CUNA continued its engagment with the Federal Communications Commission by sending a joint letter supporting FCC’s goals of eliminating illegal automated calls but working to ensure consumers receive important, time-sensitive calls from financial institutions, healthcare providers and other legitimate entities. CUNA has long called on the FCC to ensure legitimate calls to consumers not fall under the agency’s efforts to eliminate illegal robocalls.

“These calls include, for example, safety alerts, fraud alerts, data security breach notifications, product recall notices, healthcare and prescription reminders, power outage updates, and other necessary account updates needed to maintain financial health,” the letter reads. “It is critical for consumers that these calls be completed without delay, and that the caller and call recipient are notified immediately when a call is blocked. When those calls are blocked, the Commission’s rules should ensure that businesses can promptly have the block removed.”

Specifically, CUNA and the other organizations call for modifications to the FCC’s June 25 Draft Order providing a safe harbor for voice service providers that block calls based on “reasonable analytics designed to identify unwanted calls,” as long as the analytics incorporates call authentication information into the blocking decision.

The letter notes the FCC should:

• Require an entity that blocks calls to notify callers immediately that it is blocking their calls;
• Require a voice service provider to remove an erroneous block within 24 hours of the provider’s learning of the block.
• 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;
• Confirm that the obligation on terminating voice service providers to provide callers with effective redress options applies equally to mislabeled outbound calling numbers;
• Confirm that implementing the required redress mechanism is a condition of receiving the protections of the safe harbor; and
• 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.