Via ECFS
Marlene Dortch, Secretary
Federal Communications Commission
Dear Ms. Dortch:
Rebekah Johnson, Founder & CEO of Numeracle, Inc., ("Numeracle") and Keith Buell, General Counsel and Head of Global Public Policy for Numeracle, met with FCC officials on April 7, 2026, to urge the Commission to take decisive regulatory action to require verified identity delivery in voice communications as the essential, missing element in the Commission's anti robocall strategy as a matter of fraud prevention and bolstering national security. Accurate delivery of verified caller identity should be a baseline function of America's telecommunications networks and not an add-on premium service intended for telemarketers.
Numeracle’s three meetings included: (1) Commissioner Anna Gomez and her Chief of Staff Deena Shetler; (2) Marcus Maher, Legal Advisor for Commissioner Trusty; and (3) Eduard Bartholme, Bureau Chief, Consumer and Governmental Affairs Bureau; Mark Stone, Deputy Bureau Chief, Consumer and Governmental Affairs Bureau; Aaron Garza, Legal Advisor, Consumer and Governmental Affairs Bureau; Wesley Platt, Chief, Consumer Policy Division, Information Access, & Privacy Office, Consumer and Governmental Affairs Bureau; John B. Adams, Special Counsel, Consumer and Governmental Affairs Bureau; Chris Laughlin, Deputy Division Chief, Competition Policy Division, Wireline Competition Bureau; Cara Voth, Deputy Bureau Chief, Wireline Competition Bureau; and Richard Smith, Attorney Advisor, Consumer and Governmental Affairs Bureau.
An international consensus is rapidly emerging among regulators, standards bodies, carriers, and technology providers that verified caller identity delivery is essential to preserving trust in voice networks and preventing their continued exploitation as a primary conduit for fraud. Across global forums and industry initiatives, stakeholders increasingly agree that without a reliable mechanism to authenticate and convey the true identity of the calling party to end users, voice communications will continue to degrade in utility and credibility. Yet despite this alignment on the problem and the solution, progress has been slow—hampered by disagreement over governance models, standards, and the allocation of costs and revenues across the ecosystem. Absent decisive regulatory leadership, these disagreements risk delaying implementation until consumer trust has eroded beyond repair. The Commission’s action is therefore urgently needed to establish a clear framework, align incentives, and accelerate deployment of verified identity delivery before it is too late to restore the integrity of the voice network.
Numeracle urges the Commission to adopt the roadmap in Exhibit A. In summary, the roadmap establishes a comprehensive, phased framework for verified identity delivery built on three core requirements: (1) independently verified caller identity conducted by accredited third-party identity verifiers combined with robust Know Your Customer (KYC) processes; (2) secure, end-to-end transmission of that identity, cryptographically bound to the call and preserved across networks; and (3) standardized, spoof-resistant display of verified identity at the device level. The framework further provides FCC oversight of governance and accreditation, mandatory flow-down of identity and KYC requirements across all upstream providers, safe harbor protections for compliant carriers, prohibition of charging for delivery of verified identity to consumers by terminating providers, and a phased implementation timeline to enable industry adoption while eliminating insecure legacy identity mechanisms.
Numeracle notes that 2026 marks the ten-year anniversary of the FCC Robocall Strike Force and that robocalls remain the number one consumer complaint in telecommunications. Despite years of regulatory effort and marginal progress through industry-led efforts, consumers have lost trust in the voice network. Fraud thrives in anonymity, and verified identity delivery is the single most effective step the Commission can take to protect consumers and restore that trust.
No single tool will eliminate robocalls and fraud entirely, but verified identity is the foundation without which none of the Commission's other tools can succeed. The Commission has already taken many of the hardest foundational steps, and the technical tools have been developed. What is needed now is the Commission's regulatory mandate to implement verified identity delivery. Numeracle has advocated for verified identity delivery consistently for seven years, including in ex parte filings dating back to 2019.
Numeracle emphasized that while the Commission’s work on STIR/SHAKEN was an important and necessary foundation, STIR/SHAKEN only verifies the carrier that signed a call—not the identity of the caller. A call can receive an “A” attestation even when the actual caller’s identity is unknown to the signing carrier. Abuse of A-level attestation standards is rampant, showing that carriers should not be inherently trusted to perform their own KYC without independent oversight. STIR/SHAKEN enables traceback to a voice provider; it does not prevent impersonation or provide call recipients with meaningful information about who is actually calling them. These are exactly the gaps that verified identity delivery is designed to fill.
