Provider certification record
Smith Operating Solutions, LLC
Listed- RMD number
- RMD0008543
- FRN
- 0031462955
- OCN
Identity
- Legal business name
- Smith Operating Solutions, LLC
- Doing-business-as
- Foreign Voice Service Provider
- No
- Business address
- 3824 Cedar Springs Rd, Suite 8, Suite 801-1363, Dallas TX 75219
- Filing contact
- Adam J Smith
Manager · Adam
support@smithos.net
(469) 554-0130
3824 Cedar Springs Rd, Suite 8 Suite 801-1363 Dallas TX 75219
United States of America - Principals, Affiliates, Subsidiaries, and Parent Companies
- • Designated Human Principal: Adam Smith • Title: Owner/Manager • Responsibility: Mr. Smith is the primary individual responsible for the implementation and oversight of this Robocall Mitigation Plan, including customer vetting, call analytics monitoring, and regulatory compliance. • Affiliations: SOS LLC has no parent companies, subsidiaries, or affiliates at this time.
Classification
- Provider role(s)
- Voice service provider
- STIR/SHAKEN implementation
Role Implementation Voice service provider None Overall None - Exemption rules
- The Company does not claim a § 64.6304 extension. Pursuant to the alternative provision in 47 CFR § 64.6305(d)(2)(i), the Company is unable to implement STIR/SHAKEN due to a lack of control over the network infrastructure necessary to implement STIR/SHAKEN. Specifically, the Company is a voice service provider that delivers calls originated by its end-user customers to the public switched telephone network through Telnyx LLC, an upstream voice service provider. The IP network facilities at which STIR/SHAKEN authentication is technically performed — including the session border controllers, signing infrastructure, and the originating provider's STI-CA certificate — are owned and operated by Telnyx, not by the Company. The Company does not hold, and under current Secure Telephone Identity Governance Authority (STI-GA) policy is not currently positioned to obtain, an Operating Company Number, an SPC token issued by the STI Policy Administrator (iconectiv), or a STIR/SHAKEN certificate from an STI Certification Authority. Accordingly, the Company has no technical means to authenticate calls under its own certificate on the infrastructure through which its customer traffic is delivered. The Company's lack of control is limited to the IP-PSTN signing layer. The Company exercises full operational control over its Hosted PBX platform, where its robocall mitigation program is implemented and enforced. This position is consistent with the Commission's longstanding determination that providers that lack control over the facilities necessary to implement STIR/SHAKEN do not have an implementation obligation. See First Caller ID Authentication Report and Order, 35 FCC Rcd 3241, 3260, para. 40 (2020); Wireline Competition Bureau, Triennial Report on the Efficacy of the Technologies Used to Implement Caller ID Authentication, n.27 (Dec. 2022). It is further consistent with the framework articulated in the Commission's Eighth Report and Order (FCC 24-119, adopted Nov. 2024), under which the STIR/SHAKEN implementation obligation attaches to the provider with control over the network infrastructure where authentication occurs. The Company has implemented, and continues to maintain, the comprehensive robocall mitigation program described in the attached Robocall Mitigation Plan (Sections 3 through 9), which fully satisfies the Company's obligations under 47 CFR § 64.6305(a). If the Company in the future obtains the credentials and infrastructure necessary to authenticate calls under its own STIR/SHAKEN certificate, the Company will update its RMD certification accordingly within 10 business days, consistent with 47 CFR § 64.6305(d)(5).
