The phone-scam economy: actors, enablers and evidence.

What this report establishes.

This report maps the phone-scam economy behind a US debt-relief robocall campaign and the enablers that make similar campaigns reach American victims. It is built from public records, not from a single victim's call log. The register contains 375 actors and entities, 152 of them entities, and 223 edges. Every row carries an evidence URL, a quote or precise record cite, a source type and a confidence label.^[S1][S2][S3]

The campaign is not a collection of unrelated brands. It is a family of ten US entities and four individuals, named in 19 federal TCPA dockets and MDL No. 3123, with a final Minnesota Department of Commerce consent order dated 2024-10-03. The brands the caller speaks, including Rencrest Capital, Iron View Financial, Waypoint Financial and Seacoast Lending, have no corporate existence. They are the script's watermark, not a defendant.^[S32][S31]

The public record supports 33 candidate Better Debt numbers: 9 multi-cluster numbers in the FCC complaint graph and 24 transcript-linked voicemail lines. It does not support 200. The largest rotating pools in the FCC data are 216, 198, 116 and 113 numbers. Two of them match the Alliant Financial campaign on brand and window: the FCC's May 20, 2024 cease-and-desist letter names Alliant Financial and Mohammad Hossain, its member of management, and reports YouMail estimates of 16.1 million Alliant, 13.5 million Main Street Financial and 48.7 million One Street Financial calls, 78.3 million in total. The per-number subscriber is still unnamed. The same day, a K4 public notice allowed US carriers to block Alliant's traffic outright. The report keeps that distinction: a cluster is an operation, not a defendant.^{[S4][S37][S38]}

The US carrier layer is documented. Five RespOrgs hold the campaign's 31 toll-free lines: Excel Telecommunications (12), Telnyx (9), Inteliquent (5), thinQ (4) and Pestilence Labs (1). Inteliquent and thinQ have public enforcement records. Two additional US gateways, Telcast Network LLC and Peerless Network, Inc., have FTC cease-and-desist letters naming debt-relief and other campaigns. None of these carriers is campaign-attributed to Better Debt Solutions. They are the regulator and subpoena lane, not the private defendant.^{[S6][S7][S8][S10][S11][S12]}

The class-action route is narrower than it looks. MDL 3123 was denied centralization, leaving 19 separate dockets. No settlement or consumer-redress fund exists in any Better-family matter. Payment processors, lead buyers, brokers, offshore centers, brand-only shells and the individual controllers' assets are named in no class action. That is the white space a firm could file into.^[S19][S31]

How the register was built.

The unit of analysis is the actor, not the number. A number is evidence of a call. An actor is a person or company that can be served, subpoenaed or referred to a regulator. The register links actors to entities, numbers, cases and edges.^[S1]

The FCC corpus extraction covered 170,260 rows and 86,963 distinct 8xx numbers. The number graph uses the advertiser-caller relationship: the advertised callback is the storefront, and every caller ID that advertised it is part of a rotating pool. The script graph uses the victim report text. The two graphs are kept separate because a number match is not a script match, and a script match is not an actor.^[S4][S18]

Every actor carries a status label: convicted adjudicated partially-adjudicated settled-no-admission dismissed-with-prejudice named-not-adjudicated identified-not-charged no-public-record. A name in a complaint is not a finding. An arrest is not a conviction. A regulator's letter is not a judgment.^[S20]

Twelve findings.

1. The campaign is one operator family, not many brands. Better Debt Solutions LLC, nine affiliates and four individuals are named in 19 federal TCPA dockets. The brands are script labels with no corporate existence.^[S1][S32]
2. The strongest state record is final. The Minnesota Department of Commerce consent order against Better Debt Solutions, dated 2024-10-03, imposes a $10,000 penalty and $348.75 investigation fee and states that the action is final.^[S32]
3. MDL 3123 did not centralize. The JPML denied transfer on 2024-10-04, leaving 19 separate dockets in 11 courts. The caption persists as a plaintiff calling card.^[S31][S19]
4. The public record supports 33 Better Debt numbers, not 200. Nine are multi-cluster numbers in the FCC graph; 24 are transcript-linked voicemail lines. The 33 is a ceiling, not an inventory.^[S4]
5. The campaign's own callbacks carry 0 to 2 complaints each. The complaint volume sits on the outbound caller IDs. The callback rotates before complaints accumulate.^[S4]
6. The callback often never answers. The client's recordings ring out with no voicemail pickup. The transfer, if it happens, is on the outbound call. The callback is a display or tracking number.^[S18]
7. The voice layer is consistent. The voicemails sound like a white American English speaker, consistent with an AI voice or a US-trained front. The public r/Scams reports match.^[S18]
8. Four script families survive the number rotation. S1 hardship/underwriting, S2 unbranded option, S3 income-based/no-minimum-score, and S0 for one unrecovered transcript. S1 covers 23 variants across brands, reps and callbacks.^[S18]
9. Five RespOrgs hold the 31 lines. Excel 12, Telnyx 9, Inteliquent 5, thinQ 4, Pestilence Labs 1. Inteliquent and thinQ have enforcement records. Excel, Telnyx and Pestilence Labs have no public enforcement record found.^[S6]
10. Two more US gateways are on notice. Telcast Network LLC and Peerless Network, Inc. received FTC cease-and-desist letters dated 2023-03-17. Peerless's letter names 25 campaigns, including DebtRelief-COVID-19Payment and DebtRelief-ZeroTax. Neither is campaign-attributed to Better Debt.^[S7][S8]
11. The payment rail is the gap. Nexway, Nuvei, Paddle and Restoro/Reimage are current processor precedents. No processor is campaign-attributed to Better Debt. The missing bridge is the ACH descriptor plus merchant ID plus KYC file.^[S21]
12. The class-action white space is the middle. Payment processors, lead buyers, brokers, offshore centers, brand shells and individual assets are named in no class action. The 19 dockets are entity-tying and arbitration fights.^[S19]

