Letter to the FCC on the NPRM re: Numbering Policies

Dear Chairman Carr,

The American Bankers Association (ABA) commends the Federal Communications Commission (Commission) for scheduling a vote to issue a proposal (Proposal) that would strengthen the Commission's numbering policies to combat illegal calls. Among other steps, the Commission proposes to impose restrictions on the resale of phone numbers and to seek comment on how the Commission should address number "cycling" – i.e., the use by a caller of large quantities of telephone numbers on a rotating or single-use basis to avoid detection.

Fraud continues to be a pervasive problem that takes an extraordinary financial and emotional toll on consumers. In a December 2025 report, the Federal Trade Commission estimated that 2024 fraud losses totaled a staggering $196 billion. Increasingly, criminals perpetrate fraud by impersonating banks and other legitimate companies through voice calls, text messages, and advertisements on social media websites. Criminals illegally "spoof" the number used in the caller ID, causing a call recipient’s caller ID to display the name, or solely the number, of a legitimate company instead of the name and number of the actual caller with the intent to defraud the consumer. The numbering practices addressed by the Proposal should limit the ability of criminals to complete calls to consumers without detection, gain consumers’ trust, and perpetrate fraud.

The Proposal builds on the Commission’s recent action to mandate U.S. voice service providers and intermediate providers block calls from Belthrough LLC for violating the Commission’s rules against illegal calls, and to remove the company from the Robocall Mitigation Database. We applaud the Commission for effectively shutting down Belthrough as one step in our larger collective fight against illegal calls.

In comments we submitted recently, ABA offered data demonstrating that rogue originating voice service providers like Belthrough are able to establish themselves and, within weeks, originate hundreds of millions of illegal calls. Moreover, in a poll of 4,456 adults conducted by Morning Consult for ABA this past February, 77% of consumers said they support regulatory action that requires telecommunications providers to do more to authenticate the identity of a caller and prevent spoofed caller IDs. We look forward to continuing to work with the Commission to combat illegal calls and text messages.

Sincerely,
Jonathan Thessin
Vice President/Senior Counsel
Consumer & Regulatory Compliance
Regulatory Compliance and Policy