Insights

Bad Traffic (Toll-Free Traffic Pumping)

Aug 24, 2015

We’re not talking about the DC Beltway at rush hour, Chicago’s O’Hare airport at any time of the day, or the all kazoo cover of John Barleycorn Must Die. We are talking about traffic that is sent to Toll-Free subscribers for fraudulent purposes. This practice is referred to as “traffic pumping.”

Traffic pumping in Toll-Free occurs when one party generates a volume of calls (usually using a robo-dialer) to a particular Toll-Free number for the purpose of generating revenue from a Toll-Free subscriber or from one of the providers in the call path.  Traffic pumping may also be used to harass a Toll-Free subscriber into giving up a particular vanity number. Almost all traffic pumping schemes also involve Caller ID spoofing and several carrier hand-offs, making it very difficult to trace the call back to the call originator or even the originating carrier. Use of VoIP makes it even easier to engage in spoofing and traffic pumping.

Spoofing and traffic pumping are not, per se, illegal. There are many legitimate reasons to spoof Caller ID. For example, Uber drivers use a spoofed Caller ID when contacting a person requesting a ride so that the customer does not have the personal cell phone of the driver.  While the FCC rules do not prohibit spoofing outright, it is illegal 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.

When traffic pumping is occurring, your subscribers are receiving an unusually high volume of calls and almost all of the calls are hang-ups or dead air. Some traffic pumpers have sophisticated systems that can leave a call connected for hours by tricking automated attendants into thinking there is a live person on the line, especially during non-business hours.

Somos has heard from Resp Orgs that traffic pumping is a growing problem. Somos, Inc. has spoken to the FCC about the problem and there is no magic bullet to stop this nefarious practice. One way to bring more attention to the problem and contribute toward a solution is to file FCC complaints. Not just one or two victims of traffic pumping, but many, so the FCC can see the full scope of the problem and use its resources and investigative powers to hopefully get to the source of this fraudulent traffic and shut down the traffic pumpers. But, they need your help. That is why we have made it easier for Resp Orgs and their subscribers to file complaints at the FCC. We have instructions for filing complaints, a complaint template for Resp Orgs, a complaint template for Toll-Free subscribers that Resp Orgs can give to their subscribers, and an affidavit template, which can be accessed by logging into secure.sms800.com, selecting the "Find Documents" section and clicking on the "Miscellaneous" menu item. The more information you can give the FCC, the easier it will be for them to pursue the complaints. In addition, you can also file a complaint at the FBI’s Internet Crime Complaint Center at: http://www.ic3.gov/.

When the telecom industry transitions to an all-IP network, it may be possible to create an encryption-based authentication system that can eliminate or at least severely hamper the ability to spoof Caller ID. That day is several years away. Until there is a technological solution to spoofing and traffic pumping, the industry can help itself by alerting the FCC to the need for enforcement and enlisting the FCC’s resources and authority to slow down or stop this illegal and costly drain on the Toll-Free industry.

Joel Bernstein

Vice President, Regulatory and Public Policy