ACA and a coalition of associations outlined efforts seeking clarity on the FCC’s draft order.
This week ACA International continued efforts with a broad coalition of associations to advocate for changes to the Federal Communications Commission’s draft order concerning call blocking, which will be considered by the commission on July 16, 2020. This action is the latest in a series of actions taken by the FCC to address “robocalls,” and has been a top focus of ACA’s advocacy to ensure that overly broad efforts do not limit legitimate business calls.
On Thursday, July 9, ACA filed a notice of ex parte presentation for meetings with the staff of Commissioners Brendan Carr, Michael O’Rielly, Jessica Rosenworcel, and Geoffrey Starks.
During the meetings, the associations discussed the points raised in their July 2, 2020, ex parte letter. Specifically, the associations asked that the commission make the following modifications to the draft order in order to protect consumers against illegal calls while ensuring that all voice service providers and third-party call-labeling service providers have the incentive to avoid mislabeling and erroneously blocking time-sensitive, legal calls on which consumers rely:
- The commission should require an entity that blocks calls to notify callers immediately that it is blocking their calls.
- The commission should require a voice service provider to remove an erroneous block within 24 hours of the provider’s learning of the block.
- The commission should clarify and confirm that a terminating service provider that blocks calls is prohibited from imposing a charge on callers for reporting, investigating, resolving, and, as appropriate, removing erroneous blocks promptly.
- The commission should confirm that the obligation on terminating voice service providers to provide callers with effective redress options applies equally to mislabeled outbound calling numbers.
- The commission should confirm that implementing the required redress mechanism is a condition of receiving the protections of the safe harbor.
- The commission should prohibit terminating voice service providers from blocking a fully authenticated call unless the provider can determine with a high degree of certainty that the call is unlawful through application of objective, defined criteria, and after investigation into the call.
This letter serves as the notice of ex parte for telephone calls that included representatives of the American Bankers Association, American Association of Healthcare Administrative Management, American Financial Services Association, Consumer Bankers Association, Credit Union National Association, Mortgage Bankers Association, National Association of Federally Insured Credit Unions, and the Student Loan Servicing Alliance with ACA.