Telecom AI agent · CPNI certification

CPNI Certification AI Agent

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.

Typical delivery: 4–6 weeks
Deployment: Your stack
Officer signs: Procedure-bound
After launch: Agent Care

What this agent does

Drafts the statement, not the certification

01
A caller asks for call detail, and the password that gates it must not be prompted with account information.
02
A caller has no password, and § 64.2010(b) leaves only the address and number of record.

Reason

03
An address of record changes, and the § 64.2010(f)(1) notice must not reveal it or go to it.
04
A customer walks into a store, and § 64.2010(d) wants a valid photo ID that matches the account.
05
A password reset falls back, and the back-up method may not prompt for account information either.

Decide

06
A complaint about unauthorized release is logged, and its categories come from the form, not the rule.
07
A location record is disclosed, and the April 2024 forfeitures ran on § 64.2007(b) and § 64.2010(a).

Out

08
A year closes, and the certificate is due with the Enforcement Bureau on or before 1 March.
09
Execute write actions only inside the approval boundaries agreed during implementation.

Product statement

The agent assembles and reconciles; a named officer states personal knowledge, signs the certificate and files it, and the carrier answers.

Example workflow

One procedure, evidence to filing

Agent

Human

1Procedure evidence receivedAuthentication configuration, notification logs or complaint records
2Channel coverage assembledPhone, online, retail and back-up paths, each tied to the § 64.2010 paragraph it answers to
3Statement draftedThe certificate, the statement, the data-broker actions and the complaint summary
4Controls appliedCoverage checks, evidence-sufficiency checks, date checks and completeness confidence

No human action required

Stages 1 to 4 run unaided, and nothing is certified at any of them — the agent is drafting, and the compliance lane opens at the completeness gate.

5DecisionBranches at the completeness gate

Evidence sufficient

Goes to the certifying officer to sign.

Anything thin

Adds a regulatory counsel read first.

Compliance review

The draft is held with its evidence, its gaps and the channels they sit in.

Sign and file · Append evidence · Send to counsel

Filed — by a named officer

6Procedure and case records updatedOnly where write access and records policy allow it
7Outcome evaluatedEvidence completeness, channel coverage, counsel corrections and what review found

Corrections

Each counsel correction is counted in the evaluation.

What should not run autonomously

Human approval stays in control

Outside the boundary — human approval required

8 items

Stating personal knowledge under 47 CFR 64.2009(e).
- Signing or filing the annual certificate.
- Asserting the carrier is, or is not, in compliance.
- Deciding that an operating procedure is adequate.
Automation boundary
Agent acts unaided
- ✓Assemble the procedure evidence and name the channel it governs.
- ✓Bind each configured challenge to the § 64.2010 paragraph behind it.
- ✓Sort the complaint log to the categories the Commission form names.
- ✓Draft the accompanying statement against what the procedures do.
Nothing is signed or filed except by a named officer, inside the agreed boundaries.
- Judging a complaint outside the unauthorized-release scope.
- Telling a customer their CPNI was handled lawfully.
- Deciding what an action against a data broker achieved.
Changes to authentication rules or notification templates.

Example output

One procedure, annotated

Our customer-support agent runs the challenge on the call; this record is the evidence that it is adequate.

Statement draft · single procedure

Illustrative example

Procedure: Call detail over the phone
Drafted as: Password gate, no biographical prompt
Channel: Voice, agent-assisted
Evidence of record: IVR and CRM configuration, 14 August 2026
Confidence: Held unsigned
Held for: The certifying officer, in person

As received

Taken from the live channel configuration and the notification log — it reaches as far as the logs do.

What the record holds

Password-rule evidence
Notification records
Complaint log entries

Why no adequacy call here

Adequacy is the officer test under 47 CFR 64.2009(e), not a model output.

What the score decides

Below the configured threshold the draft picks up a counsel read before the officer sees it.

Action

Sign and fileAppend evidenceSend to counsel

Value

Where AI adds value

The same four claims, placed at the point in the workflow where each one applies.

Where the value lands

Value 01 – 04

Every procedure

From the channel that runs it

03Evidence

Where the certification is used

Our fraud and SIM-swap agent scores a request against the challenge set your officer certified; this page holds that certification.

