Joint Trades Comment Letter of FCC Call-Blocking Proposal
Last week, the American Financial Services Association joined the American Bankers Association, ACA International, Consumer Bankers Association, Credit Union National Association, Mortgage Bankers Association, National Association of Federally-Insured Credit Unions, National Council of Higher Education Resources, and Student Loan Servicing Alliance in commenting on the Federal Communications Commission’s (FCC) call-blocking proposal.
The FCC proposal reiterates the negative effects of bad actors that increasingly place calls that impersonate legitimate companies with intent to defraud consumers, something on which financial services institutions, customers and consumer advocates can all agree is bad for Americans.
Unfortunately, bad actors at times illegally “spoof” phone numbers belonging to our members by causing the call recipient’s caller ID to display the name of a legitimate company instead of the name of the actual caller, who is seeking to defraud the recipient. In order to properly combat this without harming the consumer, the comment letter provides several ways the FCC can improve the proposal.
- The FCC should prohibit the display of data on the consumer’s caller ID device when the authenticity of the incoming call cannot be adequately verified through a direct and verified relationship with the call originator.
- The FCC should protect the lawful and consumer-benefitting calls that our members place by ensuring that the analytics do not include servicing calls, such as fraud alerts, in a blocked calls list.
- The FCC should require voice service providers to provide callers with the same redress options when calling numbers are mislabeled as when calls are blocked. Specifically, a provider (or its third-party service provider) should be required to provide immediate notification whenever a derogatory label is placed on a call and provide the caller with an opportunity to dispute that label.
August 15th, 2023
