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Before the Federal Communications Commission
Washington, D.C. 20554
In the Matter of: Advanced Methods to Target and Eliminate Unlawful Robocalls; Call Authentication Trust Anchor
CG Docket No. 17-59; WC Docket No. 17-97
Date posted:
January 31, 2020

Numeracle, Inc. (“Numeracle”) hereby files comments in response to theFederal Communications Commission’s (“FCC” or “Commission”) request for input on call blocking in CG Docket No. 17-59 and WC Docket No. 17-97. Numeracle fully supports the Commission’s efforts to protect consumers from illegal robocalls while at the same time encourages the Commission to protect legal and wanted calls from erroneous labeling and blocking.

 

I.        About Numeracle’s Services and Our Vetted Entities 

Numeracle’s unique contribution to the fight against illegal and unwanted robocalls is our vetting and verification process for identifying entities and their associated numbers used to originate legal and wanted calls. For those voice service providers and analytics interested in improving the accuracy of call blocking and labeling, Numeracle offers this data at no cost but requires data privacy and protection commitments. Numeracle has vetted more than 150entities using approximately 300,000 numbers in 15 industries. These entities are from the following industries:

1) Life and Safety
2) Safety Recall 
3) Telecommunications or Cable
4) Insurance
5) Resort and Travel
6) Accounts Receivable or Debt Collection
7) Payday Loans
8) Student Financing & Admissions
9) Lease and Rentals
10) Retail
11) Medical Device
12) Survey, Research, Polling
13) Financial Investment
14) Home Security
15) Charity, Nonprofit

Numeracle has been providing vetting and registration services for more than two years.

In working with major voice service providers, leading analytics providers, hundreds of call originators, and multiple industry associations, we have identified trends, data points, challenges, and successes. To support the Commission’s effort to evaluate the effectiveness of call blocking tools and impact of FCC actions, we are providing our insights and trends below based on vetted entities and their numbers.

Before taking on a company as a client, Numeracle requires each entity to complete a comprehensive verification of identity, business status validity, and evaluation of regulatory or legal enforcement preventing the entity or business executives from operating a call center.

Numeracle’s vetting includes additional data points that we do not want to reveal publicly.Thus far, Numeracle has rejected entities that sought registration that did not meet Numeracle’s strict standards. Other entities abandoned Numeracle’s vetting process when they saw the detailed information that Numeracle required.Numeracle has worked cooperatively with analytics providers to investigate any suspicious patterns. Numeracle has the unique perspective of seeing how all the major analytics providers view a caller’s traffic. We have zero tolerance for illegal callers seeking to benefit from using our services.

In fact, Numeracle’s clients suffer harm from illegal callers in their industries. By submitting to vetting, disclosing their numbers and call intent, and establishing their identity around a static set of numbers (rather than spoofing and rotating), Numeracle’s clients are saying “here I am—if you have a problem with my calls, you know where to find me.” For example, Numeracle’s clients do include vacation sales that operate with signed written consent of the call recipient. They are harmed by illegal callers using their names and trademarks without permission. Industry’s efforts to battle illegal robocalls should not work against law abiding entities using voice communications legally and with customer consent.

Similarly, Numeracle’s clients include accounts receivable and debt collectors.

Although some call recipients complain about such calls, Numeracle’s clients commit to operating within the strict regulatory regime of the Fair Debt Collections Practices Act. The anti-illegal robocall industry efforts should encourage debt collectors to reveal their phone numbers and calling practices to ensure accurate labeling so that customers who are inadvertently behind on payments receive prompt notification so they can reconcile their accounts before their credit score is harmed or more serious action is taken.

 

II.        Accuracy of Analytics

Nobody currently has any reliable data about false positives. All the analytics can do to evaluate their accuracy is to compare their results to their own analysis. This is circular.

Numeracle has unique information about its clients’ ratings from each analytics provider, but lacks data about call volumes to each carrier that would be necessary to establish an accuracy rating for Numeracle’s clients. The accuracy of false positives for other entities that are not Numeracle clients is a giant question mark.

The analytics entities have touted false positive rates in the low single digits, but those are based on falsely labeled phone numbers rather than phone calls. Numeracle’s experience is that the worst fraud and spam ratings from analytics are usually associated with callers’ highest volume outbound numbers. Numeracle cannot provide an exact percentage of its customers’ calls subject to adverse ratings because it varies constantly by call originator and the scoring changes daily.

Numeracle’s experience has shown that the following data is needed to properly evaluate the effectiveness of call blocking and labeling as it relates to false positives:

• Vetted entities and the associated verified numbers, as established by a trusted vetting agent such as Numeracle

• Volume of calls delivered by the vetted entity across verified numbers

• Volume of calls identified by the voice service provider for a given time period labeled fraud or spam

Numeracle has the first data point above for its customers. The second data point could be provided by some callers, carriers, or the analytics providers. But the final data point is uniquely within the knowledge of the analytics providers. The Commission cannot get reliable data on the subject without combining all three data sources. Numeracle is conscientious about the need for analytics providers to avoid revealing their methods in a way that benefits illegal callers. But Numeracle thinks a targeted data collection with appropriate privacy protections by the Commission would be invaluable at revealing the impact of false positives on legal callers.

