Telephone Numbers, Local Number
Portability, and TCPA Compliance
© 1999-2008 NeuStar, Inc
Index
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NeuStar Overview
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US Telephone Number Anatomy
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Local/Wireless Number Portability Overview
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Local/Wireless Number Portability Process
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Some Telephone Numbering Facts
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Telephone Number Use
•
Federal Communication Commission (FCC) Telephone Consumer Protection
Act (TCPA) Regulatory History
•
NeuStar Inter-modal Ported TN Identification Service
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NeuStar Contacts
© 1999-2008 NeuStar, Inc
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NeuStar Overview
NeuStar is the leading provider of mission-critical clearinghouse services for
communications.
•
•
•
Addressing
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Trusted, neutral administrator of addressing directories, utilities and registries for the telephony
and Internet communities worldwide
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Enables the routing of virtually every telephone call dialed in North America
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Operates the authoritative database of all North American telephone numbers
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Conserves and optimizes shared public telephone numbering resources
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Spearheads online digital identity efforts and number translation services
Interoperability
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Operator of a unique inter-carrier transaction clearinghouse platform that enables IP/converged
services
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Delivers efficiencies to markets where natural competitors must exchange millions of transactions
per day
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Accelerates service providers' time-to-market, allowing them to focus on core businesses while
enhancing the value of products and services
Infrastructure
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Premier provider of infrastructure services that enable networks to connect and interoperate
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Assists service providers in managing their internal systems (especially where those systems
interface with volatile, high-volume inter-carrier networks)
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Manages shared operations data among competing carriers
© 1999-2008 NeuStar, Inc
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US Telephone Number Anatomy
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•
Format: (NPA) NXX-XXXX
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NPA
= Number Planning Area (Area Code)
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NXX
= Central Office Code (Prefix/Exchange)
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XXXX
= Line Number
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N digit can be any number from 2 to 9
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P, A, X can be any number from 0 to 9
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Ex: (571) 434-5400
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571
434
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5400
Area code assigned in Virginia
Identifies Exchange assigned to a Telco within a specific Rate Center
using a specific telephone company switch.
Line Number assigned to NeuStar PBX (Private Branch Exchange)
A part of the North American Numbering Plan
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Comprises 19 countries including US, Canada, and Caribbean nations
© 1999-2008 NeuStar, Inc
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Local/Wireless Number Portability Overview
•
The Telecommunication Act of 1996 defined "number portability" as "the
ability of users of telecommunications services to retain, at the same
location, existing telecommunications numbers without impairment of
quality, reliability, or convenience when switching from one
telecommunications carrier to another
•
The Telecommunications Act of 1996 established a "competitive checklist"
that required the Bell Operating Companies (BOCs) to be in full compliance
with the FCC’s LNP regulations in order to provide in-region inter-LATA
services. The Bell Operating Companies were not permitted to offer long
distance service until such time that LNP had been implemented in their
service areas.
Bottom Line: Businesses and consumers can now switch their local telephone
carrier without having to change their telephone number.
© 1999-2008 NeuStar, Inc
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Local/Wireless Number Portability Process
8. Broadcast New Routing Instructions
PSTN
PSTN
Carrier
Telephone
Networks
Carrier
Telephone
Networks
Number
Portability
Administration
Center
4. Creation of
Pending Port
7. Activation
of Approved
Pending Port
5. Notification
of Pending
Port
3. Confirmation of Subscriber
Information
New Service
Provider
2. Request to Validate
Subscriber Information
1. Requests to
Port Number
© 1999-2008 NeuStar, Inc
Consumers &
Businesses
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6. Approval of
Pending Port*
Old Service
Provider
*Note: The Old Service Provider may NOT approve
the port and place the Pending Port in “Conflict”,
which, typically requires “verbal” interaction
between the new and old service providers. If the
consumer or business changes their mind and
does not wish to port, the Pending Port may be
“Cancelled.”
Some Telephone Numbering Facts
•
In the NANP (North American Numbering Plan), 325 area codes have been assigned
covering over 100,000 working prefixes/exchanges (source NANPA)
•
In the US, there are estimated to be 600+ million working telephone numbers
•
LNP (Local Number Portability) has been available in the top 100 MSAs
(Metropolitan Statistical Areas (these are defined by the Census Bureau)) since 1997
for wireline telephone numbers
•
WNP (Wireless Number Portability) has been available in the top 100 MSAs since
November 24, 2003 for wireless numbers
•
There have been over 37 million wireless telephone numbers ported.
