CUNA submitted comments to the Federal Communications Commission (FCC) for their Third Further Notice of Proposed Rulemaking to regarding advanced methods to target and eliminate unlawful robocalls.
CUNA believes the FCC should direct voice service providers not to block “unsigned” calls under the SHAKEN/STIR framework until the framework has been fully implemented.
“Requiring providers to quickly unblock legal calls is necessary because the Commission has no authority to authorize the blocking of legal communications,” the letter reads. “The FCC should permit voice service providers to block only calls that have not been properly authenticated under the framework or authenticated, but the provider has concluded with a high degree of certainty that the call was placed illegally.”
The letter states that the FCC should discourage voice service providers from labeling calls as “debt collector.” Unlike the call labels of “spam” and “nuisance” — which describe illegally placed calls — servicing and collections-related calls are lawful and beneficial to consumers.
The FCC's proposed “Critical Calls List” should include numbers from fraud alerts, data breach notifications, remediation messages, utility outage notifications, product recall notices, prescription notices, and mortgage servicing calls required by Federal or State law.
In assessing the effectiveness of voice service providers’ solutions to the problem of illegal automated calls, CUNA believes the FCC should measure and report annually on the number of calls that providers have blocked erroneously.
CUNA also continues to engage lawmakers in Congress over legislation designed to address robocalls.