Put the evidence behind the annual 47 CFR 64.2009(e) certificate where an officer can read it — the procedures as configured, the complaints, the data-broker actions — and let that officer sign.
A channel-level procedure-evidence figure can read clean while one channel carries most of the corrections. Nestack reports the counsel-correction rate by channel, not only in total.
Slice performance — reported separately, not only in aggregateIllustrative example
Slice
Failure rate
Lift
Lift vs. threshold
Status
Call detail over the phone
10.1%
3.7×
Review
Online account access
7.4%
2.7×
Review
Retail counter identification
4.6%
1.7×
Watch
Business accounts under contract
1.8%
0.7×
Normal
Bar: counsel-correction-rate lift vs. contracted-business-account baseline · scale 0–4.0× · tick marks the 2.0× review threshold2 of 4 slices over threshold
Evidence-linked improvement
What an unevidenced procedure costs
A cycle closes when the unevidenced procedure is a regression case. That suite is what the next certificate drafted is measured against.
Improvement cycle · five stagesSwitchback — the path turns at Improve and returns at Learn
01Detect
Counsel-correction rate rises in one channel.
02Diagnose
The password rule that had been written down once and never read against a call is read back until one cause remains.
03Improve
The change ships numbered, and the procedures that forced it ride with it.
04Verify
Nothing releases while one touched channel case is still red.
05Learn
It is kept permanently, and the authentication rules move in the same commit.
Learn → DetectThe return edge. The next statement is measured against a suite one case longer.
Typical build scope
Twelve workstreams across six weeks
The build scope read against the delivery timeline. Week structure follows the six-week plan — discovery, sources, evidence assembly, evaluation, integration, then production validation and handover.
WorkstreamWeek 1Week 2Week 3Week 4Week 5Week 6
01Certification-workflow discovery and boundary work.
02Authentication and complaint sources.
03Channel-procedure and evidence-coverage mapping.
04Procedure evidence ingestion.
05Channel, paragraph and record binding.
06Completeness scoring and counsel routing.
07Officer signature workflow.
08Complaint and case-system integration.
09Authentication and disclosure cases.
10Guardrails and attestation controls.
11Procedure-trail instrumentation.
12Deployment, documentation and Agent Care handover.
12 workstreams · 6 weeks · bar shows the weeks a workstream is active — several run in parallelFinal scope and sequence confirmed in discovery
Engagement tiers
What each tier includes
Rows are the capabilities named in each tier's scope. Higher tiers include everything below them.
Capability✓ in scope · — not at this tierPilotOne channel, one yearProductionProduction certification workflowAdvancedMultiple channels / entities
Introduced at Pilot
Statement drafting to your procedures✓✓✓
Named-officer signature✓✓✓
Procedure-evidence baseline✓✓✓
Introduced at Production
Reporting by channel—✓✓
Signature workflow in your systems—✓✓
Approved write-back—✓✓
Customer-record integration—✓✓
Introduced at Advanced
Multi-entity certification duties——✓
Cross-channel evidence packs——✓
High complaint volume——✓
Multi-channel authentication controls——✓
Build priceFrom $5,000From $8,000Custom quote
Final build priceConfirmed after discovery based on integrations, workflow complexity, transaction volume, approval controls and deployment requirements.
Separate from buildBuild pricing is separate from recurring Agent Care, which covers managed monitoring, evaluations, incidents and verified improvements after launch.
What we need from you
What you bring, and what we build with it
Each input maps to a piece of build scope and a week in the delivery timeline.
You bringWe build with it
01Your operating procedures as configured→Channel-procedure mapping and evidence captureWeek 1
02Representative complaints and notification logs→Complaint sorting, log binding and the statement baselineWeek 2
03Your data-broker actions and their outcomes→Procedure mapping, channel binding and the automation boundaryWeek 1
04Access to relevant APIs, feeds or exports→Authentication, CRM and complaint-source assessment, then integration setupWeek 2
05Procedures you would not want certified→Authentication cases and failure testingWeek 4
06What no compliance statement may assert→Completeness scoring, counsel routing, guardrails and signature controlsWeek 3
07A named officer to sign and file→Officer signature workflow, then pilot and production validationWeeks 5–6
Nothing else is requiredDeployment, documentation and Agent Care handover are ours.
Delivery timeline
Four phases across six weeks
These bands are the weeks each phase honestly costs, and the fifth of them therefore carries two.
PhaseW1W2W3W4W5W6
DiscoveryW1
BuildW2 – W3
EvaluateW4 – W5
Pilot & LaunchW5 – W6
Week focusW1Certification workflow discovery, procedure mapping and the automation boundaryW2Source integration and the procedure-evidence baselineW3Statement assembly, channel logic and signature controlsW4Evaluation suite, authentication cases and failure-mode testingW5Record integration, pilot procedures and targeted correctionsW6One certification year run under the certifying officer, then Agent Care handover
Reading the bandEach bar spans only the weeks its own work is named for. The fifth week doubles because the work does.
At the end of W6Validation closes on live procedures, and Agent Care picks up the watch.
DurationSix-week plan shown · typical delivery 4–6 weeks depending on scope confirmed in discovery.
Next step · Telecom AI agent
Build a CPNI certification agent around the evidence an officer has to hold.
Show us how a caller reaches call detail today and who signs on 1 March. If your password rule can be satisfied by what a caller reads off a bill, then the statement has to say so. A forfeiture needs no jury after 4 June 2026, and a § 222 scope petition stayed pending.