Seven layers, and who can be reached.

The table is not a list of defendants. It is a list of places where the record exists. The operator family is the only layer with a currently pleadable private TCPA case. The carriers and processors are the layers where a regulator can act and a subpoena can name the subscriber. The broker and the offshore center are the layers where the public record stops.^[S20][S19]

Who clusters by scheme type.

The master register is normalized into five scheme types. An actor can appear in more than one. The counts below are cluster memberships, not unique actors.^[S5]

The health vertical is a lead-broker business: 35 of its 56 memberships are lead generators or brokers. The crypto vertical is an operator-and-payment business: 35 operator memberships and 14 payment memberships. The debt vertical is the most balanced, with operators, lead brokers, carriers, brands and payment. That balance is why the debt campaign is the best-documented end-to-end chain in the file.^[S5]

The eleven cross-vertical enablers.

These actors appear in two or more scheme types. They are the highest-value targets because they profit from more than one campaign, and the common layer is usually the carrier or the lead broker.^[S5]

The carriers that make the calls reach the United States.

A toll-free number is a storefront with a registry record. The RespOrg is the entity that manages the number in the Somos registry. The carrier connects the call. Neither is the caller. The carrier is paid by the minute, so it profits from the traffic whether or not the scam succeeds.^[S6]

Two additional US gateways sit outside the 31-line set but on the same infrastructure. Telcast Network LLC (Talal Khalid, Dover, Delaware) received an FTC cease-and-desist on 2023-03-17 for five campaigns and a second-and-final Task Force notice in April 2025 stating that it "continues to transmit" and did not take sufficient steps after the CID. Its FCC Form 499 status moved to inactive on 2024-04-01. Peerless Network, Inc. (John Barnicle, Chicago) received an FTC cease-and-desist on the same date naming 25 campaigns, including two debt-relief campaigns, and a Task Force notice on 2025-12-03 citing 5,662 tracebacks since January 2019.^{[S7][S8][S9][S10]}

Five playbooks, the same supply chain.

Each typology uses the same seven roles. The differences are the script, the victim data and the payment rail.^[S5]

7.1 Tech support

The victim sees a fake virus warning or receives a call about a computer problem. The caller claims to be Microsoft, Apple or Amazon, asks for remote access, then charges for a repair. The payment is by card. The processor is the chokepoint. The FTC's Nexway case, the Paddle settlement and the Restoro/Reimage settlement are the current precedents. FirstIdea Infotech in Noida and MUSK Communications in Bengaluru were raided in 2025.^[S21][S22]

Evidence. The pop-up URL, the callback number, the call recording, the remote-session log, the card statement and the merchant descriptor.^[S23]

7.2 Debt relief and hardship loans

The script is a pre-approval for a $41,200 to $41,600 hardship loan. The caller claims TransUnion and Equifax have updated the file. The callback is a 1-8xx number. The operation is the best-documented end-to-end chain in the file: ten entities, four individuals, 19 dockets, 33 candidate numbers, four script families, five RespOrgs, and a final state consent order.^{[S1][S4][S18]}

Evidence. Voicemail audio and transcript, callback number, caller ID, carrier CDR, bank or card statement, and the FTC/FCC complaint rows.^[S23]

7.3 Medicare and final expense

The caller offers a new government program or a final-expense benefit. The victim gives a Medicare number, a date of birth or a payment. The lead-broker layer is the largest in this vertical. Simple Health and Steven Dorfman were hit with a $195 million judgment and a permanent telemarketing ban. Assurance IQ and MediaAlpha paid $145 million. The DOJ sued eHealth, SelectQuote and GoHealth in May 2025. The HIMS case in Karachi is charged with $703.8 million in Medicare claims.^{[S15][S16][S24][S14]}

