By Simon Woodhead
Background and ‘Why’
In 2018 we modified our porting policy, attempting to redress the disproportional cost of the few exports we do, especially by those who would attempt to abuse the process (and us) with what we call fraudulent “wholesale ports”. We did this by levying a charge for exports, which in no way covered the true cost and which was fully creditable against imports. Thus, those customers porting in and seeing natural ports out had zero cost because the charge for the export would be credited against their next two imports. This has worked well for most customers.
One area where it hasn’t worked is for those customers who lose a substantial customer of their own and end up with a large export charge from us and thus a large credit which they may not be able to work off. We’re still under water for the cost of the export whether they work it off or not but this has caused some angst and we want to overcome that.
Of course, this situation is not helped by us being singularly unique in the marketplace in actually telling you what our policy around wholesale ports is. We think that is a good thing but it seems silence leads to presumed innocence for some! The fact is we invited every one of our competitors to join an initiative whereby porting was frictionless and without stress – and they all declined. We also know that whilst our policy on exports seeks to avoid the cost through abuse, others seek to avoid revenue loss. They’re entitled to do so as the porting process exists for end-users, not abuse by resellers, but evidently we have the fairer policy amongst our peer group, yet we tell you about it beforehand rather than you be shocked later.
It is further not helped by those resellers who call themselves wholesale, or even CPaaS in some corners of fantasy land, and who have assertively criticised our policy claiming their own to be so much fairer. Of course they don’t actually have a policy as they’re beholden to the unpublished policy of the Simwood peer they resell. Sigh.
Anyway, we’re not about to keep our policy a secret until we need to wield it, we’re not about to change it in the name of profit protection, and we’re not about to enter fantasy land and talk about realities we know nothing of and have no control over!
But we do want to do what is fair by our loyal customers, what we believe is fairer than our peer group (if they came clean) but insulate ourselves somewhat against the cost of exports, especially where they are fraudulent. In a world where an export costs us £150 per number (we acknowledge this could be weighted given how few we need to do) and at the wholesale level we make on average 9p per month (gross profit) on each seat you sell, the numbers just do not work for us at any reasonable level of churn. Thankfully, you and we generally don’t have any, and we still import many many times the volume of numbers we export.
Effective May 1st, we’ll be making the following changes:
- For customers who are ‘in contract’, there will be no charge for exports!
- For all customers who are ‘out of contract’ we will be mirroring our import fees for export attempts, including for hosted numbers.
- We will no longer be offering any additional credit of these fees against imports. Credits already earned will be honoured and allowed to work through or expire. So you don’t earn any more after May 1st, but you don’t lose the ones you accrue until May 1st.
A key term here is ‘in contract’ and by that we mean those Startup (excluding Startup Legacy customers), Virtual Interconnect or Managed Interconnect customers who have signed an agreement for a period of time, and which has time left to run. We value your loyalty and this seems fair to us. You may recall for Virtual Interconnect and Managed Interconnect customers, we changed our numbering pricing last year such that the rental charge was for the entire contract term (be that 1, 3 or 5 years!) or monthly for those no longer ‘in contract’. This has proved very popular and we hope to repeat that.
What isn’t changing is our policy on fraudulent wholesale ports, which we maintain is the fairest we know of. Those who attempt to commit porting fraud are reminded of the terms of our MSA and the £150 charge per port attempt where deemed to be, and notified of, doing so. To reassure the majority of customers who this will never apply to, we only have one account in this status at the moment and do not exercise this right lightly. It is absolutely not something a good customer who has the odd legitimate export, even of a large end-user estate, needs to ever worry about.
Whilst I aspire to a Ramsay-esque policy of ‘don’t want to be our customer, f*%$ off then’, largely given the toxicity around attempted porting fraud, that simply isn’t economically feasible given the long-term costs of allowing it. As a reminder, 80% of incoming calls to Simwood numbers or numbers ported in come over our expensive BT SS7 capacity because BT are often the original rangeholder. Where a Simwood number ports away, that potentially uses double the capacity (once on the way in, once on the way out). Once that capacity is over IP, or Ofcom pull their finger out and get rid of onward routing in the UK, my desired policy will be possible.
Of course, uniquely amongst our peer group, we do not stand in the way of porting fraud for non-Simwood numbers – we lose revenue but we do not have long-term cost because when they port away we see no calls for them. Whereas competitors wish to protect their revenue by blocking these too, we simply wish to avoid the cost.
We will also, uniquely again, enable accounts to go into a dormant state if the situation arises, i.e. numbers don’t leave, calls are delivered by SIP, but you get no support, API etc. from us. Again, this feels fair in allowing ex-customers to achieve what they want, in a way which isn’t allowing them to commit fraud against us and incur us lifetime costs.
Lastly, who is really who
For customers seeking to port numbers from other operators it can be very hard to know who is who. Despite appearances and pleas to the contrary, there are only five of us in the UK market-place who host number ranges at any scale for other operators, and they are:
- BT IPEX
With the exception of BT, we generally all have a similar policy of including hosted ranges under our own porting agreements, and we have porting agreements with all of the above.
However, there is no resource in the public domain that enables you to look up a range-holder and see where they may be hosted. You can of course look up who the range-holder is quite easily from Ofcom data. Our portal and API have attempted to guess the host network for you in the past but it is imperfect. So we’ve decided to publish a list!
Customers with a login can see this in our knowledge-base and we’ll keep it up to date as we remember or learn of new hosting arrangements. I appreciate some won’t like this level of transparency, but if everyone is adding value to the end user, they have absolutely no reason not to. Any particularly awesome, gorgeous and dynamic operators not shown on this list will likely be hosted by Simwood, and we’re happy to confirm where an internal port is possible.
You never know, maybe our peers will publish their own list showing who we host, right alongside their porting policy perhaps?