ACA will be filing reply comments, due Feb. 28, 2020, with some additional information about industry harm as a result of over-broad blocking efforts.
1/30/2020 12:00
ACA International outlined in recent comments that call blocking tools authorized by the Federal Communications Commission continue to limit much-needed communication to consumers and restrict and mislabel lawful, legitimate calls—in one instance 97,006 outbound calls in a week for a member company.
In the comments, ACA outlined examples of how the accounts receivable management industry is being harmed by faulty blocking and mislabeling and provides suggestions to the FCC to improve the environment for legitimate callers. ACA also outlined how new requirements in the TRACED Act mandate that carriers provide transparency and redress options for callers and directs unblocking to be done at no cost to callers.
“ACA International strongly supports the commission’s efforts to target the serious problem of illegal, scam, and fraudulent automated calls. However, in conjunction with representatives from numerous other industries, ACA has expressed substantial concerns to the commission that a significant number of consumers may be harmed by the FCC’s recent Declaratory Ruling because lawful, legitimate calls continue to be blocked and mislabeled in the wake of the FCC’s actions,” said Vice President, Senior Counsel of Federal Advocacy Leah Dempsey. “ACA in comments filed this week reminds the commission that blocking legitimate calls can ‘have life or death consequences for the intended recipient’ and these concerns should be at the forefront of any policymaking in this area.”
The FCC’s review of the call blocking tools, the Caller ID Authentication and SHAKEN/STIR, is to inform a report required through the commission’s approval of call blocking as the default option in an effort to reduce automated, unwanted robocalls.
The FCC’s Consumer Advisory Committee (CAC) approved a recommendation on the effectiveness of call blocking tools during a special meeting Feb. 13.
Stakeholders were asked to comment on several issues for the FCC’s first staff report on call blocking, including:
- The availability of call-blocking tools;
- The effectiveness of call-blocking tools;
- The impact of FCC actions on call blocking;
- The impact on 911 services and public safety; and
- “Any other information that may inform the commission’s analysis of the state of deployment of advanced methods and tools to eliminate illegal . . . calls.”
As an overarching matter, ACA is concerned that most of the questions posed in seeking feedback for the FCC’s report are aimed at voice service providers, with minimal fact-finding about the June 6 Declaratory Ruling’s impact on legitimate callers placing lawful calls.
“Because the FCC has not required voice service providers to implement a uniform call-blocking disclosure and has put few parameters around what these disclosures should include, consumers and callers are unlikely to know where or what to look for to determine the source of blocking and may not know how to stop legitimate calls from being blocked,” Dempsey said.
In its comments, ACA strongly urges the FCC to consider providing more uniform requirements for unblocking calls.
It would help ACA members and organizations impacted by the Declaratory Ruling—particularly smaller businesses—have more options to reliably and cost-effectively determine the exact percentage and source of the blocking.
Currently, ACA members report that they are still not being given notice from providers when calls are being blocked and most providers have not developed a simple or workable challenge mechanism for unblocking calls.
One member told ACA about 39% of its outbound calls were being blocked in the fall of 2019, including 97,006 blocked calls in just one-week last November
On an annualized basis in 2019, another member said that it had 311,195 blocked connections.
ACA continues to seek data from members to inform the FCC of the impact of current call blocking efforts. ACA will be filing reply comments due Feb. 28, 2020, with some additional information about industry harm as a result of overbroad blocking efforts.
“Without a definitive and uniform mechanism for detecting call blocking, callers will not know the extent of call blocking and the commission will not be able to collect any useful data from callers to ascertain issues,” Dempsey said.
ACA also urges the FCC to clarify that voice service providers may no longer rely on “reasonable analytics” to block “unwanted robocalls” on an opt-out basis and require voice service providers to give notice when they place a derogatory label on a business’s outbound calling number which would be consistent with the TRACED Act now signed into law. One year after enactment of the TRACED Act, it is required that robocall blocking services include transparency and effective redress options for consumers and callers.
The FCC is strongly encouraged to provide further consideration to this major problem for its report and before issuing a final order concerning SHAKEN/STIR.
ACA’s advocacy team continues to seek important member insights on their experiences with call blocking and mislabeling.
Related content from ACA International:
FCC Opens Call Blocking Comment Period; ACA Continues Advocacy for Members
FCC Sets Special Meeting on Call Blocking and Labeling Data; Share Your Insights with ACA