PITTSBURGH, September 1, 2020 – ACA Connects applauds the Federal Communications Commission’s efforts on many fronts to stem the tide of illegal and unwanted robocalls, including its work across many proceedings to implement the provisions of the TRACED Act. As the FCC considers further regulatory steps, the agency should proceed with caution to ensure it does not impose burdens on providers that outweigh their benefits or adopt rules in one proceeding that undermine the policies set forth in another.
The trade association made specific recommendations to the agency along these lines in comments filed on Aug. 31.
“The FCC is taking important steps to protect customers from fraudulent and abusive calls, and our members are pleased to be part of the solution,” said ACA Connects President and CEO Matthew M. Polka. “Our comments are offered in the spirit of finding solutions that serve the needs of consumers and are workable for providers, including smaller voice service providers that are eager to help their customers but must get the job done with limited resources and personnel.”
In its comments, ACA Connects urged the FCC to refrain from imposing prescriptive and costly redress requirements on voice providers that offer call-blocking services, including third-party blocking tools that are popular among smaller providers and their customers. The comments noted that the FCC just recently adopted more flexible requirements and should give them time to take hold in the marketplace before judging them insufficient.
ACA Connects also cautioned the agency against rushing the adoption of rules that promote blocking of “unauthenticated calls” per section 7 of the TRACED Act. Such rules could sweep in many legitimate calls from voice providers that are not yet required to implement call authentication, including small providers operating under a compliance delay as the TRACED Act contemplates.
Next, ACA Comments expressed support for the adoption of a well-crafted safe harbor for network-level blocking of calls that are highly likely to be illegal. Finally, ACA Connects urged the FCC to take steps to educate smaller providers about their responsibilities under any traceback mandate it adopts, and to utilize enforcement action sparingly against these providers while they are still becoming familiar with their obligations.