Prior investigations / actions
- Description
- Pursuant to 47 CFR § 64.6305(d)(2)(iv) and the Commission's Robocall Mitigation Database ("RMD") filing instructions, Smith Operating Solutions, LLC ("SOS" or "the Company") provides the following description of the prior agency action to which it was subject, addressing each of the five elements required by the Commission's instructions and the WCB Frequently Asked Questions document released January 22, 2026. (1) LAW ENFORCEMENT OR REGULATORY AGENCIES INVOLVED: The action was conducted entirely within the Federal Communications Commission ("FCC"). Two FCC bureaus participated: the Wireline Competition Bureau ("WCB"), which administers the RMD, conducted the initial review of the Company's certification, and issued the original deficiency notification; and the Enforcement Bureau ("EB"), which was the deciding bureau and issued the operative Show Cause Order and Final Removal Order. No other federal agency, state attorney general, the Industry Traceback Group, or other law enforcement body was involved. The matter was administered under FCC File No. EB-TCD-24-00036891, subsequently reassigned to File No. EB-TCD-25-00038590. (2) DATE THE ACTION OR INVESTIGATION COMMENCED: The matter commenced on March 29, 2024, when the WCB Robocall Mitigation Database team sent the Company an email notifying it that its RMD certification was noncompliant with 47 CFR § 64.6305 because the Company had not submitted an updated certification and updated robocall mitigation plan by the February 26, 2024 effective date established by the Sixth Caller ID Authentication Order and the Seventh Call Blocking Order. That notification directed the Company to cure the deficiency by April 29, 2024. The matter then proceeded through the Enforcement Bureau's Show Cause Order released December 10, 2024 (In the Matter of 2,411 Robocall Mitigation Database Filers, 39 FCC Rcd 13318), with a compliance deadline of December 31, 2024 following Federal Register publication on December 17, 2024; and concluded with the Final Removal Order, FCC Order DA 25-737, adopted and released August 25, 2025, which removed the Company's RMD certification (Database No. RMD0008543, listed in Appendix A to that Order). (3) CURRENT STATUS OF THE ACTION OR INVESTIGATION: The Enforcement Bureau's Final Removal Order (DA 25-737) took effect upon release on August 25, 2025; removed the Company's certification from the RMD as of that date; and required all intermediate and voice service providers to cease accepting traffic directly from the Company within two business days of release. On September 17, 2025, the Company received an email from the FCC's Robocall Mitigation Database team notifying the Company that its filing had been provisionally reinstated in the RMD, that downstream providers may resume accepting traffic from the Company under 47 CFR § 64.6305(g), and that the Company's downstream providers may be informed of the provisional reinstatement. The Bureau's notice expressly stated, however, that the "provisional reinstatement is not a final determination regarding the compliance of the [C]ompany's filing with the Commission's rules" and that "[d]eficiencies may still exist in [the] filing, which the [C]ompany should promptly address." Accordingly, the current status of this matter is as follows: (a) the Company's RMD certification was removed by Final Order on August 25, 2025; (b) the Company was provisionally reinstated to the RMD on September 17, 2025, pending the Bureau's confirmation that all deficiencies in its filing have been cured; (c) the Company has, in response to subsequent communications from Commission staff, undertaken iterative corrections to its certification and to the mitigation plan attached to this filing; and (d) the present submission is intended to address all remaining deficiencies identified by Commission staff. The Company is not aware of any ongoing investigation, civil enforcement action, forfeiture proceeding, or referral arising from this matter, and no monetary forfeiture or other sanction beyond the August 25, 2025 removal has been imposed. (4) SUMMARY OF FINDINGS OF WRONGDOING: The Enforcement Bureau's findings, set forth in paragraphs 7 and 8 of DA 25-737, were limited to administrative deficiencies in the Company's RMD filing. Specifically, the Bureau found that the Company's RMD certification was deficient on two grounds: (a) the Company's robocall mitigation plan was either not provided or did not contain the information required to be submitted by the February 26, 2024 deadline established under 47 CFR § 64.6305; and (b) the Company's certification itself lacked information required by that same deadline. The Bureau further found that, despite receiving the March 29, 2024 deficiency notification from WCB and the December 10, 2024 Show Cause Order from the Enforcement Bureau, the Company failed either to cure the deficiency or to file a response explaining why its certification should not be removed. Importantly, the Bureau did not find that the Company originated, transmitted, encouraged, assisted, or otherwise facilitated illegal robocalls or unlawful spoofing. The wrongdoing identified was the inadequacy of the Company's prior RMD certification and mitigation program description, not any underlying illegal calling activity. The Company's name does not appear in the August 6, 2025 Initial Removal Order (DA 25-694), which separately identified 185 providers that had additionally been associated with suspected illegal robocall traffic and traceback non-responsiveness. (5) WHETHER ANY FINAL DETERMINATIONS HAVE BEEN ISSUED: Yes. A final determination was issued in the form of FCC Order DA 25-737, adopted and released August 25, 2025, by the Acting Chief of the Enforcement Bureau pursuant to the authority delegated under 47 CFR §§ 0.111 and 0.311. That Order: (a) found the Company's RMD certification deficient; (b) removed the certification from the RMD effective upon release; (c) directed all intermediate and voice service providers to cease accepting traffic directly from the Company within two business days; and (d) prohibited the Company from refiling in the RMD absent the prior consent of both the Wireline Competition Bureau and the Enforcement Bureau. No monetary forfeiture, civil penalty, consent decree, or other sanction beyond removal was imposed, and no finding of intentional wrongdoing was made. The Bureau's subsequent September 17, 2025 provisional reinstatement of the Company to the RMD is, by its own terms, expressly not a final determination regarding the compliance of the Company's filing. No other final determination, by the FCC or any other agency, has been issued against the Company in connection with this matter. Full details of this matter and the Company's remediation are set forth in Section 2 of the attached Robocall Mitigation Plan.
Robocall mitigation plan
Declaration
- By
- Adam J Smith
- Date
- 2026-05-05Last Recertified 2026-03-01
Listing history
| Date | Event | Detail / diff |
|---|---|---|
| 2026-05-05 | New | Initial certification filed and added to database. |