International Mobile Subscriber Identity (IMSI) Assignment and 1

Management Guidelines and Procedures

INTERNATIONAL MOBILE SUBSCRIBER IDENTITY

(I M S I) ASSIGNMENT AND MANAGEMENT
GUIDELINES AND PROCEDURES

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TABLE OF CONTENTS
1.0 PURPOSE AND SCOPE ........................................................................................ 4

2.0 REFERENCES ...................................................................................................... 4

3.0 IMSI FORMAT, FUNCTION, AND MANAGEMENT ........................................... 5

4.0 ASSUMPTIONS AND CONSTRAINTS ................................................................. 7

5.0 ASSIGNMENT PRINCIPLES ................................................................................ 8

6.0 CRITERIA FOR HNI ASSIGNMENT ................................................................... 9

7.0 RESPONSIBILITIES OF HNI APPLICANTS AND ASSIGNEES ........................ 11

8.0 RESPONSIBILITIES OF THE IMSI-A ................................................................ 12

9.0 HNI RETURN AND RECLAMATION PROCEDURES ....................................... 14

10.0 MCC RELIEF PLANNING.................................................................................. 15

11.0 MAINTENANCE OF GUIDELINES .................................................................... 16

12.0 APPEALS PROCESS ........................................................................................... 16

13.0 GLOSSARY......................................................................................................... 17

ANNEX A -- IMSI RESOURCE CONSERVATION AND ASSIGNMENT AUDITS ......... 1

Addendum 1 -- Temporary Accommodation for GSM-Based and ANSI-41 CDMA-Based

Wireless Networks ............................................................................................................. 3

ANNEX B – IMSI Oversight Council (IOC) OPERATING PROCEDURES...................... 1

B-1 INTRODUCTION .................................................................................................. 1

B-2 MISSION, SCOPE, AND RESPONSIBILITIES ..................................................... 2

B-2.1 Mission ............................................................................................................... 2

B-2.2 Scope .................................................................................................................. 2

B-3 IOC MEMBERSHIP AND ORGANIZATION........................................................ 3

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B-3.1 Membership and Participation ............................................................................ 3

B-3.1.1 Membership ...................................................................................................... 3

B-3.1.2 Voting Participants ............................................................................................ 3

B-3.2 IOC Chairperson ................................................................................................ 3

B-3.3 IOC Secretariat .................................................................................................. 4

B-3.4 Joint Responsibilities of the IOC Chair and IOC Secretariat................................ 4

B-3.5 IOC Organization ............................................................................................... 5

B-4 IOC RESPONSIBILITIES ..................................................................................... 5

B-5 IOC FUNDING ...................................................................................................... 6

B-6 IOC OPERATIONAL PROCEDURES................................................................... 7

B-6.1 Issue and Appeal Identification ........................................................................... 7

B-6.2 IOC Meetings ..................................................................................................... 8

B-6.3 Issue and Appeal Resolution ................................................................................ 8

B-6.4 IOC Meeting Notes ........................................................................................... 10

B-7 REVISIONS TO THE OPERATING PROCEDURES .......................................... 10

Attachment 1 -- IOC ISSUE/APPEAL IDENTIFICATION FORM ................................. 11

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1.0 PURPOSE AND SCOPE

This document contains the guidelines and procedures for the assignment and use of International
Mobile Subscriber Identities (IMSIs) in the United States (U.S.) with consideration given to other
North American Numbering Plan (NANP) countries. In certain circumstances, these guidelines
may also apply to Territories of the United States.
1.1 The IMSI was created and formatted to provide the unique international identification of
mobile terminals and mobile users and to enable these terminals and users to roam among
public networks, which offer public mobility services.
1.2 These assignment guidelines pertain, in one section or another, to all segments of the IMSI.
The IMSI Administrator (IMSI-A) participates in the management of all segments of the
IMSI, but directly administers only the Home Network Identity (HNI) segment. HNIs are
assignable to operators of public networks offering public mobility services with
international roaming capabilities. The HNI uniquely identifies the home network of a
public mobility service subscriber and contains the Mobile Country Code (MCC) and the
Mobile Network Code (MNC). The remaining segment of the IMSI, the Mobile Station
Identification Number (MSIN), is directly administered by the network operator to which
the HNI is assigned.
1.3 These guidelines were developed by the consensus of representatives of entities within the
telecommunications sector of the United States. This consensus originally was achieved
during meetings of the IMSI Management Forum (IMF), the open industry forum initially
chartered to manage and oversee the administration of IMSIs. Since 2001, the IMSI
Oversight Council (IOC), a committee of the Alliance for Telecommunications Industry
Solutions (ATIS), is responsible for this oversight.
1.4 These guidelines apply throughout the United States, excluding those United States
Territories assigned their own unique MCCs, and do not supersede the regulations,
procedures or requirements of the FCC or any other appropriate legal or regulatory
authority.
1.5 These guidelines are based on the content of International Telecommunications Union –
Telecommunications’ (ITU-T) Recommendation E.212, The International Identification
Plan For Public Networks and Subscriptions. This Recommendation was revised in 2016.
The content of this document is in conformance with that iteration of the Recommendation.

2.0 REFERENCES

2.1 ITU-T Recommendation E.212, The International Identification Plan For Public Networks
and Subscriptions.

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3.0 IMSI FORMAT, FUNCTION, AND MANAGEMENT

3.1 The IMSI format and function are based on ITU-T Recommendation E.212. The addition
of a definition for an HNI, not contained in the Recommendation, is necessary in a country,
such as the United States, allocated multiple MCCs by the ITU.
3.2 Each IMSI uniquely identifies the mobile terminal/user, the home network of the mobile
terminal/user, and the home country of the network and of the mobile terminal/user.
3.3 The IMSI enables mobile terminals/users to roam among public networks, domestically
and internationally, by providing a uniform and unique home network and mobile
terminal/user identification that is recognizable by all conforming public networks. When
transmitted between visited and home networks, the IMSI enables the exchange of
subscription and billing information for the visiting mobile station.
Specifically, the IMSI is used for:
• Determination of the mobile terminal’s/user’s home network,
• Mobile terminal/user identification when information about a specific mobile
terminal/user is to be exchanged between visited and home networks,
• Mobile station identification on the radio control path for registering a mobile station
in a visited wireless network,
• Mobile station identification for signaling on the radio control path,
• Identification of the mobile terminal/user to allow for charging and billing of visiting
mobile terminals/users, and
• Subscription management, i.e., retrieving, providing, changing, and updating
subscription data for a specific mobile terminal/user.
3.4 The format of the IMSI in the United States is:

