26-49 — Comment Digest

Extending robocall-related certification obligations to all providers and resellers is contested.

Filers split on: “The Commission should require robocall-related certification obligations for all providers and resellers.”

• Alliance for Telecommunications Industry Solutoppose — ATIS and the Alliance for Telecommunications Industry Solutions oppose extending robocall-related certification obligations to all providers and resellers, arguing that existing Commission mechanisms already provide sufficient information and that imposing additional obligations would create unnecessary overlap with limited incremental benefit.p. 3
• Numeraclesupport — Numeracle supports the proposal, emphasizing the need to address the current asymmetry in robocall certifications among different providers, and urges the Commission to implement annual re-certification for compliance, require due diligence before assigning numbers to resellers, and advance entity-level verification to enhance trust and accountability in the telecommunications system.pp. 4, 6, 7
• Tammy Glover Fowlersupport — CCC supports excluding Video Relay Service (VRS) and Internet Protocol Relay Service (IP Relay) providers from expanded certification and reporting obligations due to the lack of a resale-driven visibility gap, while also advocating for extending robocall-related certification obligations to resellers of telephone numbers to enhance transparency and compliance, as well as supporting the extension of other certifications related to robocalls and foreign ownership.pp. 2, 3, 4
• 448 Consultingmodify — The commenter generally supports the Commission's proposal to extend robocall mitigation certification requirements to resellers, suggesting that the requirements should account for the scale of operations among providers, and advocates for a definition of an end user that focuses on the party originating or terminating calls to ensure clear guidance and enforcement.pp. 3, 5
• Responsible Enterprises Against Consumer Harasmixed — R.E.A.C.H. supports the proposals for requiring disclosure of resellers by wholesalers to enhance transparency and aid in robocall enforcement, but warns that making numbering service providers liable for end user use is anti-competitive; additionally, R.E.A.C.H. stresses the importance of a ruling on its petition before any restrictions on number rotation by American businesses.pp. 3, 11
• CTIAsupport — The commenter believes that requiring certifications and disclosures from a broader group of entities can enhance the effectiveness of existing rules in protecting consumers from illegal robocalls, and that increasing support for state enforcement against bad actors is the most effective way to achieve the Commission's consumer protection goals, while also asserting that no additional delegations of authority to the states regarding numbering are necessary to combat illegal robocalls and robotexts.p. 12

The proposal to limit the resale of numbering resources to a single level is debated.

Filers split on: “The Commission should mandate a single-level restriction on the resale of numbering resources.”

• Tata Communications Americaoppose — Tata Communications America Inc. argues that the proposed restriction limiting the resale of numbering resources to a single level is unlikely to effectively address illegal robocalling, imposes significant costs on legitimate providers and their customers, presents practical enforcement challenges, fails to adequately weigh costs against speculative benefits, and may conflict with existing statutory obligations.pp. 1, 4, 5, 6
• BCM Oneoppose — The commenter argues that a single-level resale restriction would fail to meet the Commission's goals and could cause unintended consequences, such as shifting illegal robocall activities offshore, while suggesting that a registered-resale-relationship framework would better address visibility, traceback, and accountability concerns without the associated costs and disruptions. Additionally, if any restriction on suballocation is deemed necessary, the commenter advocates for grandfathering existing customer arrangements to maintain competitive practices and avoid disrupting lawful businesses.pp. 9, 11, 12
• Alliance for Telecommunications Industry Solutoppose — ATIS INC and the Alliance for Telecommunications Industry Solutions oppose the prohibition of reselling numbers beyond a single level, arguing that such a restriction would reduce competition, increase costs, and disrupt providers serving niche or specialized markets.pp. 3, 16
• USTelecom - The Broadband Associationoppose — The Commission should generally continue to find that limiting resale to a single level would be anticompetitive and contrary to the intent of the Act, as it would also force some large providers to reevaluate their business plans with significant impacts.p. 13
• Inteliquentoppose — The commenter argues that the Commission should define 'reseller of telephone numbers' to exclude commonly owned entities, confirm that using another carrier’s numbering resources for retail end users is a permitted single level of resale, and suggests that a flat prohibition on suballocation beyond a single level would not effectively advance the anti-robocall objective.pp. 21, 22, 23
• Tammy Glover Fowleroppose — CC believes that enhanced reporting requirements relating to intermediary carrier assignment and resale can improve transparency in number assignment, and greater emphasis on transparency in number resale would better advance the Commission’s objectives than a categorical restriction on resale levels.p. 5

The expansion and modification of NRUF reporting requirements are debated.

Filers split on: “The Commission should expand NRUF reporting requirements to include more detailed data.”

