The Federal Communications Commission (FCC) should avoid imposing excessive restrictions on “non-conversational traffic,” CUNA and other organizations wrote to the FCC Wednesday. The comments were filed in response to a proposal involving methods to target and eliminate unlawful robocalls.

“As the Commission acknowledges, there are ‘wanted, and even important’ calls that fall within the proposed definition of non-conversational traffic, citing as examples, ‘emergency alerts, post-release follow up calls by hospitals, credit card fraud alerts,’” the letter reads. “The Commission further notes that intermediate or terminating carriers “not comfortable with potential liability for carrying non-conversational traffic” might block these important communications.  

“This concern is greatly amplified if the Commission were to impose strict liability on voice service providers that originate or pass illegal non-conversational traffic notwithstanding their good-faith mitigation efforts,” it adds.

The organizations also urge the FCC to:

• Take further steps to curb illegal spoofing by requiring voice service providers using non-IP networks to authenticate caller ID using commercially available technology.
• Move cautiously before imposing further restrictions on the use of U.S. numbers for foreign-originated calls.