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3.5 The IMSI format in the United States is a fixed 15-digit length -- the maximum allowable
by ITU-T Recommendation E.212. Each IMSI contains an MCC, an MNC, and an MSIN.
The MCC and MNC combine to form the US-defined HNI, which is the segment of the
IMSI directly administered by the IMSI-A. MSINs are administered directly by the
network operator to which the HNI is assigned.
3.6 The function of the MCC is to identify the domiciliary country of a mobile terminal/user.
By analyzing the MCC, a visited network can determine the country from which the mobile
terminal/user originated and in which its home network resides.
According to ITU-T Recommendation E.212, an MCC is three digits in length and is in the
format NXX, where N equals any of the decimal digits 2-9, and X equals any of the decimal
digits 0-9. MCCs are assigned by the ITU-T in response to formal requests from
recognized national administrations of ITU-T-member countries -- in the United States, the
Department of State. The seven MCCs currently assigned to the United States, not
including its Territories, are “310” through “316.”
3.7 The function of the MNC is to identify the home network, within the country associated
with the MCC, of the visiting mobile terminal/user. The visited network uses the MCC-
MNC combination to identify and query the home network of the visiting mobile
terminal/user that is requesting service.
MNCs in the United States are three digits in length and in the format XXX, where X
equals any of the decimal digits 0-9. The 3-digit maximum is necessary so that, when
combined with the 3-digit MCC, the visited network need not analyze more than 6 digits
to determine the home network of the visiting mobile terminal/user, another ITU-T
Recommendation E.212 requirement. This format provides a mathematical potential of
one thousand MNCs (000-999) for each MCC. Consequently, a mathematical potential of
seven thousand public networks can be served by the seven MCCs allocated to the United
States.
3.8 The function of the MSIN is to uniquely identify a mobile terminal/user within its home
network.
MSINs in the United States are nine digits in length and in the format XXXXXXXXX,
where X equals any of the decimal digits 0-9. ITU-T Recommendation E.212 limits IMSI
length to a fifteen-digit maximum. Since the United States’ IMSI format includes a six-
digit HNI, a nine-digit MSIN is the maximum allowable. The nine-digit format provides
one billion MSINs per MNC or network, if no other function than mobile terminal/user
identification is embedded in the MSIN.
3.9 The HNI contains the MCC followed by the MNC and is a fixed 6-digit length in the United
States. The HNI is required in a country with multiple allocated MCCs because analysis
of both the MCC and the MNC is required to uniquely identify the home network since
MNCs will be duplicated within the multiple MCCs allocated to the country. The HNI is
not specified in ITU-T Recommendation E.212. It has been created and defined in the
United States to address the lack of MNC uniqueness inherent in a multiple MCC
environment.

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3.10 Test HNIs are available for use by the industry. The test HNIs are intended for use by
industry entities to perform internal testing. These HNIs do not identify any particular
network. Test HNIs are not for exclusive use by any industry entity and it should be
expected that the same HNIs may be in use by other entities simultaneously.
3.11 All current HNI assignments (including test HNIs) are available at the IMSI-A web site
[Link].
3.12 The IMSI Oversight Council (IOC), a committee of the Alliance for Telecommunications
Industry Solutions (ATIS), manages the IMSI resource in the United States and oversees
the performance of the IMSI-A. The management of the resources includes such functions
as Assignment Guidelines maintenance, ensuring the adequacy of the resource inventory,
and ensuring the appropriate function and use of the resource. Annex B of these Guidelines
contains the IOC Operating Procedures. This Annex is an integral part of these Guidelines.

4.0 ASSUMPTIONS AND CONSTRAINTS

These guidelines are based on the following assumptions and constraints:

4.1 These guidelines and procedures should provide the greatest latitude to those providing
public mobility services, while permitting the effective and efficient management of a finite
resource.
4.2 Although the quantity of IMSIs available within the seven MCCs currently allocated to the
United States is substantial, the demand for HNIs may, at some time in the future, exceed
the capacity of the seven MCCs initially assigned to the United States. Planning for MCC
exhaust and obtaining additional MCC resources are discussed in Section 11.
4.3 The guidelines and procedures for IMSI assignment in the United States, as set forth in this
document, remain in effect until there is either industry consensus or regulatory policy
direction to change them.
4.4 These guidelines do not describe the method by which IMSIs are transmitted across and
processed by public networks. Network interworking arrangements are contained in other
standards, documents, or business agreements.
4.5 There are authorized HNI application and maintenance fees. Each application must have
an accompanying HNI application fee payment or the application will be returned. The
HNI application fee funds the IMSI Administration function. Additionally, each HNI
assignee will be separately assessed an annual HNI maintenance fee. The maintenance fees
will be invoiced on a calendar year basis (January 1st – December 31st). Any proposed
changes to the application or maintenance fees should be submitted to the IOC at least 30
days in advance of the requested approval date.

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5.0 ASSIGNMENT PRINCIPLES

The assignment principles defined below allow public network operators the greatest possible
latitude in providing public mobility service and the users of these services the widest possible
roaming capabilities.
5.1 HNIs are to be assigned and used only by public networks offering public mobility services
(Section 1.2).
5.2 Upon application, the IMSI-A will assign one HNI for each valid network operator.
Nothing shall preclude a network operator, however, from aggregating multiple or merged
networks/licenses within a single HNI. An application for a subsequent HNI may be
submitted to the IMSI-A should an assignee exhaust the number of IMSIs within the
assigned HNI, or require an additional HNI for a unique application, service or technology.
5.3 The 6-digit HNI, as part of the 15-digit IMSI, is to be assigned so as to uniquely identify
the home network of the terminal/user.
5.4 MSINs are assigned by network operators to their subscribed mobile terminals/users. An
IMSI is unique to a single mobile terminal/user, but a mobile terminal/user may have
multiple IMSIs.
5.5 IMSIs and HNIs shall be assigned to permit the most effective and efficient use of a finite
resource in order to maximize the existing allocated resource inventory and to defer, as
long as practical, the need to request additional MCC resources.
5.6 IMSIs are a public resource. The assignment of any portion of an IMSI (i.e., HNI, MSIN)
does not imply ownership of the resource by either the entity to which it is assigned or by
the entity performing the administrative function.
5.7 Should an assignee transfer control of the CMRS license or a portion of its serving area
under an existing license, then the use of the assigned HNI is transferable to the new license
owner.
5.8 The IMSI-A will:
• Assign HNIs in a fair, timely, and impartial manner to any applicant that meets the
criteria for assignment (Section 6).
• Assign HNIs on a first come, first served basis from the available pool of unassigned
HNIs.
• Make all assignments based on the procedures in these guidelines (Section 8).
• Treat sensitive information received from applicants as proprietary and confidential,
and not to be shared with those outside the IOC and IMSI-A.
5.9 Information that is requested of applicants in support of an HNI application shall be
uniform and kept to a minimum.