The Commission’s 2019 Call Blocking order authorized carriers to block calls based on a loosely defined standard, and the Commission should gather more accurate data to evaluate whether carriers and analytics providers are getting it right.

Numeracle works with legal callers, analytics providers, and voice service providers to correct inaccurate labeling. Numeracle’s unique perspective into all aspects of call rating—from vetting to rating—has revealed the following:

•       Inconsistency across analytics in identifying the risk rating of a number for vetted and verified numbers. The data in the appendices shows the widely differing ratings from the analytics providers of the same phone numbers making the same types of calls.

•       Analytics providers defend their fraud or spam label, claiming that the negative rating was due to spoofing of vetted entity numbers rather than bad calls by the vetted entities themselves. But the analytics providers have rarely been able to back up their claims that the negative rating was due to illegal spoofing.

•       Analytics providers and voice service providers recommend changing call patterns, reducing volume, and, ironically, using both more individual numbers and less.These recommendations do not align across all analytics providers, therefore making it impossible to have one corrective action for one voice service provider and another corrective action for another voice service provider. Callers do not know which carrier or analytics provider their customers use.They just want their legal calls to go through without inaccurate labeling or blocking regardless of which carriers route the call.

•       Analytics providers weigh complaint volumes for a phone number without looking at associated call volumes. In one example, a vetted and verified entity delivered more than 100,000calls across a single number in a single month. The number was labeled Spam due to less than 50 consumer complaints for that number covering multiple months.Although customer complaints can be useful in evaluating a number’s reputation at a specific point in time, number reassignment and customer confusion renders complaint evaluation problematic if the analysis is no more sophisticated than counting complaints for an individual number.

•       The voice service providers and analytics providers do not know when a number is reassigned to a different entity, therefore creating a history for a number that may not be related to the current entity originating calls.

Call originators have a strong desire and incentive to be vetted by a third-party provider such as Numeracle, to have their identity vetted and numbers verified in exchange for sharing of numbers and call intent with analytics providers and voice service providers. The Commission’s 2019 CallBlocking Order stated that voice service providers must provide redress for inaccurate labeling and blocking. Vetted callers are eager to establish their identities and cooperate with voice service providers and analytics providers to avoid errors and provide information to call recipients about who is calling and why. 

Vetted entities are providing this data to assist in accurate call labeling and blocking, but their data is sometimes being resold by the analytics providers and voice services providers.

Voice service providers are in the process of creating services that will charge legal callers for accurate call delivery and name display. The Commission should not permit voice service providers to take advantage of their own inaccuracies as a revenue source. Callers are willing to provide this information and be vetted, and the resulting verified identity should be passed at no cost to the subscriber. Anything less is just plain extortion.

The current practices incentivize callers to monitor their risk ratings and change numbers when a particular number has acquired a bad rating. This is an inefficient use of limited voice numbers, but, more importantly, it encourages callers to hide in the shadows rather than affirmatively state their identities and associated numbers. Illegal and unwanted callers are doing this today, and the entire calling industry—both legal and illegal—is engaged in evasive practices designed to avoid tripping the analytics providers triggers. Instead, the Commission should encourage callers to verify their identities and use phone numbers efficiently. This race to the bottom is characterized by these practices that Numeracle has observed:

•       Attempts by callers to register numbers multiple times with the same analytics providers.

•       Increased rotation of numbers in an attempt to acquire “clean” numbers. 

•       Utilizing services that do not require rigorous vetting of the entity or ownership of numbers to obtain risk ratings indirectly or directly from analytics and voice service providers. Call originators will immediately reduce volume or drop the number out of rotation when their numbers are labeled Fraud or Spam.

•       Distribute call volume across larger set of numbers to reduce volume of calls per number.Both legal and illegal callers are doing this to avoid spam labels. Not only is this an inefficient use of phone numbers, it also reduces analytics accuracy because, absent registration that can link multiple numbers to the originating caller, the analytics providers view the world one number at a time.

The Commission should require carriers and their analytics partners to work with legal callers and their agents to establish a mechanism to ensure that all legal calls to reach their intended recipients. The Commission can do that by making sure that working with legal callers and providing a redress mechanism for improper labeling and blocking is an essential element of the“reasonable analytics” the Commission has required to justify blocking. 

Numeracle supports the Commission’s actions to address the scourge of illegal robocalls. 

Numeracle will continue to work with the Commission and the industry to reduce illegal and unwanted calls while preserving the use of the voice channel for critical and legal calls.

Respectfully submitted,

NUMERACLE

Rebekah Johnson
Founder & CEO
Numeracle
P.O. Box 2523
Arlington, VA 22202

Footnotes:

For Appendix and Charted Data, see full filing: https://ecfsapi.fcc.gov/file/101311857929629/Numeracle_Comments_Robocall_Report_01302020.pdf

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