Collector - January 2018 - 42
"At the moment you
don't have a good way
to check to see if those
telephone numbers have
been blocked or labeled
until you are making
calls and you see a drop
in your contact rate."
people report that the call is a scam," he
said. "That tags the number in the thirdparty database and thereafter those calls
are going to be flagged as a scam. We can't
stop that; it's been going on independently
for a number of years. The FCC isn't really
regulating this aspect."
Moreover, this type of call labeling can
potentially present Fair Debt Collection
Practices Act third-party disclosure concerns
if the call is labeled "debt collector."
The misclassification of legitimate business
calls as scams is a serious issue that
threatens the fundamental ability of debt
collectors to communicate with consumers
to share important account information.
"This is one area where consumers agree
that call blocking could happen in a way
that harms the consumer if the consumer
doesn't know the calls are being blocked or
hasn't chosen to have those calls blocked,"
It's critically important that callers
know when and why their numbers are
being blocked or if they are being labeled
improperly, especially in instances when
consumers have not requested those services.
Databases and whitelists of "good
numbers" are not currently viewed as
long-term solutions to the illegal robocall
issue because scammers can change their
techniques just as quickly as the carrier and
analytics companies can come up with ways
to block and label these types of calls.
One call authentication solution being
proposed now is SHAKEN/STIR, which uses
tokenization techniques and algorithms to
prevent spoofed and fraudulent robocalls.
"I think it's a good framework because
it prevents callers from being anonymous,"
Koster said. "Under it, there would be
attestation levels that must be passed with
each call. If it's enacted, the carriers are
going to probably be unofficially involved
in enforcing it."
Some companies wonder if they can
sidestep call blocking and labeling issues
by replacing their outgoing phone numbers
every few months or even weeks. But Shuster
said that is not a long-term solution.
"At the moment you don't have a good way
to check to see if those telephone numbers
have been blocked or labeled until you are
making calls and you see a drop in your
contact rate," she said.
Shuster noted that there is one simple
step business can take to help their calls go
through, if they haven't already: Make sure
both your phone number and company
name are being displayed accurately on
"It's a good idea to go back to make sure
your numbers are outpulsing a legitimate
number-not all zeros or something else
that's not a 10-digit telephone number-
because the carrier will have the ability to
block those types of numbers," she said.
ACA INTERNATIONAL'S ADVOCACY
In July 2017, ACA filed comments
supporting the FCC's call blocking Notice
of Proposed Rulemaking, asserting that
the limited, well-defined categories of
spoofed calls identified by the FCC appear
to strike an appropriate balance between
combating illegal robocallers, protecting
consumers, and preserving the flow
of important informational calls from
legitimate businesses to consumers. In
November, the FCC adopted narrow rules
in support of these goals.
However, ACA emphasized that while
it supported the narrow categories in the
CALL BLOCKING &
ACA is working to put an
end to the unintended
"robocall" blocking and
labeling, and hearing from
you can help us better
advocate for the industry.
If you are an ACA member
who has been affected by
robocall blocking tools,
please take a moment to
share your experience with
NPRM, it was deeply concerned about
the issues raised in the related Notice of
Inquiry, which explored the possibility
of developing a future framework
in which legitimate business calls
containing important information could
be mistakenly blocked by voice service
providers. As a result, ACA urged the FCC
to move forward on the measures in the
NPRM while refraining from considering
the much more complicated issues raised
in the NOI.
ACA is committed to finding a way to
put an end to the unintended consequences
of "robocall blocking," which-although
well intentioned-has the potential to be
devastating to individual businesses and to
the industry as a whole.
"It's something that's been around for a
while," Shuster said. "As legitimate actors,
we've all suffered from the scourge of illegal
robocalls, and it's important for us now as
an industry to come forward and provide
a voice and to work with regulators and
carriers on mitigation strategies."
Anne Rosso May is editor of Collector