Numeracle submitted an ex parte filing to the FCC as part of the ongoing robocall and unwanted communications proceedings.
The submission builds on the FCC’s recent actions and draft proposals focused on strengthening Know Your Customer (KYC) requirements and reducing illegal call traffic at its source. Through this filing, Numeracle provides input on the importance of clear, enforceable identity and accountability standards as the Commission continues to refine its approach to robocall mitigation.
KYC Relevance
Numeracle’s ex parte emphasizes that effective robocall enforcement depends on accountability that traces back to the originator. The filing reinforces a consistent regulatory theme emerging across recent FCC activity: originating providers are best positioned to prevent illegal calls from entering the network and must therefore apply meaningful customer verification, risk‑based evaluation, and ongoing oversight.
Key arguments and noteworthy points raised include:
- Originating providers bear primary responsibility for stopping illegal calls before they enter the network
- KYC obligations must be defined by verified identity, not the passive collection of customer data
- Supporting records and documentation are essential to substantiate identity claims
- Risk‑based KYC is critical, with heightened scrutiny for high‑volume or higher‑risk callers
- Suitability for access to the voice network should be assessed during onboarding and throughout the customer lifecycle
- KYC is an ongoing obligation requiring monitoring and re‑verification tied to traffic patterns and red flags
- Weak or inconsistent KYC practices directly enable fraud, impersonation, and large‑scale consumer harm
Together, these points underscore that KYC is not a one‑time compliance checkbox, but a continuous operational responsibility central to network integrity and enforcement effectiveness.
Numeracle's Stance
In this ex parte, Numeracle reiterates its long‑standing position that KYC is foundational to restoring trust in the voice network.
It is encouraging to see continued progress on these issues following recent engagement between Numeracle leadership and FCCChairman Carr, and while the filing does not suggest attribution or direct influence, its principles align closely with the direction the Commission is now advancing. Numeracle supports the adoption of enforceable, originator‑focused KYC standards grounded in verified identity, accountability, and suitability. KYC done right is an ongoing responsibility that protects consumers, enables enforcement, and strengthens the integrity of communications.
Our platform empowers organizations to manage branded calling, improve caller id reputation, and stay compliant with evolving regulatory and industry standards. FAQs like this are designed to provide clear, actionable guidance backed by our expertise in verified identity, call labeling mitigation, and spam prevention.
To explore how Numeracle supports trusted and effective outbound communications, visit www.numeracle.com.
