified that their E911 service will not work if the power goes out or if they move their ATA without notifying their VoIP provider. While notification is required by the FCC, verification by an outside organization is not. The reason VoIP providers would go to the added expense of outsourcing is not unlike buying an insurance policy. Should an incident arise where VoIP users are unable to connect to emergency services akin to the well-publicized cases with Vonage customers in Florida and Texas last year service providers have verifiable proof notification was given. TPV providers give VoIP providers almost instant access to voice recordings and online verifications they can share with customers if they call to complain.

Its a gray area as to whether the third-party verification is absolutely necessary, but its a small price to pay to make sure you have a solid customer confirmation and easily retrievable record of every customer confirmation, says Leikin.

TPV providers say VoIP providers increasingly are adding the E911 scripts to traditional LOA scripts. And, they say many customers are moving both of these processes to the Web, where online signups are becoming the norm. Brinkman says the trend to online is pervasive even among non-VoIP providers, noting around 20 percent of the 3PVs verifications now are done online with its newly trademarked eLOA product.

eLOA, which is used by Vonage, for example, is seamlessly integrated into a providers Web-based order process. Once the customer fills out the subscriber information, the data is sent in an XML stream to 3PV, which redirects the subscribers browser to 3PVs Web site. 3PV prepopulates the eLOA with information from the XML stream, and records the subscriber typing his/her digital initials. If a telesales agent made the sale, they simply e-mail the URL for the eLOA to the subscriber; the rest of the process is the same.

VoIP subscribers can digitally sign electronic LOAs online with 3PVs AssureSign product.

VoiceLog has a similar offer wherein the copy of the confirmed online order is recorded. VoiceLog has added a new feature called URU to its electronic LOA process as a result of its purchase by BSG Clearing Solutions earlier this year. URU really takes online verification to the next level, says Leikin, noting that it goes beyond simply recording the transaction. Its the ability in a realtime manner to confirm the customer that is typing in that order is who they say they are.

URU is an applet, which is integrated into existing provider Web forms using SOAP or HTTP APIs, and collects information (name, date of birth, address, home telephone number or the last four digits of the social security number) about the customer and verifies within seconds the customers identity. The process is transparent to the user.

3PV also has made enhancements to its eLOA with an optional product introduced in March called AssureSign, a forensically identifiable digital signature that a user signs with his/her mouse.

While it can augment the electronic signature that you make by typing your initials, it creates a more binding signature, says Brinkman, noting that it also is being used for online commerce using credit cards and for contracts. Later this fall, AssureSign will include tools that allow for multiple signatures and allow users to define where those signatures are placed in the document.

3PV Third Party Verification Inc.

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