This is absolutely spot on, with the caveat that you do need to disaggregate from accounts to people, which is the hard problem. Having people call a phone number is definitely not going to work as a way of achieving this disaggregation. I'm pretty sure I could create a system to bring that call center to a halt with fairly minimal cost in less than a week of coding.
As an attacker, you can also hire people in call centers to make phone calls at scale for you.