Yesterday several industry groups filed comments with the Federal Communications Commission (FCC) regarding mechanisms to resolve erroneously blocked calls.  

On November 17, 2017 the FCC adopted rules to allow call carriers to block unwanted or illegal “robocalls.” The rules now allow voice service providers to block calls in these four categories:

  1. Calls from a phone number placed on a “do not originate” list by the number’s subscriber
  2. Calls from invalid numbers, like those with area codes that don’t exist
  3. Calls from numbers that have not been assigned to a provider
  4. Calls from numbers allocated to a provider but not currently in use

At the same time, the FCC issued a Further Notice of Proposed Rulemaking (FNPRM) to gather input on ways to minimize the effects of calls blocked in error. The deadline to submit comments on the FNPRM ended yesterday. Multiple groups submitted input, including the Professional Association for Customer Engagement (PACE) -- the Consumer Relations Consortium was a co-signer of these comments, as was Alorica, Inc. -- and ACA International.

In addition to providing detailed context, PACE suggested:

  1. Require carriers to offer a call blocking mitigation service for callers and called parties
  2. Provide a speedy Commission complaint procedure for callers whose requests to have their calls unblocked are ignored or denied
  3. Implement effective and appropriate reporting requirements to gather and make publicly-available data related to call blocking and blocking mitigation.

Among other guidance, ACA International suggested that the FCC should require providers who offer call blocking services, whether provider initiated or consumer initiated, 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. 

The full ACA International comment can be downloaded here.

The full PACE comment can be downloaded here.

Others who submitted comments include:

Comcast Corporation
CTIA (representing the Wireless Industry)
Danal, Inc.
Encore Capital Group
First Orion
Montgomery County, Maryland
National Council of Higher Education Resources (NCHER)
Noble Systems Corporation
The Voice of the Net Coalition
Federal Trade Commission

insideARM Perspective

For more background on this topic, including robocall labeling – which is not addressed in the FNPRM, please read the following insideARM coverage:

November 20, 2017: FCC Issues New Proposed Robocall Blocking Rules; Collectors Have a Unique Challenge

September 19, 2017: FCC Committee Meets About Unwanted “Robo” Calls; Makes More Recommendations.

September 11, 2017: The Gathering Avalanche: “Robocall” Blocking, and What Can be Done

Call labeling poses a challenge unique to debt collectors because of the potential for third party disclosure of the purpose of the call. Industry groups have been in dialogue with robocall application developers to identify a practical solution, however it has proven difficult to identify a label that 1) serves the purpose of providing accurate information to consumers, 2) prevents third party disclosure, and 3) is applicable to all possible types of debt.

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