Provider certification record

Graduation Alliance, Inc.

Listed
RMD number
RMD0041543
FRN
0038832382
OCN
 

Identity

Legal business name
Graduation Alliance, Inc.
Doing-business-as
 
Foreign Voice Service Provider
No
Business address
10 W. Broadway, Ste 700, Salt Lake City UT 84101
Filing contact
Charity Carney
Chief Technology Officer · Technology
charity.carney@graduationalliance.com
(602) 540-9187
10 W. Broadway Ste 700 Salt Lake City UT 84101
United States of America

Classification

Provider role(s)
  • Intermediate provider
STIR/SHAKEN implementation
RoleImplementation
Intermediate providerNone
OverallNone
Exemption rules
Pursuant to 47 CFR § 64.6302, the direct obligation to implement the STIR/SHAKEN authentication framework applies strictly to voice service providers and gateway providers originating or introducing IP traffic into the public switched telephone network (PSTN), or intermediate providers with an assigned Operating Company Number (OCN) operating as the first IP-based provider in the call chain.The filer is a standard commercial enterprise and does not operate as a traditional telecommunications carrier, facilities-based provider, or gateway provider. The filer does not hold an OCN. The filer utilizes an upstream voice service provider (Bandwidth) to provision inbound and outbound communications. The technical routing configuration within the filer’s proprietary software platform acts strictly as an internal transit network to bridge inbound communications across existing systems via automated call forwarding for internal IVR routing.Because all traffic handled by the filer originates on an underlying IP network managed by an authorized Voice Service Provider, the legal and technical obligation to execute cryptographic STIR/SHAKEN digital signatures resides with the originating carrier. Consequently, the filer is exempt from direct STIR/SHAKEN implementation under FCC rules and has instead established a comprehensive Robocall Mitigation Program to ensure network security and compliance.

Prior investigations / actions

Description
 

Robocall mitigation plan

Declaration

By
Charity Carney
Date
2026-09-02No Recertification Date

Listing history

DateEventDetail / diff
2026-09-02NewInitial certification filed and added to database.