The National Consumer Law Center (NCLC), on behalf of its low-income clients, and the Electronic Privacy Information Center, applaud the Federal Communication Commission (Commission or FCC) for its continuing attention to the persistent problem of illegal calls. The Commission is encouraged to continue to develop systemic solutions, including many that are proposed in this docket. In these comments, the focus is on one particular systemic change the Commission should adopt: it should prohibit the temporary rental of telephone numbers, a tactic widely used by callers—particularly scam callers and fraudulent telemarketers—to render the displayed caller ID information meaningless. These callers rent numbers on a short-term basis specifically as a way of avoiding “scam likely” warnings and enabling neighborhood spoofing.
NCLC and EPIC recognize that numbering issues are more relevant to the docket on Numbering Policies for Modern Communications. However, as the improper use of rented numbers is inextricably linked to the authentication of caller IDs, the groups write to encourage the Commission to address this issue on an expedited basis, and tighten the authentication requirements.