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5.10 Assigned HNIs should be deployed as soon as possible, but no later than twelve months
after assignment. If the assignee can demonstrate that an assigned HNI has not been
deployed solely due to delays beyond its control, the time period can be extended for up to
90 days. At the discretion of the IMSI-A, one additional 90-day extension may be granted
without the approval of the IOC.
5.11 An entity that is denied an HNI assignment or extension under these guidelines has the
right to appeal that decision (Section 12).
5.12 These guidelines have no effect on HNI assignments made prior to the guidelines’
approval. Use of all assigned resources shall be consistent with these guidelines.
5.13 A working HNI returned to the IMSI-A for reassignment will remain dormant for a period
of not less than 180 days from the date of return to the HNI pool before reassignment. An
HNI recovered in accordance with reclamation procedures will not be reassigned until
confirmation is received from the IOC. If an HNI is returned and was never working in
the current assignee’s network, the HNI is immediately reassignable (i.e., no dormancy is
required).
5.14 There is an administrative fee associated with an application for an HNI.
5.15 As required, applicants for HNIs must comply with all applicable local, state, and federal
regulations relative to the provisioning of public mobility service.

6.0 CRITERIA FOR HNI ASSIGNMENT

The assignment criteria in the following paragraphs should be considered by a potential HNI
applicant before submitting an HNI application and will be used by the IMSI-A in reviewing and
processing an HNI application:
6.1 The HNI applicant must be, and certify that it is, a public network operator (commercial or
government), or an authorized agent operating on behalf of a public network operator as a
Mobile Virtual Network Operator (MVNO), offering mobility services in the United States
with a need to roam onto/from commercial networks, or that it is a provider of a service
profile management system (e.g., Home Location Register [HLR], Home Authentication,
Authorization, and Accounting [AAA], or Home Subscriber System [HSS]) based in the
United States for end user devices that can access public networks in the United States.
6.2 The applicant/assignee of an HNI must have and provide evidence of authorization, if
required, from the appropriate federal, state or local regulatory authorities to operate in the
area in which it intends to provide mobility services. MVNO applicants must provide a
copy of the executed contract with a public network operator.
6.3 Applicants offering commercial services must offer non-discriminatory access of this
resource to users. That is, such applicants must offer the availability of services to any end-
user customer requesting the service.

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6.4 The applicant must certify that the HNI will be used for mobile applications. That is, the
applicant must certify that the service provided will have at least two of the following
characteristics:
• Access to a service profile 1 management system – Service profile management is the
ability to access and manipulate a service profile. The user, the subscriber or the
provider can perform service profile management.
• Terminal Mobility – The ability of a terminal to access telecommunication services
from different locations and while in motion, and the capability of the network to
identify and locate that terminal.
• Personal Mobility – The ability of a user to access telecommunications services at any
terminal on the basis of a personal identifier, and the capability of the network to
provide those services according to the user’s profile. Personal mobility involves the
network capability to locate the terminal associated with the user for the purpose of
routing.

6.5 At least one radio interface protocol used by the network equipment or end user devices of
the Applicant must be from the following list of protocols known to require IMSI for
identification and signaling:
• GSM-based protocols including General Packet Radio Service (GPRS), Enhanced Data
for GSM Evolution (EDGE), Wideband CDMA (W-CDMA), and High Speed Packet
Access (HSPA).
• CDMA2000 protocols including CDMA2000 1X (a 3GPP2 cellular technology
providing voice and data services) and High Rate Packet Data (HRPD [EVDO]).
• Long Term Evolution (LTE) protocols including LTE Advanced.

6.6 An HNI will only be assigned by the IMSI-A upon receipt and approval of a completed
Form A – Home Network Identity (HNI) Application. The payment of the application fee
must accompany the application or the application will be returned. An application for
additional HNI assignments will only be processed if the annual maintenance fees of the
applicant/assignee are paid to date (see the IOC Operating Procedures, Annex B, Section
B-5 for further detail concerning fees).

1
Service profile—a record containing all the information related to a user in order to provide that user with service
(i.e., a database).

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7.0 RESPONSIBILITIES OF HNI APPLICANTS AND ASSIGNEES

Entities requesting HNI assignments and entities already assigned one or more HNIs shall comply
with the following:
7.1 HNI applicants and assignees must meet all conditions specified in these guidelines.
Official copies of the guidelines may be obtained from the ATIS IOC web site. 2
7.2 Applicants must apply online at [Link]/forms or in writing to the IMSI-A by
completing Form A - Home Network Identity (HNI) Application.
7.3 HNI assignees shall:
7.3.1 Assign and efficiently manage the MSINs (last nine digits of the IMSI) associated
with the assigned HNI. Maintain up-to-date and accurate assignment records that
match MSINs to mobile terminals/users. These records may be required for audit
purposes (Annex A).
7.3.2 Inform the IMSI-A of changes in the information associated with an HNI
assignment by using Form D – Request for Change in Home Network Identity (HNI)
Assignment Information. Changes may occur because of the transfer of an HNI,
through merger or acquisition, to a different network (Section 5.7). The initial
assignee of the HNI involved in a transfer occurring through merger, acquisition or
other means must immediately inform the IMSI-A when such a change becomes
effective. Timely submission of change information enables the IMSI-A to
maintain accurate HNI assignment records.
7.3.3 Participate in the IMSI audit process, when requested (Annex A).
7.3.4 Deploy any HNI, assigned either directly by the IMSI-A or obtained through
merger or acquisition, within the time period specified (Section 5.10). Inform the
IMSI-A of HNI deployment by submitting Form C – Home Network Identity (HNI)
Deployment.
7.3.5 Apply to the IMSI-A for an extension (Section 5.10) if the deployment requirement
cannot be met and the HNI is still required.
7.3.6 Return to the IMSI-A, using Form F – Home Network Identity (HNI) Assignment
Return:
• Any HNI no longer needed for the provision of public mobility services,
• Any HNI not deployed within the time period specified, including extensions
(Section 5.10), or

2
The ATIS IOC web site is maintained at [Link]/ioc.

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• Any HNI not used in conformance with these assignment guidelines, including
failure to submit proper application and maintenance fees.

8.0 RESPONSIBILITIES OF THE IMSI-A

The role of the IMSI-A is to manage the entire IMSI resource and to directly administer the HNI
segment of the IMSI. In this context, the IMSI-A shall:
8.1 Provide to the industry general and specific information on the structure and proper use
and management of IMSIs.
8.2 Provide copies of these guidelines and forms to HNI applicants and assignees, and assist
them in completing the required forms.
8.3 Review and process HNI applications as follows:
8.3.1 Review the application to determine if all requested information is provided and
credible. If not, return the application to the applicant requesting that any
deficiency be corrected.
8.3.2 Inform applicants of the status of their requests using Form B – Home Network
Identity (HNI) Application Disposition. There are three possible dispositions:
approved, denied, or additional information required. Notify the applicant in
writing of the disposition within ten working days from receipt of Form A. The
response will include:
• If assigned, the specific HNI(s) assigned,
• If denied, the reasons for denial and instructions on how and where to appeal
the decision, or
• If additional information is required, the specific information required.
8.4 Use the following HNI assignment procedures:
8.4.1 The IMSI-A shall generally assign HNIs in numerical sequence by MCC and by
MNC within each MCC. The next MCC in numerical sequence should not be used
until all MNCs in the preceding MCC have been assigned.
8.4.2 There may be technical considerations or limitations on the part of the applicant
that require a specific assignment or preclude them being able to use the next
consecutive MNC assignment. These exceptions are set forth below and in the
Addenda (if any) to this document.
Accommodation for backward compatibility for existing public networks offering
public mobility services only identified by 10-digit mobile identification numbers
(MINs): The following HNIs are not available for assignment in order to support
inter-networking with wireless network licensees requiring backward compatibility

