Via Electronic Filing
Ms. Marlene H. Dortch, Secretary
Federal Communications Commission
445 12th Street, S.W.
Washington D.C., 20554
Dear Ms. Dortch:
On February 11, 2020, Rebekah Johnson, CEO of Numeracle, Inc. met with Mark Stone, Jerusha Burnett, Patrick Webre, Mika Savir, Aaron Garza, Kristi Thornton and Kurt Schroeder of the Consumer and Governmental Affairs Bureau. The purpose of the meeting was to discuss the challenges with SPAM labeling of calls from legal callers who have consent and the effectiveness of the redress process with major carriers.
Numeracle is the pioneer in entity and number vetting services to assist with visibility and management of call blocking and labeling. In working with major voice service providers, leading analytics providers, hundreds of call originators, and multiple industry associations, Numeracle provides the verified identity and call intent of numbers at no cost to carriers and/or analytics providers to improve the accuracy of analytics.
Challenge to Remove SPAM For Vetted Callers withConsent Regardless of Industry
Numeracle presented the impact on the lack of guidance to carriers for the identification of SPAM numbers. Numeracle covered the challenges faced by all call types whether informational, payment reminder, debt collection or life and safety. In reference to Numeracle’s comments 1, it was noted there continues to be major disparity in analytics ability to properly identify calls as SPAM. Even with a redress process through an entity vetting solution provider like Numeracle, legal entities must conduct one on one calls with the carriers and/or their analytics providers to discuss possible removal of SPAM labels. The common response from carriers and analytics is to “change their calling pattern.” Unfortunately, changing the calling pattern to accommodate one carrier could create a SPAM rating for another carrier. This inability to have SPAM removed for vetted entities willing to share their identity and regulatory compliance practices results in vetted entities needing to rotate through numbers or switch traffic to a number not labeled SPAM.
Need for Effective Redress Process for Vetted Callers
For the current redress process on the Verizon, Sprint, T-Mobile and AT&T wireless network, Numeracle covered the legal caller redress experience for each. For a legal caller, they would complete the process for each carrier in order to know how the carriers are rating their numbers.
T-Mobile utilizes First Orion as their analytics provider of call blocking and labeling for subscribers. Through https://calltransparency.com/, an entity will create an account and upload one or many numbers for registration. Upon successful vetting of the entity and numbers, the entity will receive an email from Call Transparency of the before and after labeling of Fraud, Nuisance or lower ratings. This report will also include adjustments made where the rating was reduced due to the entity and their numbers passing the vetting process.
Verizon’s redress process is completed at the following website https://voicespamfeedback.com/vsf/. There is no account creation or feedback mechanism. The entity uploads a file with phone numbers and the numbers will be provided to Verizon’s third-party provider.
Sprint’s redress process is supported through Transaction Network Services via this website: https://reportarobocall.com/trf/. There is no account creation or feedback mechanism. The entity uploads a file with phone numbers and the numbers will be provided to Verizon’s third-party provider.
AT&T’s redress process is supported through Hiya via this website https://hiyahelp.zendesk.com/hc/en-us/requests/new?ticket_form_id=824667. In order to challenge a number that has been improperly labeled, the legal entity must know in advance which of their numbers are labeled Fraud or Spam by AT&T’s Call Protect before the redress processing can begin.
In the TRACED Act, the Commission was charged to take a final agency action to ensure the robocall blocking services provided on an opt-out or opt-in basis are provided with transparency and effective redress options for callers 2, such as those vetted by Numeracle. An effective redress process includes the following:
1. Verification of the legal identity of the entity seeking redress
2. Proof of ownership or authorization of use to the vetted entity for the number
3. For vetted entities, the following information provided to the vetted entity at no cost:
a. Number rating before and after redress process
b. Length of time the number was marked a Fraud or Spam Rating before correction
c. Removal and prevention of Fraud/Scam Rating of registered numbers
d. Rating reduced to Low for any numbers marked as Spam or other negative labels such as Robocaller
Based on Numeracle’s experience providing vetting and number verification services, fraudulent actors and those with disregard for compliance with the law will attempt to use the redress process to register and possibly rotate numbers marked SPAM. The requirements for a transparent and effective redress process should make strong attempts to prevent bad actors from accessing such information.
Founder & CEO
P.O. Box 2523
Arlington, VA 22202
1. See Comments of Numeracle, Inc. CG Docket No. 17-59, (January 31, 2020) (“Numeracle, Inc”)
2. Pallone-Thune TRACED Act, S.151, 116th Cong. (2019) (“TRACED Act”).