ACA International Submits Comments Urging the FCC to Require Call Blocking Mitigation Mechanisms

ACA describes the harm caused to legitimate debt collectors and consumers through current robocall processing tools; argues that it is essential for legitimate callers to know when a call is being blocked and to have a quick and easy way to challenge improperly blocked calls.

1/24/2018 12:00 PM

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ACA International Submits Comments Urging the FCC to Require Call Blocking Mitigation Mechanisms

On Tuesday, Jan. 23, ACA International submitted comments in response to a Further Notice of Proposed Rulemaking (FNPRM) adopted by the Federal Communications Commission Nov. 17, 2017. The FNPRM sought comment on call blocking mitigation options, including the need for a challenge mechanism for erroneously blocked calls.

As ACA has previously described, legitimate business calls are being blocked and mislabeled by call processing tools already in the marketplace. This trend will likely continue to become more prevalent in the absence of FCC intervention, harming businesses and consumers who lose access to timely information.

In the comments, ACA asserts that legitimate call originators need to know if a call has been blocked, as well as to be able to access a clear mechanism to quickly rectify any errors. However, neither one of these fundamental needs is presently being met. To remedy these issues and to ensure consistent call blocking mitigation mechanisms are in place, ACA urges the FCC to adopt call blocking mitigation mechanisms that apply both to provider-initiated and consumer-initiated call blocking.

In addition, while not the specific subject of the FNPRM, ACA points out that improper call labeling raises similar issues to erroneous call blocking. As such, ACA urges the FCC to consider future mitigation mechanisms in the call labeling context as well. In both instances, not only is the originating caller harmed, but the consumer who did not receive a call due to erroneous blocking or chose not to answer based on an improper “scam likely” label is deprived of important information.

In the comments, ACA also discusses the negative impact that erroneous call blocking and improper labeling has had on legitimate debt collection calls. ACA shares preliminary feedback from its ongoing survey of ACA member experiences with call processing tools. This input demonstrates the need for callers to know when a call has been blocked, the challenges associated with not having a clear and reliable mechanism for fixing errors, and the resulting harm to consumers who cannot be reached to resolve their accounts, including negative credit reporting, litigation or wage garnishment.

Finally, ACA offers responses to specific questions posed by the FCC in the FNPRM while noting similar considerations apply in the call labeling context. Ultimately, ACA advocates that the FCC should require providers who offer call blocking services to

(1) Indicate a call has been blocked on a per-call basis using a defined, unique signaling code;

(2) Make available a defined, easy to use mechanism for callers to inquire about the blocking status of a number or set of numbers; and

(3) Make available a defined, easy to use mechanism for callers to challenge the status of a  blocked number or set of numbers. 

ACA believes that through these reasonable mitigation measures, the FCC will achieve a better balance of protecting consumers from unlawful robocalls while ensuring consumers are not inadvertently losing access to important communications with legitimate businesses.

ACA continues to encourage its members to please share with us your experience related to call blocking and call labeling. If you are an ACA member who has learned that your calls are being erroneously blocked and/or improperly labeled, please share your feedback with ACA by clicking on the box below.

Call Blocking Intake Form  


Follow ACA International on Twitter @ACAIntl and @acacollector, Facebook and request to join our LinkedIn group for news and event updates. ACA International members are welcome to submit news items for possible publication to comm@acainternational.org. Visit our publications page for news submission guidelines and subscriptions to ACA Daily, Collector magazine and Pulse.

Advertising is available for companies wishing to promote their products or services. Be sure to visit the ACA Events Calendar on the Education and Training page to view our listing of upcoming CORE Curriculum and Hot Topic seminars featuring critical educational opportunities for your company.


Subscribe to ACA Daily NEWSROOM

ACA International Submits Comments Urging the FCC to Require Call Blocking Mitigation Mechanisms

On Tuesday, Jan. 23, ACA International submitted comments in response to a Further Notice of Proposed Rulemaking (FNPRM) adopted by the Federal Communications Commission Nov. 17, 2017. The FNPRM sought comment on call blocking mitigation options, including the need for a challenge mechanism for erroneously blocked calls.

As ACA has previously described, legitimate business calls are being blocked and mislabeled by call processing tools already in the marketplace. This trend will likely continue to become more prevalent in the absence of FCC intervention, harming businesses and consumers who lose access to timely information.

In the comments, ACA asserts that legitimate call originators need to know if a call has been blocked, as well as to be able to access a clear mechanism to quickly rectify any errors. However, neither one of these fundamental needs is presently being met. To remedy these issues and to ensure consistent call blocking mitigation mechanisms are in place, ACA urges the FCC to adopt call blocking mitigation mechanisms that apply both to provider-initiated and consumer-initiated call blocking.

In addition, while not the specific subject of the FNPRM, ACA points out that improper call labeling raises similar issues to erroneous call blocking. As such, ACA urges the FCC to consider future mitigation mechanisms in the call labeling context as well. In both instances, not only is the originating caller harmed, but the consumer who did not receive a call due to erroneous blocking or chose not to answer based on an improper “scam likely” label is deprived of important information.

In the comments, ACA also discusses the negative impact that erroneous call blocking and improper labeling has had on legitimate debt collection calls. ACA shares preliminary feedback from its ongoing survey of ACA member experiences with call processing tools. This input demonstrates the need for callers to know when a call has been blocked, the challenges associated with not having a clear and reliable mechanism for fixing errors, and the resulting harm to consumers who cannot be reached to resolve their accounts, including negative credit reporting, litigation or wage garnishment.

Finally, ACA offers responses to specific questions posed by the FCC in the FNPRM while noting similar considerations apply in the call labeling context. Ultimately, ACA advocates that the FCC should require providers who offer call blocking services to

(1) Indicate a call has been blocked on a per-call basis using a defined, unique signaling code;

(2) Make available a defined, easy to use mechanism for callers to inquire about the blocking status of a number or set of numbers; and

(3) Make available a defined, easy to use mechanism for callers to challenge the status of a  blocked number or set of numbers. 

ACA believes that through these reasonable mitigation measures, the FCC will achieve a better balance of protecting consumers from unlawful robocalls while ensuring consumers are not inadvertently losing access to important communications with legitimate businesses.

ACA continues to encourage its members to please share with us your experience related to call blocking and call labeling. If you are an ACA member who has learned that your calls are being erroneously blocked and/or improperly labeled, please share your feedback with ACA by clicking on the box below.

Call Blocking Intake Form  


Follow ACA International on Twitter @ACAIntl and @acacollector, Facebook and request to join our LinkedIn group for news and event updates. ACA International members are welcome to submit news items for possible publication to comm@acainternational.org. Visit our publications page for news submission guidelines and subscriptions to ACA Daily, Collector magazine and Pulse.

Advertising is available for companies wishing to promote their products or services. Be sure to visit the ACA Events Calendar on the Education and Training page to view our listing of upcoming CORE Curriculum and Hot Topic seminars featuring critical educational opportunities for your company.


Subscribe to ACA Daily NEWSROOM

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