Evidence. Enrollment documents, call recording, policy number, commission statement if obtainable, and the bank or card record.^[S23]

7.4 Auto warranty and solar

The caller says the vehicle warranty is expiring or the home qualifies for solar. The FCC's auto-warranty case identified eight US providers carrying the traffic and assessed a $299,997,000 forfeiture against the Sumco Panama enterprise. CarShield paid $10 million in 2024. The vertical is smaller in the register, 17 actor memberships, but it uses the same carrier and payment layer.^[S17][S25]

Evidence. The mailer, call recording, contract, payment record and caller ID.^[S23]

7.5 Crypto and romance

The first contact is a wrong number, a dating match or a friendly message. Weeks later, the victim is on a fake investment platform. The money leaves by crypto or a US shell company. Prince Group and Chen Zhi were OFAC-designated, with about $15 billion in forfeiture. The Shunda and Tai Chang managers were charged, with more than $700 million restrained. The SEC brought its first pig-butchering cases against NanoBit and CoinW6. Huione Group was cut off by FinCEN under Section 311. The US laundering tier moved $36.9 million through US shell companies and banks into USDT.^{[S26][S27][S28]}

Evidence. Chat logs, platform URL, wallet addresses, transaction hashes, bank wires and fake balance screenshots.^[S23]

Who can be sued, and who cannot.

Three cautions. First, a carrier is not a private TCPA defendant on carriage alone, and the Stratics Networks case was dismissed with prejudice under Section 230 on 2024-03-06. Second, a brand name is not an entity. Third, a name in a complaint is not a finding; the status table in the register is the control.^[S29][S20]

In Arizona, small claims is capped at $5,000, no attorney may appear, and a TCPA case can be removed to federal court. The class action or an existing member case is the better economic route. The TCPA is not a fee-shifting statute, and the statutory damages are $500 per call, or $1,500 for a willful violation.^[S19]

What the record proves, and what it does not.

The lawyer's warning that a phone dump is "hearsay" is too broad. Machine-generated call-log rows are not statements. Text messages and voicemails are opposing-party statements when offered against the caller. The real gate is authentication under FRE 901, not hearsay. Chain of custody goes to weight.^[S23]

A defensible file has four layers: the client's testimony and device, a hash-verified export with a declaration, the carrier's call detail records, and a forensic extraction only if the authenticity is challenged. The original voicemail audio matters more than the transcript. The carrier's business record matters more than the handset log.^[S23]

The limits are real. The FCC corpus is a complaint record, not an ownership record. Caller ID can be spoofed. The RespOrg is not the subscriber. The offshore layer is outside US jurisdiction for a private case. The register marks each gap rather than filling it with an inference.^[S4][S6]

What a plaintiff firm should do next.

1. Preserve the client's evidence first. Original voicemail audio, hash-verified export, carrier CDRs, declaration and preservation letter. Do not rely on a raw phone dump.^[S23]
2. Join or contribute to the existing Better Debt dockets. The entry points are Rozanski (Kazerouni, newest) and James (Javitch/Iskander, Better Rise tier). Add targeted discovery for telephony providers, payment processors and affiliate contracts. The current dockets do not name them.^[S19]
3. Subpoena Inteliquent first. It holds five of the 31 lines, has 9,712 tracebacks and a live Task Force notice. Then Excel (12 lines, all 2026), Telnyx, thinQ and Pestilence Labs. Ask for subscriber of record, port history, CDRs and billing.^[S6][S11]
4. Run the regulator lane in parallel. FCC complaint with the cluster extract; FTC report; Arizona AG complaint; a one-page NCCIA referral with the script and voicemail evidence. The Task Force is already investigating Inteliquent and Telcast.^{[S9][S10][S11]}
5. Add RICO only after a fee is documented. The count is leverage, not a substitute for the TCPA. The foreign layers face RJR Nabisco's domestic-injury requirement.^[S19]
6. Do not sue the carriers or the brands. The carriers are subpoena and regulator targets. The brands are not entities. The Stratics dismissal is the caution.^[S29]

Source appendix.

The full register has a source URL and a confidence label on every row. The appendix below covers the claims in this report. Where a record is a government or court document, it is marked citable. Where it is press, a vendor page or a community report, it is marked lead.