01Approved path

Personal knowledge, or none

47 CFR 64.2009(e) contemplates a statement that the carrier is not in compliance, so no draft asserts compliance the procedures do not carry.

02Human review

What was found, and what was not

Rehearing en banc was granted on 31 July 2026, vacating the decision that upheld the 2024 amendments, and no enforcement of § 64.2009(e) was found.

Build an evidence trail

The procedure, the channel it governs and the officer who certified stay on the record.

Integrations

Typical integrations

Five system groups connect to the same agent. Which of them are in scope is decided in discovery.

Filing and docket
- ECFS
- EB Docket No. 06-36
- Enforcement Bureau records
Authentication systems
- IVR
- CRM
- retail counter
- Self-service and app login
Customer records
- Account
- address of record
- Notification logs

Agent

CPNI certification evidence

Reads the procedures
Drafts the statement
Holds for the officer

Complaint and case systems
- CRM
- ticketing
- Data-broker action files
Observability & evaluation
- OpenTelemetry
- Langfuse
- Supported monitoring/evaluation sources

Integration availability depends on the client's existing systems and API access.

Agent controls

Six meshes between the model and the certificate

Six meshes, the coarsest of them first. What drops through every one is set out in the map below.

L6 · Outermost — last line of defence

Inward → L1 · closest to the model

L6Rollback / safe modeReturn the agent to evidence assembly when evaluation or production signals degrade.Roll back

L5Version monitoringTrack model, prompt and procedure changes; § 64.2010(h) stays [Reserved] with no compliance date.Track

L4TraceabilityRecord each procedure, its evidence, its channel and every read of the draft.Record

L3Officer releaseHold the draft for a named officer; it governs signature, not whether a procedure is adequate.Gate

L2Policy guardrailsTest the draft against § 64.2010 as configured per channel; the 2024 breach rule stays delayed.Restrict

L1Confidence thresholdsRoute a thin draft to a counsel read before the certifying officer sees it.Require review

Model coreStatement drafted — the procedures, the channels, the evidence and completeness

L1 – L2: Test whether a draft may stand
L3: Puts the signature in a person's hands
L4 – L5: Keep the procedure and the evidence behind it
L6: Holds the certificate undrafted when signals degrade

How Nestack evaluates it

Evaluate the whole assembly — not only the statement that comes out.

Coverage runs the whole depth of the workflow, and every layer is cut by slice.

Surface — the certificate an officer signs

E1Final-output evaluationDid the draft record the evidence behind each procedure?
E2Step-level evaluationDid the agent read the right channel, the right paragraph and the live configuration?
E3Tool evaluationDid it read and write the correct procedure record and the correct complaint?
E4Confidence calibrationDo low-confidence drafts actually attract more counsel corrections?
E5Slice evaluationHow does performance change across specific customer channels?
E6Business outcomeHow many drafts needed a correction before the officer signed?

Floor — the outcome the carrier answers for

Failure modes

Where each failure originates in the agent

Seven failure modes, set at the stage in the agent where each begins.

Agent lifecycle

Direction of processing →

01 · Retrieval
1 mode
- IL-03
  Stale procedure read
  The configuration read is not the one now running.
Stage gathers
The procedures, the channels, the logs and the complaints
02 · Reasoning
2 modes
- IL-04
  Adequacy asserted, not shown
  A procedure is called adequate without evidence.
- IL-06
  Dormant rule read as live
  The 2024 breach text is drafted as if in force.
Stage proposes
The procedures, their evidence and completeness
03 · Tool / write
2 modes
- IL-02
  Thin draft passed forward
  A draft moves on without the counsel read.
- IL-05
  Complaint mis-sorted
  A complaint is sorted to the wrong category.
Stage writes
Only where write access and approval policy allow it
04 · Output
1 mode
- IL-01
  Filed, evidence unrecorded
  The record shows a certificate but not what supported it.
Stage returns
The statement an officer signs and the Bureau reads
05 · Change / Version
1 mode
- IL-07
  Silent procedure regression
  A configuration change moves the procedure, not the record.
Stage tracks
Model, prompt, procedure rules and statement fields

