The comment request is part of the FCC’s comprehensive proposed rule on mitigating illegal robocalls through requirements for voice service providers.
07/13/2023 12:05 P.M.
3.5 minute read
The Federal Communications Commission is moving forward with a proposed rule that would implement call blocking notification requirements for voice service providers, among other items.
Of note for members and the accounts receivable management industry, the FCC is expanding proposed requirements for voice service providers to block illegal robocalls, while also making sure legitimate calls get through.
The FCC seeks public comment on:
- Requiring voice service providers to adopt analytics-based blocking.
- Requiring providers to block calls based on reasonable do-not-originate lists.
- Whether to require the display of caller name information in certain cases, and increasing forfeitures for voice service providers that fail to comply with the FCC’s rules.
The FCC also seeks comment on a number of other call blocking issues, including on requiring a single Session Initiation Protocol (SIP) code for immediate notification to callers whose calls are blocked based on analytics and requiring terminating providers to display caller name information when they provide an indication to the call recipient that the call has received “full” or “A” attestation.
According to the FCC, the proposal is to hold voice service providers accountable for calls on their networks through call blocking requirements and to determine the correct way to notify callers when calls are blocked based on reasonable analytics.
ACA International’s advocacy team has worked with the FCC on behalf of members to ensure it understands the industry’s need for communications with consumers to be protected while supporting mitigation against bad actors.
This request for comment is an opportunity to further that advocacy and provide industry input on call blocking notification procedures.
For members, communication with your phone carriers is key to understanding their obligations and to minimize the chances that your calls will be blocked or mislabeled, or, if they are, how to get them unblocked. Similar discussions can reduce the threat of blocked text messages.
ACA recently issued resources to navigate that communication with your phone carriers, including a memorandum on telephone companies’ robocall mitigation obligations and a checklist to review those obligations with your carriers, ACA previously reported.
Comments on the proposed rule are due Aug. 9, and reply comments are due Sept. 14.
To submit comments online, select “Submit a Filing” on the FCC’s electronic comment filing system and identify comments under CG Docket No. 17-59.
Members may also submit feedback to inform ACA’s comments to [email protected].
Comments on Call Consent
The FCC also seeks comments on a proposed rule that would extend consumers’ rights to revoke consent they previously gave to receive robocalls and robotexts. Comments are due July 31, according to a notice in the Federal Register.
The proposed rule also seeks to clarify callers’ obligations to honor consumers’ requests.
The proposed rule approved at the FCC’s June 8 commission meeting codifies its 2015 Telephone Consumer Protection Act ruling “confirming that consumers who have provided prior express consent to receive autodialed or prerecorded voice calls may revoke such consent through any reasonable means,” according to a news release (PDF).
The proposed rule would also close a loophole that allows some callers to make robocalls and send robotexts without a consumer’s consent or ability to opt out, according to the FCC.
Callers are asked to provide feedback on whether they have experienced any challenges complying with consumers’ requests to revoke consent through any reasonable method, ACA previously reported.
The FCC is also seeking comments on whether callers have had specific issues or circumstances it should address in the proposed rule to clarify what makes a revocation request reasonable for a consumer and a caller.
Commenters are also asked to provide feedback on whether the FCC has found an appropriate balance between consumers’ privacy and “facilitating the caller’s ability to process opt-out requests.”
Callers have the opportunity to share if there are any common situations where they are unable to process consumers’ opt-out requests and how the FCC could address those situations without placing a burden on consumers.
Following the July 31 comment deadline, reply comments on the proposed rule are due Aug. 14, 2023.
To submit comments online, select “Submit a Filing” on the FCC’s electronic comment filing system and identify comments under CG Docket No. 02–278.
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