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for existing public networks offering public mobility services only identified by 10-
digit MINs:
310–000 through 310–009
8.4.3 HNI applicants eligible for multiple MNCs may request that such MNCs be
assigned in the next available block of numerically sequential codes (excepting
those MNCs reserved or unavailable for assignment, pursuant to Section 8.4.2 or
any subsequent addenda to these guidelines). In such cases, a separate Form A
should be submitted for each MNC required, along with a cover letter requesting
their assignment in a sequential block.
8.4.4 When reassigning an HNI that has been returned or reclaimed, the IMSI-A will
ensure that the HNI has remained dormant for the required period (Section 5.13)
and confirm with the IOC that the HNI is no longer in use for reclaimed MNCs (per
Section 9.2).
8.4.5 A returned or reclaimed HNI should be reassigned, following the required dormant
period, prior to the assignment of any HNI from an MCC of higher numerical value
than the returned or reclaimed HNI.
8.5 Maintain accurate and current HNI application and assignment records. Update the records
as required to respond to requests for changes in assignment information reported by HNI
assignees (Section 7.3.2). Respond to these requests within ten working days using Form
E – Confirmation of Change of Home Network Identity (HNI) Assignment Information.
8.6 Publish, at least monthly, via the agreed medium, a list of assigned HNIs. The list will
include the HNI number and the HNI assignee company name. Track the number of IMSIs
assigned and the assignment rate and report this data regularly to the ATIS IOC.
8.7 Investigate any HNI that has not been deployed within the required time frame, and issue
extensions if appropriate (Section 5.10). The IMSI-A will forward a letter to each HNI
assignee that has not reported the implementation of an assigned HNI(s) in conformance
with Section 5.10, i.e., at the one-year initial implementation date and at the end of an
implementation extension(s). The letter will request the implementation status of the
assigned HNI(s) and state that if implementation confirmation, or an extension request, is
not received within 30 days, the HNI(s) is subject to reclamation/reassignment. Notify the
IOC if an assignee fails to deploy an assigned HNI within the allotted extension(s).
8.8 Reclaim assigned HNIs (Section 9), as needed.
8.9 At the determination of the IOC, the IMSI-A may be requested to perform assignment
audits. This requirement is not considered to be the ongoing responsibility of the IMSI-A
unless agreed to by the IOC. The IMSI-A may recommend to the IOC that a specific audit
be performed. See Annex A for the future and potential auditing process. This Annex is
not an integral part of these guidelines. If/when the IOC directs the conduct of an audit, a
method of remuneration for the IMSI-A’s time and effort will be jointly determined by the
IOC and the IMSI-A.

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8.10 Inform the United States telecommunications industry, via the agreed method, of any
revisions to these guidelines (Section 11).

9.0 HNI RETURN AND RECLAMATION PROCEDURES

9.1 Assignee responsibilities:

• Assignees will return HNIs that are no longer required, not deployed, or not used in
conformance with these assignment guidelines (Sections 5.10, 7.3.5 - 7.3.6).
• Assignees will cooperate with the IMSI-A in carrying out its reclamation and auditing
responsibilities.
9.2 IMSI-A responsibilities:
• The IMSI-A will contact any HNI assignee identified as not having returned to the
IMSI-A, for reassignment, any HNI no longer required, not deployed, or not used in
conformance with these assignment guidelines (Sections 5.10, 7.3.5 - 7.3.6), including
non-payment of the annual HNI maintenance fee(s).
• The IMSI-A will first seek clarification from the assignee regarding any alleged non-
use or misuse. If the assignee provides an explanation satisfactory to the IMSI-A, and
in conformance with these assignment guidelines, the HNI will remain assigned. If no
satisfactory explanation is provided, the IMSI-A will request a letter from the assignee
returning the assigned HNI for reassignment. If a direct contact cannot be made with
the assignee to affect the above process, the IMSI-A will look up the license associated
with the IMSI and attempt to contact the current licensee. If that contact does not
resolve the non-conformance, a registered letter will be sent to the assignee address of
record requesting that they contact the IMSI-A within thirty days regarding the alleged
HNI non-use or misuse.
• If the letter is returned as non-delivered or the assignee refuses to return the MNC or
to comply with the guidelines, the IMSI-A will advise the IOC. Per Section 9.3, the
IOC will direct the IMSI-A as to whether the HNI will be reclaimed and made available
for reassignment following the required dormant period (Section 5.13).

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9.3 If the IMSI-A refers to the IOC an unresolved HNI assignment as described in Section 9.2,
the IOC will:
• Accept all referrals of alleged non-use or misuse of HNIs from the IMSI-A or any other
entity, and
• Investigate the referral, and
• Review the referral in the context of these assignment guidelines, and
• Attempt to resolve the referral, and perform one of the following:
o Direct the IMSI-A regarding the action, if any, to be taken (if the action to be
taken is not in conformance with the existing guidelines, the IOC will initiate
the guidelines revision process [Section 11]), or
o Refer the case to the appropriate regulatory body for resolution if the IOC
cannot reach consensus on a resolution, or
o Refer the case to the appropriate regulatory body if the HNI assignee will not
comply with the consensus resolution developed by the IOC.

10.0 MCC RELIEF PLANNING

10.1 When all the HNIs in all but two of the MCCs assigned to the United States have been
assigned, or assignments are exceeding 10% of the resource per quarter, the IMSI-A will
inform the IOC.
10.2 When the IMSI-A informs the IOC that the MCCs assigned to the United States are
approaching exhaust, the IOC will:
• Conduct an audit of current IMSI assignments to ensure that efficient IMSI utilization
is in effect, and, if not,
• Recommend additional procedures to be initiated to effect more efficient IMSI
utilization, or if efficient utilization is in effect,
• Provide the requisite data to the United States Department of State and request that it
obtain additional MCC resources from the ITU-T, if required.
Using data provided by the IOC, the United States Department of State will request
additional MCC resources for the United States from the ITU-T and will inform IOC of
the result. Currently, MCCs 317-329 are not allocated. Should additional MCCs be
required by the United States, MCCs in this list of unallocated MCCs could be requested
in order to continue with consecutive MCC allocations.

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11.0 MAINTENANCE OF GUIDELINES

It may be necessary to modify the guidelines periodically to meet changing and unforeseen
circumstances. The need for guidelines modification may be identified by the IMSI-A, any entity
in the telecommunications sector or the IOC. When a need for modification is identified by an
entity other than the IOC, the identifying entity will submit the modification issue to the IOC. The
IOC will coordinate the modification process. Questions or concerns regarding the maintenance
of the guidelines may be directed to the IMSI-A or IOC.

