Collector - June 2017 - 23

"Pai has been an
outspoken critic of the
FCC's partisan split over
the years."

it, noting that allowing the FCC "to engage in
frank, non-public discussions improves the
decision-making process."
But why not release orders to the public
immediately after the FCC voted on them?
Sallet said commissioners needed time to
prepare statements expressing their opinions
and those had to be shared with other
commissioners and staff before release, and
may lead to edits to the order itself.
In his 2015 study for the Technology Policy
Institute, Wallsten observed that the FCC had
"steadfastly asserted a right to keep secret the
text of the documents it votes on. In response
to a Freedom of Information Act request by
the Associated Press in 2008, the FCC argued
that it had no obligation to make public these
texts on the somewhat puzzling grounds that
they were 'predecisional.'"
For his part, Pai has long complained
that the FCC favored opacity over
transparency. In testimony before the
House Subcommittee on Communications
and Technology last year, Pai thanked the
subcommittee for focusing on process
reform, calling out the FCC Consolidated
Reporting Act, which combined seven
separate reports into one, as well as the FCC
Process Reform Act, which required the
FCC to "regularly consider how to maximize
opportunities of public participation and
efficient decision-making."
However, Pai took care to note that
despite the movement on these bills, the
FCC hadn't operated in a bipartisan and
collaborative manner.
"The decisions we make impact hundreds
of millions of Americans and thousands
of small businesses," Pai said. "And yet to
the public, to Congress, and even to the
Commissioners at the FCC, the agency's
work remains a black box."

COLLECTOR 06.17

THE FCC TAKES ON
ROBOCALLS
On March 23, 2017, the Federal Communications
Commission unanimously voted to approve the Notice
of Proposed Rulemaking (NPRM) that would enable
voice service providers to block certain types of spoofed
calls to protect subscribers from fraudulent and illegal
robocalls. The FCC also approved the related Notice of
Inquiry (NOI) that seeks information on further actions
the FCC can take to block additional unlawful robocalls.
The NPRM seeks to codify guidance that providers may
block spoofed calls when the subscriber of the spoofed
number requests it, as well as to permit providers to
block calls from certain categories of spoofed numbers
in which the FCC sees no legitimate, lawful purpose for
spoofing. These include invalid numbers, valid numbers
that are not allocated and valid numbers that are
allocated but not assigned.
While the FCC makes clear that it understands that there
can be lawful uses of spoofing-or manipulating a caller
ID-the FCC does not believe there is any legitimate,
lawful purpose for intentionally spoofing a number that
cannot be called back.
The NPRM and NOI build on efforts of the industryled "Robocall Strike Force," which has been working to
develop solutions to prevent, detect and filter unlawful
robocalls. One issue that has been identified is the need to
remove regulatory uncertainty around blocking fraudulent
robocalls, which is what the proposed rules seek to do.
ACA applauds the FCC for focusing its TCPA efforts on
the growing number of bad actors who are using modern
dialing technology to harass and scam consumers.
As Commissioner Mignon Clyburn pointed out during
the March 23 meeting, unlawful robocalls are not just
annoying, but they can cause substantial consumer harm
and should be aggressively pursued.
However, this unlawful use of modern calling
technology is nothing like the use of such equipment
by legitimate businesses seeking to communicate
individualized information with consumers. As a result,
it's critical that the FCC exercises caution so that it
does not adopt any future rules that would lead to
lawful calls containing important financial information
from being inadvertently blocked.
23



Table of Contents for the Digital Edition of Collector - June 2017

President's Page
Industry News
Best Practices
FYI
Collection Tips
In Case of Emergency
Pulling Back the Curtain
ACA International's 2017 Convention and Exposition Preview
Calendar
Honor Roll
Seeing Eye to Eye
The Business Battle
Blueprint for Success
Federal Court Nixes CFPB Enforcement Action That Claimed a Payment Processor Ignored Fraud
Compliance
ACA SearchPoint
Last Word
Collector - June 2017 - Cover1
Collector - June 2017 - Cover2
Collector - June 2017 - 1
Collector - June 2017 - 2
Collector - June 2017 - President's Page
Collector - June 2017 - Industry News
Collector - June 2017 - 5
Collector - June 2017 - 6
Collector - June 2017 - 7
Collector - June 2017 - Best Practices
Collector - June 2017 - 9
Collector - June 2017 - FYI
Collector - June 2017 - 11
Collector - June 2017 - Collection Tips
Collector - June 2017 - 13
Collector - June 2017 - In Case of Emergency
Collector - June 2017 - 15
Collector - June 2017 - 16
Collector - June 2017 - 17
Collector - June 2017 - 18
Collector - June 2017 - 19
Collector - June 2017 - Pulling Back the Curtain
Collector - June 2017 - 21
Collector - June 2017 - 22
Collector - June 2017 - 23
Collector - June 2017 - 24
Collector - June 2017 - 25
Collector - June 2017 - ACA International's 2017 Convention and Exposition Preview
Collector - June 2017 - 27
Collector - June 2017 - 28
Collector - June 2017 - 29
Collector - June 2017 - 30
Collector - June 2017 - 31
Collector - June 2017 - Calendar
Collector - June 2017 - Honor Roll
Collector - June 2017 - Seeing Eye to Eye
Collector - June 2017 - 35
Collector - June 2017 - The Business Battle
Collector - June 2017 - 37
Collector - June 2017 - 38
Collector - June 2017 - 39
Collector - June 2017 - Blueprint for Success
Collector - June 2017 - 41
Collector - June 2017 - Federal Court Nixes CFPB Enforcement Action That Claimed a Payment Processor Ignored Fraud
Collector - June 2017 - 43
Collector - June 2017 - Compliance
Collector - June 2017 - 45
Collector - June 2017 - ACA SearchPoint
Collector - June 2017 - 47
Collector - June 2017 - Last Word
Collector - June 2017 - Cover3
Collector - June 2017 - Cover4
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