Industry Cautious on NPRM Expanding Robocall Rules

"The future of voice communications in the United States is in peril," said Numeracle. It asked the FCC to promote adoption of rich call data and know-your-customer practices to complement Stir/Shaken. Establish a do-not-originate list that includes "all categories of numbers that are highly likely to be illegal and can easily be blocked by providers," said Somos, which backed requiring all voice service providers to block calls based on a DNO list.

Require terminating providers to offer customers analytics-based blocking of calls with an option to opt out, said NCTA, saying its members currently offer this and have "seen significant benefits for consumers and industry partners in reducing the number of illegal calls that are able to transit voice networks." NCTA asked the FCC to not expand call blocking obligations after commission notification and displaying caller ID name or Rich Call Data information on authenticated calls "given the significant operational challenges presented by current proposals" and instead continue focusing on the industry's transition to IP networks. Consider the "limited personnel, technical, and financial resources of small and rural providers that make compliance with such unfunded mandates a significant burden," the Rural Wireless Association said.

Adopt session initiation protocol (SIP) code 603+ as the "exclusive means to notify callers of analytics-based blocking," said USTelecom. The group asked the FCC to ensure providers have the flexibility to "determine the best blocking mechanisms to protect their customers," saying it would allow providers to update and change their approaches as the landscape changes. "The full promise of Stir/Shaken has yet to be realized," said Verizon: The FCC should "focus on achieving the full benefits of Stir/Shaken before shifting its attention to the next iterations of call labeling technology." The carrier also backed the use of SIP code 603+ to notify originators of blocked calls.

Incompas said its members "continue to have concerns about terminating providers’ treatment and removal of critical information and data added to the call at the point of origination." It asked the FCC to adopt SIP code 608 for call blocking notifications, saying it would "provide transparency and effective redress to callers," which the Voice on the Net Coalition echoed in similar comments. Incompas also sought additional guidance on what constitutes reasonable analytics if it requires that calls be blocked if they're "highly likely to be illegal" based on such measures.

Reject calls to adopt SIP code 607 or 608, said Transaction Network Services, adding they "raise technical and cost-related challenges." TNS urged the FCC to not mandate caller name technologies "before they have been fully developed and are widely deployed throughout the industry."

Providers "must use high-quality analytics that identifies and blocks bad traffic," said YouMail. The FCC shouldn't "require terminating providers to deploy some form of analytics simply to meet a requirement to use analytics," it said, saying it would cause providers to implement "quick and dirty" analytics. YouMail asked the FCC to define "metrics of effectiveness" and allow industry "to determine how to meet the metrics."

Let branded calling technologies "mature and develop, rather than adopting regulations or mandates that might skew investments and inhibit this progress," said CTIA, which also encouraged the FCC to continue pursuing global initiatives as part of its efforts to curb illegal robocalls originating from abroad. A report published Thursday by Hiya said phone spam slightly decreased from Q1 to Q2, but phone fraud globally spiked to "new heights" in Q2.

Don't mandate analytics-based blocking on an opt-out basis for all terminating voice service providers, said the Cloud Communications Alliance: "There is no need for converting the current voluntary analytics blocking programs into mandates, especially for providers solely serving business customers." CCA said the FCC should confirm analytics blocking "only applies to illegal calls, not calls that are simply unwanted, as well as confirm that providers will be afforded a safe harbor."

The FCC should "exercise care to avoid preventing the transmission of legal calls in its effort to deter illegal robocalls," said the Insights Association, Gallup, Precision Opinion, Professional Associations for Customer Engagement and ReconMR in joint comments. A coalition of financial organizations, including the American Bankers Association, American Financial Services Association and National Association of Federally-Insured Credit Unions, urged the FCC to "protect the lawful and consumer-benefitting calls that our members place."