12.0 APPEALS PROCESS

Disagreements may arise between the IMSI-A and HNI applicants or assignees in the context of
the administration and management of HNIs and the application of these guidelines. In all cases,
the IMSI-A and HNI applicants/assignees will make reasonable, good faith efforts to resolve such
disagreements among themselves, consistent with the guidelines, prior to pursuing any appeal.
Appeals may include, but are not limited to, one or more of the following options:
• HNI applicant/assignee will have the opportunity to resubmit the matter to the IMSI-A for
reconsideration with or without additional input.
• Guidelines interpretation/clarification questions may be referred to IOC for resolution. Unless
otherwise mutually agreed to by the parties, these questions will be submitted in a generic
manner protecting the identity of the appellant.
• The applicant/assignee may pursue the disagreement with the appropriate
governmental/regulatory body.
Reports on any resolution resulting from the above options, the content of which will be mutually
agreed upon by the involved parties, will be kept on file by the IMSI-A and IOC. At minimum,
the report will contain the final disposition of the appeal; e.g., whether or not an HNI was assigned.

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13.0 GLOSSARY

Conservation – Consideration given to the efficient and effective use of a finite resource in order
to minimize the cost and need to expand its availability while at the same time allowing the
maximum flexibility in the introduction of new services, capabilities and features.
Home Authentication, Authorization, and Accounting (AAA) – A server(s) in the home network of
the HNI assignee that provides authentication, authorization, and accounting service profile
management functions.
Home Location Register (HLR) – The HLR is a central database that contains details of each
mobile device subscriber that is authorized to use the core network; the HLR stores details of every
SIM card issued by the network operator.
Home Network Identifier (HNI) – The HNI is the aggregate of the MCC and MNC and is uniquely
required in countries with more than a single MCC. The existence of multiple MCCs in a country
necessitates that both the MCC and MNC must be analyzed to determine the home network of a
roaming terminal/user, hence the need for HNI functionality. The HNI is the resource for which
these Assignment Guidelines and Procedures were developed and which the IMSI-A administers.
HNI assignee – The entity to which an HNI has been assigned for the provision of public mobility
services. This enables international roaming capability.
Home network – The network to which a given mobile terminal/user is subscribed.
Home Subscriber System (HSS) – The HSS is a system that provides subscriber identification and
authorization service profile management functions.
International Mobile Subscriber Identity (IMSI) – The IMSI is a string of decimal digits, up to a
maximum length of 15 digits, which identifies a unique subscription. The IMSI consists of three
fields: the mobile country code (MCC), the mobile network code (MNC), and the mobile
subscription identification number (MSIN).
International Roaming Capability – The ability of a mobile terminal/user to originate and receive
calls and other telecommunications services while outside their home country.
Mobile Country Code (MCC) – The first field of the IMSI that is 3 digits in length. An MCC either
identifies a country or a group of Networks that share an MCC for international services.
Mobile Network Code – The second field of the IMSI that is 2 or 3 digits in length. The MNC, in
combination with the MCC, uniquely identifies the home network of the mobile terminal or mobile
user. In the U.S., the combination of the MCC and MNC is the HNI.
Mobile Subscriber – An entity or person that contracts to receive or pay for a public mobility
service.
Mobile Subscriber Identification Number (MSIN) – The third field of the IMSI that is a maximum
of 9 digits. The MSIN within a given MCC+MNC (HNI) identifies a unique mobile terminal or
mobile subscriber within a public network.

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Mobile Terminal – Any portable, transportable, or handheld terminal supporting public mobility
service.
Mobile User – A user that utilizes a subscription to access a public mobility service.
Network Operator – The entity responsible for the maintenance and operation of a public
telecommunications network which supports public mobility services.
Public Mobility Service – A public telecommunications service that supports voice and/or data
mobility for terminals or users by providing access to and from the public network via a home
network and/or visited network(s).
Public Network – A wireless network that offers service to the general public or that is operated in
the public interest.

Visited Network – The network providing service to a subscriber when the subscriber roams
outside the home network.

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ANNEX A -- IMSI RESOURCE CONSERVATION AND

ASSIGNMENT AUDITS
A-1 At the determination of the ATIS IMSI Oversight Council (IOC), the IMSI Administrator
(IMSI-A) may be requested to perform assignment audits. This requirement is not
considered to be the ongoing responsibility of the IMSI-Aunless agreed to by the IOC. The
IMSI-A may recommend to the IOC that a specific audit be performed.
A-2 Assignment and management of United States’ IMSI resources are undertaken with the
following conservation objectives:
• To efficiently and effectively administer/manage a limited resource through code
conservation, and
• To eliminate or delay the exhaust potential for the MCCs currently assigned to the
United States.
The process to achieve these objectives should not impede the introduction of competitive
services utilizing IMSI station identifiers.
A-3 The ITU-T will certainly require a compelling reason for the allocation of more than 7
billion MSINs and 7000 HNIs -- the number in the United States inventory based on the
format described above -- to one country. To promote the efficient and effective use of
numbering resources, audits of HNI assignments may be performed to ensure consistent
compliance with these guidelines.
A-4 The IMSI-A will track and monitor IMSI assignments and assignment procedures to ensure
that all segments of the IMSIs are being used in an efficient and effective manner. Ongoing
administrative procedures that foster conservation shall include, but not be limited to, the
following:
• An active reclamation program to reclaim unused or misused HNIs,
• Strict conformance with these guidelines by those assigning HNIs and MSINs,
• Appropriate and timely modifications to these guidelines to enhance text that may have
allowed inefficient use of IMSIs and HNIs, and
• Periodic specific and random audits of assignments and assignment procedures.
A-5 The IMSI-A may conduct an audit of an HNI assignee’s assignment records. The audit may
be precipitated by a complaint from outside the IMSI-A’s organization or by the IMSI-A.
The purpose of an audit will be to verify the HNI assignee's compliance with the provisions
set forth in these guidelines.
A-5.1 These audits will be conducted at the HNI assignee's premises or at a mutually
agreed to location and at a mutually agreed to time.

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A-5.2 The IMSI-A will not copy or remove the information from the premises nor will it
disclose the information to those outside the IOC and IMSI-A.
A-5.3 The IMSI-A will expect to review the following information to ensure conformance
with these guidelines and the proper use of the IMSI resource:
• Verification of assignment for each working MSIN,
• Date of assignment of each working MSIN,
• Activation date of each working MSIN,
• Indication of MSIN assignment to end users, and
• Status and status date of each MSIN unavailable for assignment; i.e., MSINs
assigned for testing, reserved, aging, pending and/or, suspended.
A-6 Audit results should be used to identify and recommend to the appropriate industry forum
specific corrective actions that may be necessary. Examples of specific corrective actions
which may be proposed are as follows:
• Modifications to these assignment guidelines to reflect the specific circumstance
revealed by the audit,
• Additional training for HNI assignees concerning the assignment guidelines,
• Return of assigned HNIs,
• Requirements for supporting documentation of future HNI requests in non-compliant
situations, or
• Modifications to the process in which records are maintained or HNIs are assigned.
A-7 Audit results with respect to HNI assignee information and/or recommended HNI assignee
process modifications shall be treated on a proprietary and confidential basis.
A-8 Failure to participate/cooperate in an audit shall result in the activation of HNI reclamation
procedures (Section 9 of the IMSI Assignment and Management Guidelines and
Procedures).

