On December 13, 2024, the North American Numbering Council (NANC) adopted recommendations and drew conclusions on VoIP providers’ direct access to telephone numbers for the use of the Federal Communications Commission (Commission or FCC). The NANC is a federal advisory committee that provides advice and recommendations to the FCC on access to, and use of, telephone numbers.
In 2023, in response to concern over the rapid consumption of telephone numbers by VoIP providers and their customers, sometimes in aid of unwanted or unlawful robocalls, the Commission directed the NANC to investigate multiple issues related to VoIP providers and telephone number use. The NANC, in turn, directed its Call Authentication Trust Anchor (CATA) working group to study the questions and provide recommendations to the NANC. Those recommendations were made and approved at the NANC’s December 2024 meeting.
The approved recommendations, which will now be reviewed by FCC staff, are:
- Improve NRUF reporting compliance: The FCC should encourage providers to comply with existing reporting requirements, particularly in relation to intermediate number administration and wholesale transactions.
- Increase access to numbering data: The FCC should work with the States to get access to additional data sources.
- Utilize FCC auditing authority: The FCC should use its auditing authority to curtail any improper use of numbering resources.
- Enforce numbering rules strictly: The FCC should strictly enforce its numbering rules and thereby remind providers that failure to comply with industry guidelines and Commission rules regarding numbering resources could result in revocation of authorization, the inability to obtain additional numbers pending revocation, reclamation of unassigned numbers already obtained directly from the Numbering Administrators, and/or enforcement action.
- Improve call treatment analytics: The industry should adopt a goal for continuous improvement of ways a caller can be confident of proper call treatment of their calls so that callers willingly use less numbers and less complex dialing plans.
- Do not adopt international use restrictions: The U.S. should not adopt the limited international numbering restrictions described in this Report to avoid harming innovation, reducing competition, and slowing economic growth, but consider the other CATA WG recommendations.
- Endorse ITG “number traces” if successful: Should the ITG’s “number trace” pilot be successful, the FCC should formally endorse the ITG’s use of such number traces in its role as the registered U.S. traceback consortium and require providers to cooperate with such traces.
- Follow Best Practices: The FCC should encourage providers with direct access to numbers to adopt general KYC obligations regarding the use of numbers sold or leased to providers operating in the secondary market.
The approved conclusions drawn are:
- In its Direct Access Order, the Commission recognized the benefits of extending direct access to numbering resources to interconnected VoIP providers, The Commission also highlighted that its Order enforced policy goals of counteracting number exhaust, ensuring continuance of efficient number utilization and providing adequate safeguards to prevent bad actors from gaining direct access to numbers. However, these benefits seem to be lacking in the secondary market.
- The NRUF reporting process offers a valuable, albeit incomplete, window into the secondary market, where numbers change hands through one or more intermediaries. By improving visibility into reporting, regulators can better understand how numbering resources are flowing through the secondary market.
- The CATA WG believes that enhancing compliance with existing NRUF obligations for intermediate number administration may provide insights needed to manage numbering resources more effectively
Possible Next Steps The recommendations and conclusions will be reviewed by the FCC staff. The Commission may issue a notice seeking public comments on them or even on new rules adopting some of the recommendations. The Commission may also be more receptive to complaints about VoIP providers’ and their customers’ quantity of numbers used and the way those numbers are used (e.g., number rotation).
State utility commissions and, perhaps, even state attorney general offices, may investigate these issues on a state-by-state basis. We are aware, for example, that the Arizona and Maine commission are presently investigating number access and use by both carriers and VoIP providers. They may dig more deeply into numbering reports filed by providers to identify more provider for investigation.
Smaller carriers and VoIP providers may need to add staff to manage telephone numbers and use and retention of numbers by their customers. Just as voice service providers must both know their customers and their upstream providers for purposes of identifying and preventing robocalls, so too must providers know their customers for number usage. Besides number rotation, multi-level number sales or leases may present problems. Providers may wish to limit the ability of their customers to broker telephone numbers or engage in large-volume number rotation practices.