Sev-1 · a certificate filed without an officer
Sev-2 · a wrong procedure reaches the record
Sev-3 · source degrades, draft holds unsigned

See the complete Telecom failure-mode catalogue

Affected slices

One channel absorbs the corrections

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 aggregate

Illustrative example

Slice	Failure rate	Lift	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 threshold

2 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 stages

Switchback — the path turns at Improve and returns at Learn

01
Detect
Counsel-correction rate rises in one channel.
02
Diagnose
The password rule that had been written down once and never read against a call is read back until one cause remains.
03
Improve
The change ships numbered, and the procedures that forced it ride with it.
04
Verify
Nothing releases while one touched channel case is still red.
05
Learn
It is kept permanently, and the authentication rules move in the same commit.
Learn → Detect
The 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.

Workstream

Week 1Week 2Week 3Week 4Week 5Week 6

01Certification-workflow discovery and boundary work.Week 1
02Authentication and complaint sources.Week 1, Week 2
03Channel-procedure and evidence-coverage mapping.Week 1, Week 2
04Procedure evidence ingestion.Week 2
05Channel, paragraph and record binding.Week 2, Week 3
06Completeness scoring and counsel routing.Week 3
07Officer signature workflow.Week 3, Week 4
08Complaint and case-system integration.Week 5
09Authentication and disclosure cases.Week 4, Week 5
10Guardrails and attestation controls.Week 4
11Procedure-trail instrumentation.Week 5, Week 6
12Deployment, documentation and Agent Care handover.Week 6

12 workstreams · 6 weeks · bar shows the weeks a workstream is active — several run in parallel

Final 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 tier	PilotOne channel, one year	ProductionProduction certification workflow	AdvancedMultiple 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 price	From $5,000	From $8,000	Custom quote

Final build price: Confirmed after discovery based on integrations, workflow complexity, transaction volume, approval controls and deployment requirements.
Separate from build: Build 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 bring

We build with it

01Your operating procedures as configured
→
Channel-procedure mapping and evidence capture
Week 1
02Representative complaints and notification logs
→
Complaint sorting, log binding and the statement baseline
Week 2
03Your data-broker actions and their outcomes
→
Procedure mapping, channel binding and the automation boundary
Week 1
04Access to relevant APIs, feeds or exports
→
Authentication, CRM and complaint-source assessment, then integration setup
Week 2
05Procedures you would not want certified
→
Authentication cases and failure testing
Week 4
06What no compliance statement may assert
→
Completeness scoring, counsel routing, guardrails and signature controls
Week 3
07A named officer to sign and file
→
Officer signature workflow, then pilot and production validation
Weeks 5–6

Nothing else is required

Deployment, 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.

Phase

DiscoveryW1
BuildW2 – W3
EvaluateW4 – W5
Pilot & LaunchW5 – W6

Week focus

W1Certification workflow discovery, procedure mapping and the automation boundary

W2Source integration and the procedure-evidence baseline

W3Statement assembly, channel logic and signature controls

W4Evaluation suite, authentication cases and failure-mode testing

W5Record integration, pilot procedures and targeted corrections

W6One certification year run under the certifying officer, then Agent Care handover

Reading the band: Each bar spans only the weeks its own work is named for. The fifth week doubles because the work does.
At the end of W6: Validation closes on live procedures, and Agent Care picks up the watch.
Duration: Six-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.

Typical delivery: 4–6 weeks
Deployment: Your authentication stack
Officer signs: Procedure-bound
After launch: Agent Care available

Nestack Agents · CPNI certification

AGT-TL-17 · Agent Care available after launch

CPNI Certification AI Agent

Where the certification is used

Personal knowledge, or none

What was found, and what was not

Filing and docket

Authentication systems

Customer records

CPNI certification evidence

Complaint and case systems

Observability & evaluation

Stale procedure read

Adequacy asserted, not shown

Dormant rule read as live

Thin draft passed forward

Complaint mis-sorted

Filed, evidence unrecorded

Silent procedure regression

Detect

Diagnose

Improve

Verify

Learn

Build a CPNI certification agent around the evidence an officer has to hold.