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Addendum 1 -- Temporary Accommodation for GSM-Based and ANSI-

41 CDMA-Based Wireless Networks

Currently GSM-based and ANSI-41 CDMA-based wireless public networks can handle only 2-
digit MNCs. This limitation can be accommodated, until such time as GSM-based and ANSI-41
CDMA-based wireless public networks are modified to support 3-digit MNCs, through the
following temporary assignment guideline:

Until the GSM-based and ANSI-41 CDMA-based industries, via a decision of ATIS IOC, indicate
full readiness for support of 3-digit MNC:
• MNC codes in the format XX0, where X equals any of the decimal digits 0 through 9, are
reserved for assignment to CMRS license holders choosing to deploy GSM-based or ANSI-41
CDMA-based technology. When a licensee meeting this requirement requests a code
assignment and does not specify a 3-digit MNC, the next such code in numerical sequence will
be assigned. Such codes from the next consecutive MCC should not be assigned until all such
codes from the preceding MCC have been assigned.
• Notwithstanding the above, any licensee may explicitly request a 3-digit MNC. This can be
assigned from any unassigned code in any block of 10 consecutive codes from which a 2-digit
MNC has not already been assigned.
After the industry, via ATIS IOC, indicates full readiness for support of 3-digit MNC:

• 2-digit MNC codes will no longer be assigned to GSM-based or ANSI-41 CDMA-based

wireless public networks. All assignments will be 3-digit MNC codes and can be made from
blocks containing a previous 2-digit MNC code assignment.

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ANNEX B – IMSI Oversight Council (IOC)

OPERATING PROCEDURES
B-1 INTRODUCTION

During the latter half of 1995, the U.S. wireless telecommunications industry developed
assignment guidelines for International Mobile Subscriber Identities (IMSI) in the U.S. These
guidelines were developed in an open industry forum jointly sponsored by the Cellular
Telecommunications Industry Association (CTIA) and the Personal Communications Industry
Association (PCIA). 3 The result of this development effort was the consensus-approved document
titled IMSI Assignment and Management Guidelines and Procedures – to which these Operating
Procedures are Annexed.

The IMSI Assignment and Management Guidelines and Procedures call for the formation of an
“appropriate industry forum” tasked with various responsibilities associated with the management
of the IMSI resource and oversight of IMSI administration. The forum that was formed by industry
consensus in 2001 is the IMSI Oversight Council (IOC), a committee of the Alliance for
Telecommunications Industry Solutions (ATIS). This document defines the procedures by which
the IOC shall operate, including its scope, mission, responsibilities, participants, organization,
operational procedures, and interworking.

In 2018, the need for IMSIs for use in the Citizens Broadband Radio Service (CBRS) Spectrum
was identified. CBRS is licensed, but shared (i.e., not license for exclusive use) and thus may have
a broad range of users (operators) and use cases (malls, enterprise, stadiums, apartment buildings,
etc.). Because the spectrum is not exclusive use, spectrum users do not directly attain FCC
licenses; instead, the users acquire base stations certified as compliant with the FCC rules (FCC
Title 47, Code of Federal Regulations, Part 96). The base stations must then register with a
Spectrum Access System (SAS), which verifies the base station is certified and operates in
compliance within the FCC rules.
The IOC developed a process for allocating blocks of IMSIs (IMSI Block Numbers or IBNs) for
the CBRS Spectrum users.

3
CTIA is now known as CTIA – The Wireless Association; PCIA is now known as PCIA – The Wireless
Infrastructure Association.

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B-2 MISSION, SCOPE, AND RESPONSIBILITIES

The IOC is an open industry forum serving the needs of the telecommunications industry regarding
the management and administration of IMSIs and IBNs. It has the following scope and mission.

B-2.1 Mission
The IOC is responsible for the management and oversight of the administration of IMSIs and
IBNs in the United States.

B-2.2 Scope
The IOC will maintain and ensure compliance with the IMSI Assignment and Management
Guidelines and Procedures and the International Mobile Subscriber Identity (IMSI) Assignment
and Management Guidelines for Shared HNI For CBRS Range documents to ensure that they meet
the evolving needs of the U.S. telecommunications industry, oversee the performance of the IMSI
Administrator (IMSI-A), and perform the specific responsibilities assigned to it by these Operating
Procedures and the IMSI Assignment and Management Guidelines and Procedures.

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B-3 IOC MEMBERSHIP AND ORGANIZATION

B-3.1 Membership and Participation

The IOC is an open industry forum. Any organization, company, or group within the U.S.
telecommunications industry that is materially affected by the management and administration of
IMSI and IBN resources may become a member of the IOC. Membership in the IOC is not
required for IMSI or IBN assignment or maintenance and non-members may attend meetings and
participate or raise issues for consideration by the IOC membership. Participants, however, have
an obligation to be prepared to discuss the issues/appeals, and to cooperate in moving
issues/appeals forward efficiently. Non-member participants may not participate in consensus
decisions or voting processes.

B-3.1.1Membership
Membership in the IOC shall be initiated by an organization, company, or group through
the submission of written correspondence to the IOC Secretariat. This correspondence
shall include: (1) a statement that the applicant is materially affected by the management
and administration of IMSI resources in the United States; (2) the organization, company
or group’s contact information; and (3) the contact information for the organization’s,
company’s or group’s Voting Participant.

B-3.1.2Voting Participants
Each IOC Member shall identify a Voting Participant as that company/organization’s
primary contact for the IOC. IOC participants will bear their own time, travel, and living
expenses. More than one representative or subject matter expert from each Member may
attend IOC meetings but only the Voting Participant identified to the IOC Secretariat prior
to the start of an IOC meeting may participate in consensus decisions or voting processes.

B-3.2 IOC Chairperson

A Chairperson will provide leadership to the IOC. The Chairperson will be a representative of the
IMSI-A’s organization, which will nominate the person for the consideration of the IOC. The IOC
will either confirm or deny the nomination. If denied, the IMSI-A’s organization will consult
further with the IOC membership to identify a mutually acceptable nominee.

B-3.2.1
The Chairperson, as a representative of the IMSI-A’s organization will be a non-voting
member of the IOC and will recuse himself/herself from any deliberations directly
involving or impacting the IMSI-A, e.g., assignment appeals.

