Telephone Numbers, Local Number Portability, and TCPA Compliance

Index NeuStar Overview US Telephone Number Anatomy Local/Wireless Number Portability Overview Local/Wireless Number Portability Process Some Telephone Numbering Facts Telephone Number Use Federal Communication Commission (FCC) Telephone Consumer Protection Act (TCPA) Regulatory History NeuStar Inter-modal Ported TN Identification Service NeuStar Contacts Since the 1996 Telecommunications Act, we have seen unprecedented change in the telecom industry. Increased local exchange competition and the emergence of new and innovative technologies and services have transformed the telecommunications marketplace. They have also all impacted the need and availability of NANP numbering resources and thus presented some difficult challenges to the longevity of the NANP. The FCC addressed these challenges by taking proactive and decisive measures through its Numbering Resource Optimization (NRO) Orders. NeuStar, as the NANPA, effectively and efficiently implemented the FCC’s NRO vision. The results speak for themselves, e.g., reduced demand by service providers, increased utilization of existing resources, significant reclamation of unused numbers, and the precipitous decline in the new area codes activated per year, all of which assuring the long-term viability of the NANP. Significant work remains, however. The telecom environment is again evolving and therefore requires a neutral, well-trained and tested administrator to ensure the FCC’s vision for number optimization continues to be central to NANP administration. NeuStar is that administrator and fully prepared and committed from day one to continue to serve as the FCC’s instrument to implement bold and innovative measures necessary to maintain the long term viability of the NANP. Bottom line: NeuStar understands precisely what needs to be done; we have experienced people and a robust system design; we have a plan to deliver what the FCC expects. And, we are deeply committed to NANPA responsibilities.

NeuStar Overview NeuStar is the leading provider of mission-critical clearinghouse services for communications. Addressing Trusted, neutral administrator of addressing directories, utilities and registries for the telephony and Internet communities worldwide Enables the routing of virtually every telephone call dialed in North America Operates the authoritative database of all North American telephone numbers Conserves and optimizes shared public telephone numbering resources Spearheads online digital identity efforts and number translation services Interoperability Operator of a unique inter-carrier transaction clearinghouse platform that enables IP/converged services Delivers efficiencies to markets where natural competitors must exchange millions of transactions per day Accelerates service providers' time-to-market, allowing them to focus on core businesses while enhancing the value of products and services Infrastructure Premier provider of infrastructure services that enable networks to connect and interoperate Assists service providers in managing their internal systems (especially where those systems interface with volatile, high-volume inter-carrier networks) Manages shared operations data among competing carriers

US Telephone Number Anatomy Format: (NPA) NXX-XXXX NPA = Number Planning Area (Area Code) NXX = Central Office Code (Prefix/Exchange) XXXX = Line Number N digit can be any number from 2 to 9 P, A, X can be any number from 0 to 9 Ex: (571) 434-5400 571 Area code assigned in Virginia 434 Identifies Exchange assigned to a Telco within a specific Rate Center using a specific telephone company switch. 5400 Line Number assigned to NeuStar PBX (Private Branch Exchange) A part of the North American Numbering Plan Comprises 19 countries including US, Canada, and Caribbean nations

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.

Local/Wireless Number Portability Process PSTN 8. Broadcast New Routing Instructions PSTN Number Portability Administration Center Carrier Telephone Networks Carrier Telephone Networks 4. Creation of Pending Port 6. Approval of Pending Port* 7. Activation of Approved Pending Port 5. Notification of Pending Port 3. Confirmation of Subscriber Information New Service Provider Old Service Provider 2. Request to Validate Subscriber Information *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.” 1. Requests to Port Number Consumers & Businesses

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. (Source FCC) Over 2.3 million telephone numbers have been ported from wireline carriers to wireless carriers (Source FCC)

Telephone Number Use Before LNP, the telephone number: Identified the state to which it is assigned Identified the rate center to which it is assigned Identified the service local/wireless carrier who serves the number Identified the underlying technology (wireline or wireless) associated with the number as derived by knowing the type of carrier Used solely by telephony network to set-up and route calls Used solely by mobile networks (if a mobile TN) for roaming registration and validation After LNP, the telephone number: Still identifies the state to which it is assigned Still identifies the rate center to which it is assigned *No longer identifies the service local/wireless carrier who serves the number *No longer identifies the underlying technology (wireline or wireless) associated with the number as derived by knowing the type of carrier *No longer is used solely by telephony network to set-up and route calls *No longer is used solely by mobile networks (if a mobile TN) for roaming registration and validation

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.

FCC TCPA Regulatory History Cont’d 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 company-specific 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.

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

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 Inter-modal 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.

NeuStar Contacts Lisa Turner, Manager, TCPA Compliance 571.434.5169 lisa.turner@neustar.biz