• Public Service Commission of the District of Cmodify — The State Commissions recommend revising the NRUF to require service providers reporting high levels of aging numbers in a thousands block (ten percent or more) to explain the reasons for these levels, as they could indicate inefficient and wasteful uses of numbering resources or illegal robocalling activity.p. 10
• NCTA - The Internet Television Associationoppose — The commenter opposes the Commission's proposals, arguing that making NPAC report fields mandatory would be ineffective due to incomplete data, suggests exploring existing industry tools for actionable information on the secondary market for telephone numbers, and believes that transforming NRUF reporting to detect abusive calling practices would result in duplicative and unreliable data, failing to effectively identify bad actors.pp. 5, 6, 7
• Voice on the Net Coalitionoppose — VON supports the Commission’s proposal to create more visibility and accountability in the number resale market but suggests that expanding NRUF reporting would be excessively burdensome and disproportionate to its likely benefits, recommending instead that the Commission require all resellers of telephone numbers to maintain a list of the resellers to whom they provide telephone numbers.p. 10
• ADEM ALJANINmodify — The commenter supports the objectives of the NRUF but emphasizes the need for the Commission to retain NRUF obligations at the provider-of-record level and to refrain from imposing additional reporting requirements on downstream resellers. Additionally, the commenter advocates for state commissions to have access to provider-specific disaggregated NRUF data, including out-of-state data, while ensuring confidentiality protections and use limitations similar to those for the Commission and NANPA.pp. 102, 129
• National Association of Regulatory Utility Commodify — The commenter advocates for the FCC to enhance NRUF reporting by requiring service providers to classify telephone numbers by usage, include multiple regulatory contacts to prevent delays, and provide explanations for unusually large number blocks categorized as Aging, along with a trigger for investigations.pp. 4, 5, 6
• Michigan Public Service Commissionsupport — The MPSC supports the NPRM’s proposal for all resellers to complete NRUF forms to enhance reporting consistency and enforcement, and believes that allowing cross-jurisdictional access to NRUF data, while maintaining confidentiality standards, would improve the numbering regulatory landscape and serve the public interest.pp. 3, 6

Whether state commissions should have authority to regulate numbering resources is contested.

Filers split on: “The Commission should permit state commissions to regulate and administer numbering resources.”

• National Association of Regulatory Utility Commodify — The commenter advocates for the FCC to establish a rule that explicitly prohibits the sale of numbering resources, citing state commissions' findings of an open market that contradicts Commission guidance and industry guidelines, and also supports the idea that State Commissions should have the authority to direct NANPA to withhold numbering resources from service providers that violate numbering reporting and robocalling rules.pp. 7, 8
• Public Service Commission of the District of Cmodify — The State Commissions advocate for several amendments to the FCC's numbering resource management, including requiring advance notice of requests to assist in administration, identifying multiple regulatory contacts in NRUF reports for better tracking of resold resources, allowing state commissions to direct NANPA to deny requests from non-compliant service providers, prohibiting the sale of inefficiently used numbering resources, and enabling state commissions to withhold resources from violators of state laws.pp. 4, 7, 14, 16, 20
• USTelecom - The Broadband Associationoppose — The commenter advocates for the FCC to collaborate with the Alliance for Telecommunications Industry Solutions Industry Numbering Committee to modify FCC Form 502 and develop a chain of custody for numbering resources, while also emphasizing the need for the Commission to maintain primary jurisdiction over numbering to prevent inconsistent state regulation that could hinder competition, and suggests referring NPAC proposals to the Number Portability Industry Forum to explore alternatives that align with the Commission's objectives and existing use cases.pp. 9, 12, 15
• Twiliooppose — The commenter argues that the Commission should prioritize practical utility and minimize compliance burdens when modifying Numbering Resource Utilization/Forecast reporting requirements, and suggests that current targeted mitigation efforts should be allowed to fully take effect before any significant changes to established numbering processes are considered.pp. 9, 13
• Voice on the Net Coalitionoppose — The Commission should allow existing policies to take effect and assess their efficacy before considering new regulations that would restrict the competitive numbering market.p. 5
• Michigan Public Service Commissionsupport — The MPSC asserts that numbering resources are a public resource that should not be sold or hoarded, urging the Commission to establish a rule against their sale, while also advocating for increased authority for state commissions to manage access to these resources, as current FCC regulations limit state intervention in provider applications.pp. 7, 11

The regulation of number cycling practices is debated, particularly in relation to robocalls.

Filers split on: “The Commission should adopt rules to regulate number cycling practices.”