1. [S1]Master actor register. 375 actors, 152 entities, 223 edges. actors.csv. citable / lead per row
2. [S2]Lead and live-transfer prices. LeadsRefer, HyperTarget, SalesPromis. LeadsRefer. lead
3. [S3]Edge register. edges.csv. citable / lead per row
4. [S4]Number-to-actor clusters. 170,260 FCC rows, 86,963 8xx numbers, 4,383 pools, 33 Better Debt candidates. FCC corpus; number-clusters.csv. citable for FCC rows; lead for attribution
5. [S5]Actor clusters by scheme type. actor-clusters.csv. inference from the register
6. [S6]Carrier and RespOrg map. Somos; org-map.csv. citable registry fact
7. [S7]FTC cease-and-desist to Telcast, 2023-03-17. ftc.gov PDF. citable
8. [S8]FTC cease-and-desist to Peerless, 2023-03-17. ftc.gov PDF. citable
9. [S9]Task Force notice to Peerless, 2025-12-03, 5,662 tracebacks. ag.hawaii.gov PDF. citable
10. [S10]Task Force second-and-final notice to Telcast, April 2025. ncdoj.gov PDF. citable
11. [S11]FTC warning to Inteliquent, 2022-05-10; Task Force notice, 2025-12-03, 9,712 tracebacks. FTC; nmdoj.gov PDF. citable
12. [S12]FCC cease-and-desist to thinQ, 2022-03-22. fcc.gov. citable
13. [S13]US v. Augustinsky, E.D. Va. 2:25-cr-97, convicted 2026-07-21. justice.gov. citable
14. [S14]US v. Charolia et al., N.D. Ill. 1:25-cr-00304, $703.8M Medicare claims. justice.gov. citable
15. [S15]FTC v. Simple Health, $195M, 2024-02-09. ftc.gov. citable
16. [S16]FTC, Assurance IQ and MediaAlpha, $145M, 2025-08-07. ftc.gov. citable
17. [S17]FCC auto-warranty order and Sumco forfeiture, 2023-08-03. fcc.gov. citable
18. [S18]Script fingerprints and client observations. script-fingerprints.csv. citable as the client's record; lead for pattern
19. [S19]Class-action and counsel map. class-action-map.csv. citable / lead per row
20. [S20]Case records and unadjudicated actors. case-evidence.csv. citable / lead per row
21. [S21]FTC v. Nexway, $16.5M, 2024; Paddle, June 2025; Restoro/Reimage, March 2024. FTC Nexway. citable
22. [S22]Tech-support and government-imposter record. FirstIdea Infotech (CBI, July 2025), MUSK Communications (Bengaluru, August 2025), American Tax Service. tech-gov.csv. citable / lead per row
23. [S23]Phone-evidence memo and collection SOP. Authentication, hearsay, hash and declaration. FRE 901; FRE 902. practice guidance, not legal advice
24. [S24]DOJ v. eHealth, SelectQuote and GoHealth, D. Mass., May 2025. justice.gov. citable, not adjudicated
25. [S25]CarShield, $10M, July 2024. ftc.gov. citable
26. [S26]Crypto and romance record. Prince Group OFAC designation; Shunda/Tai Chang; US laundering tier; NanoBit; CoinW6; Huione. crypto-romance.csv. citable / lead per row
27. [S27]SEC v. NanoBit and related pig-butchering cases. sec.gov. citable
28. [S28]FinCEN Section 311 action against Huione Group, 2025. fincen.gov. citable
29. [S29]US v. Stratics Networks Inc., S.D. Cal. 3:23-cv-00313, dismissed with prejudice under Section 230 on 2024-03-06. FindLaw. citable
30. [S30]Canada. CASL private right suspended (SI/2017-31); Competition Act and provincial consumer law. CRTC. citable statute / regulator
31. [S31]MDL No. 3123 order denying transfer, 2024-09-24. jpml.uscourts.gov PDF. citable
32. [S32]Minnesota Department of Commerce consent order against Better Debt Solutions, 2024-10-03; BBB profile. BBB. citable
33. [S33]FCC unwanted-calls corpus (vakf-fz8e). opendata.fcc.gov. citable
34. [S34]FTC Do Not Call reported calls and WhoCalledLookup snapshot, retrieved 2026-10-22. ftc.gov. lead, second complaint stream
35. [S35]Arizona small claims and TCPA. A.R.S. § 22-503; A.R.S. § 22-512; 47 U.S.C. § 227. azleg.gov. citable statute
36. [S36]CourtListener RECAP dockets for the Better-family cases and related proceedings. CourtListener. citable
37. [S37]FCC cease-and-desist letter to Alliant Financial, EB-TCD-23-00035896, 2024-05-20. Address 1016 W Jackson Blvd, Chicago; Mohammad Hossain, member of management; 13 ITG tracebacks, 2023-11-10 to 2024-02-03; the three YouMail call-volume estimates. fcc.gov. citable
38. [S38]FCC K4 public notice, DA-24-467, 2024-05-20, permitting US providers to block Alliant Financial traffic. fcc.gov. citable

This report is research, not legal advice. It does not assert liability against any person or entity. A name in a complaint is a lead, not a finding. The status of every actor is recorded in the register, and the register is current to 2026-10-22.