ABA Urges Robust Reassigned Numbers Database

Ms. Marlene H. Dortch
Secretary
Federal Communications Commission
445 12th Street, SW
Washington, DC 20554

Dear Ms. Dortch:

The American Bankers Association (ABA) appreciates the opportunity to comment on the request by the Federal Communications Commission’s (Commission) Wireline Competition Bureau and Consumer and Governmental Affairs Bureau for comment on the Technical Requirements Document approved by the North American Numbering Council on January 13, 2020. The Technical Requirements Document (Document) describes the technical responsibilities of the contractor that the Commission will select to administer a database of phone numbers that have been permanently disconnected from their current subscriber and are available for reassignment to another consumer (Reassigned Numbers Database, or Database). The Commission established the Reassigned Numbers Database through adoption of the Second Report and Order on December 12, 2018.

ABA shares the Commission’s goal to minimize calls to reassigned numbers. Banks regularly need to contact their customers with important, beneficial, and time-critical calls, such as suspicious activity alerts, data breach notifications, notices of address discrepancies, and low-balance and over-limit transactions. Banks make significant efforts to promote the accuracy of the numbers they call but, despite these efforts, cannot completely avoid calling reassigned numbers. We support the Commission’s decision to establish a single, comprehensive Reassigned Numbers Database that is available to callers on a voluntary basis to determine whether a customer’s wireless, wireline, or Voice over Internet Protocol (VoIP) phone number has been permanently disconnected. As the Commission establishes technical requirements for the Database’s administrator, we offer information and recommendations provided by our members, which if incorporated into the Database’s design, would improve its functionality and increase the likelihood that banks would utilize this resource.

First, we ask the Commission and the administrator to ensure that the Database can process a high volume of queries submitted by callers — potentially, billions of queries each month — and provide a response to each query in a very short period of time — e.g., three seconds or less. Under the Second Report and Order, telephone companies that provide voice service (Voice Service Providers) are required, on the 15th day of each month, to report to the Database all phone numbers assigned to the Provider that have been permanently disconnected from the number’s subscriber over the past month. For a bank to use the Reassigned Numbers Database effectively, the bank must either (1) check all of its customers’ numbers against the Database once per month (after Voice Service Providers have entered disconnections into the Database on the 15th of the month); or (2) check each customer number that the bank decides to call immediately prior to placing the call (with the exception of any numbers that the bank already has checked against the Database since the last batch of disconnections were entered into the Database).

The Technical Requirements Document states that the Database should “[a]ccommodate the ability for a User/User Agent . . . to perform a . . . Query Request of up to 50 individual [telephone numbers] at a time.” However, to encourage callers to use the Database, it must be able to process a much higher volume of queries than queries submitted in batches of 50 telephone numbers at a time. Consider the level of functionality needed for the Database to process queries submitted by one large bank, which reported that it has at least 130 million customer phone records in its system. If the bank decides to check all of its customers’ numbers on the 15th of each month, the Database would need to process 130 million queries in a short period of time — in addition to processing queries submitted by all other businesses that decide to check all of their customers’ numbers once per month. Accordingly, the Database should be equipped to process potentially billions of queries made soon after the 15th of each month.

Alternatively, banks could choose to check customer numbers immediately preceding the bank’s decision to place a call or text message to a customer. Under this approach, the Database should be able to provide immediate confirmation of the status of the number checked. Immediate confirmation is critical because text alerts sent by banks are used to advise the customer of an anomalous event regarding the customer’s account, such as potential fraud detected by the bank at the point of sale, one-time passcode messages, and customer-initiated alerts (e.g., low-balance and large-transaction notifications). The large bank described above estimates that the Database would need to respond to the bank’s inquiry about the status of a customer’s number in only three seconds for the bank to be able to execute its calling program effectively.

This approach of checking a customer’s number immediately preceding a call or text message to that number would reduce the quantity of queries that the bank submits to the Database at one time. Nonetheless, the volume of queries would remain substantial. The large bank discussed above places 100,000 text messages each hour, on average. The Database should be configured to provide a prompt response to each of these queries.

The Technical Requirements Document does not describe how callers will check the status of customer numbers using the Database. Our members report that it is critical that they can query the Database through an application programming interface (API). As described above, large banks and other large businesses possess hundreds of millions of customer phone numbers and may submit queries, within a very short period of time, to check those numbers against the Database. Large businesses can query their numbers efficiently only through use of an API. A requirement that businesses compare spreadsheets of disconnects against customer numbers would be inefficient and discourage businesses from using the Database.

The Technical Requirements Document also does not address the fee structure for use of the Database. We ask the Commission to minimize the fees charged to callers. As described above, large banks may seek to query millions of customer phone numbers each month. If the fees charged are not affordable, callers will have a disincentive to use the Database.

We appreciate the Commission’s consideration of the information and recommendations provided in this letter. We look forward to continuing to work with the Commission to ensure the Database has the functionality needed for callers to use the Database effectively and efficiently.

Sincerely,

Jonathan Thessin
Senior Counsel
Consumer & Regulatory Compliance
Regulatory Compliance and Policy