Insights

Robocallers and Toll-Free Traffic Pumpers Beware – Your Scams May Cost You $116M!

Jul 21, 2022

On July 14, 2022, the Federal Communications Commission (FCC) proposed an $116 million fine for robocalls made in an apparent Toll-Free traffic pumping robocalling scheme – one of the highest robocall penalties to date the FCC has issued and the first ever for a Toll-Free traffic pumping scheme! 

With such a monumental potential punitive action; however, some may be wondering (and/or too afraid to ask): 

What exactly IS Toll-Free traffic pumping?

Whether you refer to it as a subset of robocalling or the technical term “access stimulation,” traffic pumping is a very real problem that is negatively affecting the entire Toll-Free industry.

So, what does Toll-Free traffic pumping look like?

In a nutshell, Toll-Free traffic pumping starts with a robocaller and a telephone company (usually a smaller competitive local exchange carrier) agreeing to share revenue the carrier gets for originating a Toll-Free call. This is called “originating access.” As Toll-Free is a premium service, originating access to Toll-Free can be priced higher than other telecommunications services, creating an incentive to push more traffic, or “pump” the traffic, to Toll-Free Numbers. The robocaller usually spoofs the Caller ID on the call to make it harder to trace back to the origin. In addition, most traffic pumping schemes are highly sophisticated and involve several carrier hand-offs, which makes it very difficult to trace the call back to the call originator or even the originating carrier.

The longer the call, and the more calls being made to Toll-Free numbers, the more money these unethical carriers and robocallers collect for routing those calls. 

The tricky thing about traffic pumping and why it is so difficult to curb is that surprisingly, the tools that traffic pumpers use – Caller ID spoofing and revenue sharing, are both legal in some circumstances.  Almost all traffic pumping schemes involve Caller ID spoofing, which the FCC does not prohibit outright.  It is illegal; however, to use spoofed Caller ID for the purpose of committing fraud or wrongfully obtaining anything of value, which is exactly what happens in Toll-Free traffic pumping.  Revenue sharing is also not illegal, per se, as there are many legitimate telecommunications services that legally share revenue. However, it is also a way for the traffic pumper to get paid. 

The traffic pumping issue is getting better thanks to several simultaneous efforts. The Toll-Free industry and the Industry Traceback Group now traceback illegal traffic pumping and robocalls in record time. The FCC has given carriers broader discretion to cut-off upstream carriers that provide lots of robocall traffic, in addition to the FCC issuing cease and desist letters to carriers seen as aiding robocallers. The industry is in the process of implementing the STIR/SHAKEN standards which make it easier to trace calls back to the originator. The FCC also lowered the access charges for Toll-Free, taking some of the profits out of traffic pumping. And now, the FCC issued the $116m fine for traffic pumping. 

While these measures help curb traffic pumping, there is more YOU can do to help. Here are few tips for Resp Orgs and Toll-Free end users to help thwart traffic pumpers:

• Limit your Interactive Voice Response Systems. Scammers love to find IVRs (Interactive Voice Response systems) that will let them hang on the line for an hour or longer. Set a time limit for IVRs to three-minutes, or less, unless there is a determined need for IVRs to have a longer limit.
   
• Opt out of Pay Phone calls. Yes, payphones do exist. And scammers can make it look like a number is coming from a pay phone when traffic pumping. Pay phone charges are some of the highest in the telecommunications industry, making them a lucrative weapon for scammers to use against Toll-Free providers. Talk to your carrier about opting out of receiving calls marked as “pay phone” calls.
   
• Recognize Calling Patterns. Traffic pumping can be recognized if you know how to look for it. Resp Orgs, End Users and carriers providing services to Toll-Free Numbers may look for the following patterns to help determine if they are the victim of traffic pumping:
  • Originating Automatic Number Identifications (ANIs) differ and are spoofed, especially using the ANI of a disconnected telephone number;
  • Calls may have silence, nonsense audio, DTMF tones, or sound like a “butt dial” with indistinct conversation or babies crying;
  • High or very similar average length of conversation (ALOC) coming from one source;
  • Noticeable increase in monthly charges;
  • Calls during off-hours, including overnight hours; and
  • Spikes in incoming Toll-Free traffic from a single source.
     
• Let the FCC and Law Enforcement know.
  Help put a halt to Toll-Free traffic pumpers by filing a complaint with the FCC here: https://consumercomplaints.fcc.gov/hc/en-us and the FBI’s Internet Crime Complaint Center here: http://www.ic3.gov/.

Note that the more information you can provide, the easier it will be for them to pursue your complaint(s).