B-3.2.2
The Chairperson, as both a representative of the IMSI-A’s organization and the
Chairperson, can present the IMSI-A’s perspective on issues/appeals before the IOC, but
must clearly preface such presentations as being those of the IMSI-A and not of the
Chairperson.

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B-3.2.3
The Chairperson will be supported in his/her responsibilities by the IOC Secretariat. The
responsibilities of the IOC Chairperson include, but are not limited to:
• convening, preparing agendas for, and chairing all meetings of the IOC,
• conducting IOC meetings in a fair and impartial manner, so that the views of
all participants will be heard and discussed, and
• determining when consensus is achieved on an issue/appeal under IOC
discussion.

B-3.3 IOC Secretariat

The Alliance for Telecommunications Industry Solutions will assign a staff member to serve as
IOC Secretariat and will ensure that the IOC functions effectively. The IOC Secretariat will attend
all meetings and have primary responsibility for carrying out the directives of the IOC, including
the day-to-day management of its activities under the direction of the IOC Chairperson. The IOC
Secretariat will ensure that the IOC abides by these Operating Procedures and may facilitate IOC
meetings in the absence of the Chairperson.

B-3.3.1
The responsibilities of the IOC Secretariat include, but are not limited to:
• logistical arrangements for meetings,
• recording of participation at IOC meetings, and maintaining the IOC Member and
Voting Participant lists,
• maintain all IOC records,
• maintain and update the IOC web site (on the ATIS host),
• bill and collect the annual HNI maintenance fees (see Section 6 of the IMSI
Assignment and Management Guidelines and Procedures),
• management and tracking of issues/appeals under consideration by the IOC,
• preparation and distribution of meeting notes and records in a timely manner,
• work closely with the IOC to identify problem areas and develop and implement
appropriate action plans to address these concerns,
• provide periodic reports on IOC costs to determine appropriate funding for
Secretariat support,
• represent and speak on behalf of the IOC at both national and international
conferences, seminars and meetings as well as before government organizations
and agencies at the direction of the IOC, and
• support the Chairperson and IOC function, as reasonably required.

B-3.4 Joint Responsibilities of the IOC Chair and IOC Secretariat

B-3.4.1
The following are joint responsibilities of the IOC Chairperson and the IOC Secretariat:
• attempting to ensure that there is an adequate representation of the various
industry perspectives on issues/appeals before the IOC,
• providing technical regulatory support with regard to the issues/appeals before the

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IOC, and
• ensuring that the appropriate subject matter experts and/or documentation are
available at IOC meetings for the proper and complete discussion of meeting
agenda items.

B-3.5 IOC Organization

B-3.5.1
The IOC may establish working groups to address and resolve specific issues. Each such
working group should have one or more elected leaders (co-chairpersons), whose
responsibility it will be to lead the working group toward the resolution of the assigned
issue using a consensus process, and to report the working group’s work status and
conclusions to the IOC.

B-3.5.2
The IOC may establish and maintain an advisory group of IOC Members to provide
advice to the IOC Secretariat regarding the functioning of the IOC. Members of the
advisory committee shall be selected by the IOC Secretariat in consultation with the IOC
Chairperson.

B-4 IOC RESPONSIBILITIES

B-4.1
The IOC’s primary responsibilities include, but may not be limited to (not listed in any order of
priority):
• in cooperation with the IMSI-A, educate the telecommunications industry, regulators
and other interested parties regarding the structure, proper use and management of
IMSIs through the operation of the IOC web site, the provision of the IMSI
Assignment and Management Guidelines and Procedures, and through other means,
• accept and resolve IMSI-related issues referred to it by an affected
telecommunications entity or the IMSI-A in a timely and responsible manner through
the consensus process,
• accept and resolve all referred Home Network Identifier (HNI) and IMSI Block
Number (IBN) assignment-related appeals in a timely and responsible manner and in
accordance with the IMSI Assignment and Management Guidelines and Procedures
and the International Mobile Subscriber Identity (I M S I) Assignment and
Management Guidelines For Shared HNI for CBRS Range,
• review and resolve all referrals of alleged HNI non-use or alleged misuse, i.e., non-
conformance with the IMSI Assignment and Management Guidelines and Procedures
or the International Mobile Subscriber Identity (I M S I) Assignment and
Management Guidelines For Shared HNI for CBRS Range,
• receive proposals for the modification of the IMSI Assignment Guidelines and
Procedures, determine the appropriateness of the proposed modification and, if
deemed appropriate, make modifications and publish the resultant new version,
• oversee the administration and management of IMSIs and IBNs, including the IMSI-

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A, in the U.S.,
• respond to queries requesting an interpretation of the content of the IMSI Assignment
and Management Guidelines and Procedures or the International Mobile Subscriber
Identity (I M S I) Assignment and Management Guidelines For Shared HNI for CBRS
Range,
• determine the amount of the HNI application and maintenance fees to be paid by HNI
applicants and assignees,
• interface with the U.S. Department of State, as appropriate, regarding IMSI
administration and management (the Department is the governmental entity
responsible for interfacing with the ITU-T with regard to the assignment of IMSIs in
the U.S.), and
• interface and initiate liaisons with other industry or regulatory bodies affecting the
management and administration of IMSIs in the U.S., as appropriate.

interface and initiate liaisons with other industry or regulatory bodies affecting the management
and administration of IMSIs in the U.S., as appropriate.

B-4.2
The IOC may, if consensus is reached to do so, undertake additional responsibilities, within the
bounds of the mission and scope regarding IMSIs, in the interest of the U.S. telecommunications
industry.

B-4.3
The existence of the IOC, including its policies and procedures, does not interfere with the right
of any telecommunications entity to refer or appeal matters to regulators or appropriate
government agencies. The IOC does not supersede the authority, rules, or procedures of any
appropriate U.S.-based telecommunications regulatory entities.

B-4.4
The IOC will perform its responsibilities in accordance with the IMSI Assignment and
Management Guidelines and Procedures and in a consensus-based manner.

B-5 IOC FUNDING

B-5.1
Annual maintenance fees assessed on HNI and IBN assignees will fund the functions necessary
for the IOC to perform its responsibilities, e.g., Secretariat, web site.

B-5.2
The IMSI-A will be funded by HNI and IBN application fees and a negotiated portion of the IMSI
maintenance fees. The application fee will be reviewed annually and modified, by mutual
negotiation between the IOC and the IMSI-A’s organization, to reflect a cost plus reasonable profit
algorithm.

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B-5.3
Maintenance and HNI and IBN Application fee modification requests from Secretariat and/or the
IMSI-A may on occasion be needed and will be reviewed by the IOC and either accepted or denied
based on consensus as defined in 6.3.3 of the IOC Operating Procedures.