Numeracle presented a framework for verified identity delivery built on three foundational pillars:
A verified identity framework requires not only technical standards but also a durable governance structure. Numeracle presented four elements of a governance framework necessary to support verified identity delivery at scale:
Numeracle noted that verified identity delivery in voice communications is an emerging global priority. Numeracle recently participated in a GSMA proof of concept for Open Verifiable Calling demonstrated at Mobile World Congress, showing demand from carriers, enterprises, device manufacturers, and consumers worldwide. If the United States does not act promptly, standards for verified identity display will be developed by other jurisdictions. Consistent with Chairman Carr’s emphasis on U.S. leadership in communications infrastructure and national strategic competition, Numeracle urged the Commission to act now to define the global standard for trusted communications.
Robocalls and robotexts are not merely a nuisance—they are a major fraud ecosystem with serious national security implications. The Global Anti-Scam Alliance has reported that the annual, global volume of fraud exceeds $1 trillion, much of which was committed using telecommunications channels.1 The FTC reported $12.3 billion in fraud losses in just the first nine months of 2025, with calls and texts remaining key entry points for scammers. These fraud proceeds frequently fund organized criminal enterprises, including human trafficking networks and international fraud rings.
The proliferation of AI-powered fraud tools has made the problem significantly worse even if the volume of calls has not continued to increase. Voice cloning, deepfake technology, and AI generated scripts make it trivially easy to convincingly mimic trusted brands, company representatives, or even family members. As businesses deploy AI-powered communications assistants, consumers need assurance that they are interacting with a verified, trusted source—not a convincing AI impersonation of their bank or government agency. Fraudsters are also leveraging breached personal data to create highly personalized scams that defeat legacy pattern based defenses, making cryptographically verifiable caller identity essential rather than optional.
The President has expressly recognized impersonation-driven fraud as a central threat to American citizens and to the integrity of U.S. communications. In Executive Order 14390, released earlier this month on March 6, 2026, the President identified “impersonation” schemes, phishing, and the misuse of stolen identities as core components of modern cybercrime, describing a global “shadow economy fueled by stolen identities” and directed federal agencies to prevent and disrupt these activities.2 Active FCC involvement is essential to fulfill the President’s objectives.
The cumulative effect of this fraud ecosystem is that consumers are losing trust in the voice network itself. Most Americans now ignore unknown calls, which means that even critical and legitimate calls go unanswered. This erosion of trust in the PSTN has broad public safety implications—it impairs emergency communications, public health outreach, and legitimate business communications alike. As Chairman Carr has emphasized, U.S. telecommunications infrastructure is a matter of national strategic competition, and the integrity of that infrastructure depends on restoring consumer trust through verified identity.
A decade of regulatory flexibility has not solved the robocall problem. Since the FCC Robocall Strike Force was convened in 2016, carriers have consistently argued that a light-touch approach would allow industry to self-determine the most effective solutions. That approach has failed. Robocalls remain the number one consumer complaint in telecommunications, countless billions of dollars are lost to voice and messaging scams each year, and consumer trust in the voice network has continued to decline as users migrate to conference platforms like Microsoft Teams and Zoom, or to over-the-top applications like WhatsApp and FaceTime for personal calls.
Numeracle noted that industry stakeholders have been slow to implement verified identity delivery absent a regulatory mandate, and the disjointed and overpriced marketplace disincentivizes call originators to participate. Terminating carriers in particular benefit from the current system and are currently treating identity delivery—both secured and unsecured—as a high-margin revenue opportunity by charging rates that far exceed the cost of implementation and that disincentivize widespread adoption of verified identity frameworks. As the Commission moves to bill-and-keep for inter carrier compensation, the Commission should not allow charges for verified identity delivery to replace legacy intercarrier compensation cash flows.
Numeracle’s mission is that every entity on Earth and every person on the planet should know with certainty who is calling. That principle should guide the Commission’s policy framework for voice communications and trusted network integrity in the United States. Numeracle appreciates the Commission’s leadership and the opportunity to collaborate on these issues. Verified caller identity must rest on a foundation of trust, robust KYC standards, and a governance framework. Numeracle stands ready to support the Commission in this effort and urges prompt action consistent with the framework set forth in Exhibit A.
The Commission should:
Keith Buell, General Counsel and Head of Global Public Policy