• ACA Internationaloppose — The commenter advocates for the Commission to take action to address the root causes of legitimate companies' use of number rotation by promoting greater transparency and accountability in the labeling of calls, emphasizing that number cycling is a response to the erroneous blocking and mislabeling of lawful calls.p. 3
• ADEM ALJANINsupport — The commenter supports the adoption of the short-tenure number cycling velocity rule as the primary enforcement tool against robocall abuse, arguing that it effectively meets the Commission's enforcement objectives at the individual end-user sub-account level while preserving competitive market integrity.pp. 95, 101
• Voice on the Net Coalitionmodify — VON urges the Commission to give substantial weight to legitimate use cases before adopting any prohibition or restriction on number cycling, as enhanced know-your-customer requirements would effectively target the specific risk of number cycling by bad actors without impacting legitimate users.p. 14
• Pingeroppose — Pinger Inc. opposes any rule addressing number cycling that inadvertently affects single-account consumer retail provisioning, arguing that such rules would burden consumers without addressing the intended conduct. They propose that new number-access rules should be based on observable provisioning and traffic characteristics, distinguishing between high-volume programmatic provisioning and single-account consumer retail provisioning.pp. 3, 15, 16
• American Bankers Associationsupport — The American Bankers Association urges the Commission to restrict number cycling, as it impedes efforts to identify the entity responsible for illegal calls when a criminal obtains a large quantity of phone numbers.p. 5
• Online Lenders Allianceoppose — The Online Lenders Alliance strongly encourages the Commission to exercise caution before adopting rules that broadly restrict number cycling practices without first addressing systemic deficiencies in current call-blocking and analytics regimes.p. 4

The establishment of standardized remediation procedures for mislabeled or blocked calls is debated.

Filers split on: “The Commission should adopt standardized remediation procedures for mislabeled or blocked calls.”

• Online Lenders Alliancemodify — The commenter advocates for the incorporation of meaningful due process protections in any rulemaking from the NPRM to prevent penalties on lawful entities based on inaccurate information, the establishment of evidence-based standards before restricting telephone numbers, and the creation of expedited and standardized remediation procedures for lawful callers that have been mislabeled or blocked.pp. 5, 7
• ACA Internationalmodify — The commenter advocates for the Commission to enhance the remediation process by promoting automation through carrier-to-carrier APIs or developing a database of legitimate numbers, while also emphasizing the need for greater transparency and accountability from voice service providers and their analytics partners regarding the labeling of calls.p. 7
• Telnyxmodify — Telnyx urges the Commission to mandate that analytics providers and carriers publish objective labeling criteria, arguing that the current closed-loop labeling system prevents remediation of blocked or mislabeled calls through existing redress mechanisms. They contend that without implementing accuracy, transparency, and appeals obligations on the labeling layer, restricting rotation will fail to deter bad actors and hinder legitimate callers from reaching important recipients.pp. 9, 10
• William H. Dudleymodify — The regulatory mandate should shift away from counting commercial corporate links and instead legally mandate strict, automated, API-driven traceback query response speeds at the final service delivery endpoint.p. 6
• TelSwitchmodify — TelSwitch Inc. asserts that policies lacking enforcement and real consequences will not effectively reduce robocalls, emphasizing that measurable results depend on enforcement and the availability of supportive tools.p. 4
• Convososupport — Convoso urges the Commission to adopt uniform, transparent remediation standards and timelines to address the inconsistency of remediation outcomes across providers.p. 6

The creation of additional tracking subcategories for intermediate-number reporting is debated.

Filers split on: “The Commission should permit the creation of additional tracking subcategories for intermediate-number reporting.”

• Alliance for Telecommunications Industry Solutoppose — ATIS opposes the creation of additional tracking subcategories for intermediate-number reporting, arguing that it would complicate the process for service providers and is unnecessary since they already track number utilization; it also believes that having multiple intermediate number definitions would be confusing and disagrees with the notion that creating three subcategories would reduce confusion in NRUF reporting.pp. 10, 12
• Michigan Public Service Commissionsupport — The MPSC supports the proposal to gain more insight into the use of numbers within the intermediate category and advocates for splitting this category into three subcategories to enhance understanding of number usage, which could improve forecasting accuracy and prevent unnecessary area code exhaust.p. 4
• Tammy Glover Fowlersupport — CCC agrees that the Commission should create the three proposed subcategories - intermediate assigned, intermediate other, and intermediate available, as the single intermediate category is no longer adequate to describe how numbers actually move through reseller relationships today.p. 4
• Bandwidthmodify — The Commission should engage further with the NANC to gain consensus on the definition of an 'intermediate provider' and how the reporting framework should reflect that distinction before adopting the proposed three-subcategory approach.p. 18