B-6 IOC OPERATIONAL PROCEDURES

B-6.1 Issue and Appeal Identification

B-6.1.1
Any IOC Member, HNI applicant/assignee, IBN applicant/assignee, liaisons from
external fora, the IMSI-A or the IOC Secretariat may introduce issues/appeals to the IOC,
either on their own behalf or on the expressed behalf of the issue/appeal originator in
their absence. Each issue/appeal to be addressed by the IOC should be submitted on an
IOC Issue/Appeal Identification Form (Attachment I). The completed form should
contain:
• the name of the issue/appeal originator/advocate,
• a clear, concise statement of the issue/appeal, and
• a proposed resolution, if appropriate.

B-6.1.2
Only issues/appeals relating to the content of the IMSI Assignment and Management
Guidelines and Procedures, the International Mobile Subscriber Identity (I M S I)
Assignment and Management Guidelines For Shared HNI for CBRS Range and/or in
conformance with the IOC scope and mission will be accepted for resolution by the IOC.

B-6.1.3
Completed issue/appeal identification forms should be submitted to the IOC Secretariat at
any time but no later than two (2) weeks prior to a meeting. The Secretariat will log the
issue/appeal, post it to the IOC web site, and send an email message to all IOC members
announcing its posting.

B-6.1.4
Completed issue/appeal identification forms received after the two (2) week period,
including at an IOC meeting, will be handled at the meeting only with the consensus
concurrence of the IOC Members present at the meeting.

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B-6.2 IOC Meetings

B-6.2.1
Scheduled IOC meetings will occur annually. The consensus of the IOC can modify this
schedule as appropriate.

B-6.2.2
If the IOC Secretariat receives an IOC Issue/Appeal Statement Form two (2) months or
more prior to the next scheduled meeting, it will confer with the IOC Chairperson to
determine if the issue/appeal is sufficiently urgent to warrant an Ad Hoc meeting of the
IOC to discuss and resolve the issue/appeal (most appeals would automatically qualify
for urgent resolution).

B-6.2.3
The IOC Secretariat will make arrangements for all meetings (scheduled or Ad Hoc), and
will notify the IOC membership list of the meeting logistics by email at least two (2)
weeks prior to the meeting. The pre-meeting information should also include any relevant
information necessary for the participants to be prepared for the meeting, e.g., new
issue/appeal statements.

B-6.3 Issue and Appeal Resolution

For each issue/appeal discussed at the meeting, participants will have received, in advance, both
the Issue/Appeal Identification Form and notice that the issue/appeal is on the meeting agenda
for discussion. Thus, participants should come to the meeting prepared to state their positions
and assist the IOC in moving the issues/appeals quickly toward resolution.

B-6.3.1
During the meeting, each issue/appeal will be discussed in sequence, as dictated by the
agenda. As each issue/appeal is introduced by its originator (or designated
representative), other participants will have a chance to introduce their related
contributions.

B-6.3.2
For each issue/appeal, after the initial issue/appeal statements and all contributions have
been introduced, the Chairperson will lead the group towards agreement on a work plan
to resolve the issue/appeal. To develop the work plan and to resolve the issue/appeal, the
IOC will use the consensus process developed and refined by the industry over many
years:
Consensus is established when substantial agreement has been reached among
those participating in the issue at hand. Substantial agreement means more than a
simple majority, but not necessarily unanimous agreement.

Consensus requires that all views and objections be considered, and that a
concerted effort be made toward their resolution. Under some circumstances,
consensus is achieved when the minority no longer wishes to articulate its
objection. In other cases, the opinions of the minority should be recorded with the

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report of the substantial agreement, or consensus, of the majority. 4

B-6.3.3
The Chairperson will first attempt to identify all reasonable solutions to the issue/appeal.
Once all reasonable solutions have been identified, the IOC will work towards consensus
agreement on the best of the solutions.

B-6.3.4
When consensus is reached, new text will be drafted for the IMSI Assignment and
Management Guidelines and Procedures and/or the International Mobile Subscriber
Identity (I M S I) Assignment and Management Guidelines For Shared HNI for CBRS
Range if revision of the document is appropriate. This new text can be derived from
contributions or developed by consensus during an IOC meeting.

When the consensus reached does not require new text, but the consensus is with regard
to an issue/appeal referred to the IOC, the IOC will inform the issue/appeal originator of
its conclusion. This information will be sent to the originator in the form of an IOC letter
jointly signed by the Chairperson.

B-6.3.5
All agreements and resolutions regarding issues/appeals referred to the IOC will be
documented in meeting notes, which will be made available to all IOC participants, and
will be posted on the IOC web site.

B-6.3.6
Once consensus is reached on textual modifications to the procedures, the revised
document will be posted on the IOC web site for IOC membership comment. If the
received comments are editorial in nature, the Secretariat will make the appropriate
revisions and forward the final document to all IOC participants and to the IMSI-A for
industry wide distribution. If the comments received by the Secretariat are substantive in
nature, the IOC must be reconvened in order to resolve the substantive comments. The
comment cycle will be 21 days.

B-6.3.7
In spite of due diligence on the part of the Chairperson and the IOC Membership, there
may be issues/appeals on which it is not possible to reach consensus. In such cases, the
IOC Chairperson may refer the issue/appeal, as documented, to the appropriate federal
agency for consideration, guidance, or resolution.

B-6.3.8
To ensure that all Members have had an adequate opportunity to study and comment on
each issue/appeal, the IOC generally should not reach resolution on any issue/appeal that
is not included in the agenda, announced in advance of the meeting.

4
These paragraphs have been abstracted for the Operating Procedures from ATIS Forums and Committees.

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B-6.4 IOC Meeting Notes

B-6.4.1
The IOC Secretariat will record meeting participation and notes.

B-6.4.2
Meeting notes will address the items discussed at the meeting, significant points noted
during discussion, any agreements reached, and action items. The meeting notes, as
containing the above sections, will be reviewed and approved during the meeting. The
final meeting notes will be posted to the IOC web site within ten (10) working days of the
end of the meeting.

B-6.4.3
A list of all documents will be posted on the IOC web site and retained by the Secretariat.

B-7 REVISIONS TO THE OPERATING PROCEDURES

These Operating Procedures are maintained by the IOC Secretariat. Proposed revisions to these
Operating Procedures may be submitted in writing by any IOC member to the IOC Secretariat
along with supporting rational for the proposed change. The IOC Secretariat will present the
proposed revisions to the IOC membership for review and consideration. Changes to the Operating
Procedures must be approved by consensus and will be effective upon publication.

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International Mobile Subscriber Identity (IMSI) Assignment and B-11
Management Guidelines and Procedures

Attachment 1 -- IOC ISSUE/APPEAL IDENTIFICATION FORM

(See Section 6.1 of the IOC Operating Procedures for information regarding the completion and
submission of this form)

1. Issue/Appeal Title:
________________________________________________________________________

2a. Originator: 2d. Date Submitted:

2b. Company: 2e. Appeal/Issue Number:

2c. Phone/Fax: 2f. Resolution Date:

3. Issue/Appeal Statement:

4. Suggested Resolution:

5. Issue/Appeal Status (per meeting):

6. IOC Resolution:

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