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Over 2.3 million telephone numbers have been ported from wireline carriers to
wireless carriers (Source FCC)
© 1999-2008 NeuStar, Inc
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(Source FCC)
Telephone Number Use
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•
Before LNP, the telephone number:
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Identified the state to which it is assigned
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Identified the rate center to which it is assigned
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Identified the service local/wireless carrier who serves the number
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Identified the underlying technology (wireline or wireless) associated with the number as
derived by knowing the type of carrier
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Used solely by telephony network to set-up and route calls
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Used solely by mobile networks (if a mobile TN) for roaming registration and validation
After LNP, the telephone number:
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Still identifies the state to which it is assigned
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Still identifies the rate center to which it is assigned
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*No longer identifies the service local/wireless carrier who serves the number
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*No longer identifies the underlying technology (wireline or wireless) associated with the
number as derived by knowing the type of carrier
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*No longer is used solely by telephony network to set-up and route calls
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*No longer is used solely by mobile networks (if a mobile TN) for roaming registration and
validation
© 1999-2008 NeuStar, Inc
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FCC TCPA Regulatory History
•
In December 1991, Congress passed the Telephone Consumer Protection Act (TCPA) in an effort
to address a growing number of telephone marketing calls and certain telemarketing practices
thought to be an invasion of consumer privacy and even a risk to public safety.
•
In 1992, the FCC adopted rules implementing the requirements of the TCPA. The TCPA
specifically prohibits calls using an auto-dialer or artificial or prerecorded message “to any
telephone number assigned to a paging service, cellular telephone service, specialized mobile
radio service, or other radio common carrier service, or any service for which the called party is
charged.”
•
In July 2003, the Commission released a Report and Order revising the TCPA rules to respond to
changes in the telemarketing marketplace over the last decade. The FCC acknowledged that,
beginning November 24, 2003, LNP would permit subscribers to port numbers previously used
for wireline service to commercial mobile radio service (CMRS) providers, and that telemarketers
would need to take the steps necessary to ensure continued compliance with the TCPA. Also,
the FCC rejected a proposal to create a “good faith” exception for inadvertent autodialed or
prerecorded calls to wireless numbers finding there are adequate solutions in the marketplace to
solve the problem.
© 1999-2008 NeuStar, Inc
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FCC TCPA Regulatory History Cont’d
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In September 2004, the FCC established a limited safe harbor period in which persons will not be
liable for placing autodialed or artificial or prerecorded message calls to numbers recently ported
from wireline to wireless service. The FCC concluded that callers will not be in violation of 47
C.F.R. §64.1200(a)(1)(iii) for autodialed or artificial or prerecorded message calls placed to a
wireless number that has been ported from a wireline service within the previous 15 days,
provided the number is not already on the national do-not-call registry or caller’s companyspecific do-not-call list. The 15-day safe harbor period runs from the time the port has been
completed and the number appears in Neustar’s “Inter-modal Ported TN Identification Service” as
a wireless number.
Bottom Line: Calls placed using auto-dialers or made with artificial or prerecorded
messages are prohibited to wireless phones; however, there is a 15-day safe harbor
period in cases where a telephone number is ported from a wireline to a wireless
service. Posting of the telephone number in Neustar’s Inter-modal Ported TN
Identification Service starts the 15-day safe harbor period clock.
© 1999-2008 NeuStar, Inc
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Intermodal Ported TN Identification Service
• Available at www.tcpacompliance.us
• Two ASCII text files updated daily:
– One file identifies telephone numbers that have ported/moved from
wireline carriers to wireless carriers since the inception of WNP
– Another file identifies telephone numbers that have ported/moved from
wireless carriers to wireline carriers since the inception of WNP
• Both files are available in two different ASCII text formats
• Provided on a subscription basis:
– Reasonable fee
– Unlimited downloads
– Strict data use and data disclosure restrictions; subscribers can be
audited
© 1999-2008 NeuStar, Inc
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Industry TCPA Compliance
To fully comply with TCPA, Industry members should do one of the
following (in addition to any other method of identifying wireless
numbers that is being used):
– Subscribe to NeuStar’s Inter-modal Ported TN Identification (Wireless
Do Not Call) Service directly or ensure that their outsourced call center
is a subscriber
– Ensure that their current list vendor/scrubber is a NeuStar Inter-modal
Ported TN Identification (Wireless Do Not Call) Service reseller or
ensure that their outsourced call center is using a list vendor/scrubber
who is a NeuStar Inter-modal Ported TN Identification (Wireless Do Not
Call) Service reseller
– Ensure that their current call suppression service is a NeuStar Intermodal Ported TN Identification (Wireless Do Not Call) Service
user/reseller or that their outsourced call center is using a call
suppression service that is a NeuStar’s Inter-modal Ported TN
Identification (Wireless Do Not Call) reseller/user.
© 1999-2008 NeuStar, Inc
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NeuStar Contacts
• Lisa Turner, Manager, TCPA Compliance
571.434.5169
lisa.turner@neustar.biz
© 1999-2008 NeuStar, Inc
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