Collector - October 2020 - 45

GOVERNMENTAFFAIRS

data provided by ACA and coalition
partners outlining examples of erroneous
call blocking. ACA also submitted
extensive data compiled by Number Sentry
showing clear evidence of erroneous call
blocking and labeling.
Additionally, one of the wins in the
report was that it listed contact information
for voice service providers and analytics
companies for callers to report the erroneous
call blocking and labeling. Until recently,
it was unclear where members of the ARM
industry should even start to get their calls
unblocked, and this put the onus on carriers
to provide that information.
Subsequently, as the FCC worked
to finalize an order this summer
surrounding the safe harbor for blocking
calls, ACA engaged in extensive advocacy
that led to some important changes in the
final draft. Notably, in his statement on
the order, FCC Commissioner Michael
O'Rielly expressly recognized the harms of
overly broad call blocking and the need for
recourse. He also noted that the language
ACA worked to secure in the TRACED Act
mandated the FCC to provide additional
protections to callers who are unfairly
having their calls blocked.
He stated, "At its heart, the TRACED Act
is about targeting and eliminating illegal

COLLECTOR 10.20

calls, not restricting legal and legitimate
ones, and we need to make sure that our
implementation of the legislation stays true
to this purpose, through meaningful and
expeditious redress mechanisms for such
callers and providers."
In this order, the FCC included some
important points for callers, including but
not limited to the following:
*	 It clarified that voice service providers
must maintain a single point of contact
for blocking disputes but may also
offer "a web portal, chat bot, or other
electronic means of contact."
*	 The investigation and resolution of
complaints must "come at no cost to the
caller, so long as the complaint is made
in good faith."
*	 Blocking disputes must be resolved in a
"reasonable" amount of time depending
on specific circumstances.
*	 It confirms that these redress
mechanisms are conditions for
obtaining the safe harbor established
in the order.
During the meeting, the FCC also adopted
a Further Notice of Proposed Rulemaking to
take public comment on additional matters.
Specifically, it sought comment on whether
and how to address any risks of consumer
confusion or competitive issues stemming

from call labeling, an issue that ACA and
its coalition partners outlined to the FCC
in recent ex parte filings. This is critical
as the FCC has not yet taken any actions
surrounding call labeling.
The FCC also stated, "We intend to
address call-blocking issues and the role
of analytics in relation to call blocking in a
separate item and thus decline to address
these requests here."
ACA submitted additional comments on
the FNPRM before the August deadline and
is continuing advocacy with the FCC on
this issue.
ARM industry problems with call
blocking and labeling have certainly not
been resolved, particularly since a lot of
issues stem from third parties that are not
necessarily directly regulated by the FCC.
However, we continue to make inroads
and successfully educate lawmakers and
regulators about why they must add
protections for legitimate callers. Slowly
but surely, we are chipping away at the
problematic policies that have been created
in this area and making it harder to ignore
the very real problems associated with
blocking legitimate callers.
Leah Dempsey is ACA International's vice
president and senior counsel of federal advocacy.

45



Collector - October 2020

Table of Contents for the Digital Edition of Collector - October 2020

Collector - October 2020 - Cover1
Collector - October 2020 - Cover2
Collector - October 2020 - 1
Collector - October 2020 - 2
Collector - October 2020 - 3
Collector - October 2020 - 4
Collector - October 2020 - 5
Collector - October 2020 - 6
Collector - October 2020 - 7
Collector - October 2020 - 8
Collector - October 2020 - 9
Collector - October 2020 - 10
Collector - October 2020 - 11
Collector - October 2020 - 12
Collector - October 2020 - 13
Collector - October 2020 - 14
Collector - October 2020 - 15
Collector - October 2020 - 16
Collector - October 2020 - 17
Collector - October 2020 - 18
Collector - October 2020 - 19
Collector - October 2020 - 20
Collector - October 2020 - 21
Collector - October 2020 - 22
Collector - October 2020 - 23
Collector - October 2020 - 24
Collector - October 2020 - 25
Collector - October 2020 - 26
Collector - October 2020 - 27
Collector - October 2020 - 28
Collector - October 2020 - 29
Collector - October 2020 - 30
Collector - October 2020 - 31
Collector - October 2020 - 32
Collector - October 2020 - 33
Collector - October 2020 - 34
Collector - October 2020 - 35
Collector - October 2020 - 36
Collector - October 2020 - 37
Collector - October 2020 - 38
Collector - October 2020 - 39
Collector - October 2020 - 40
Collector - October 2020 - 41
Collector - October 2020 - 42
Collector - October 2020 - 43
Collector - October 2020 - 44
Collector - October 2020 - 45
Collector - October 2020 - 46
Collector - October 2020 - 47
Collector - October 2020 - 48
Collector - October 2020 - 49
Collector - October 2020 - 50
Collector - October 2020 - 51
Collector - October 2020 - 52
Collector - October 2020 - Cover3
Collector - October 2020 - Cover4
http://online.collector.com/collectormagazine/202010
http://online.collector.com/collectormagazine/202009
http://online.collector.com/collectormagazine/202008
http://online.collector.com/collectormagazine/202007
http://online.collector.com/collectormagazine/202006
http://online.collector.com/collectormagazine/202005
http://online.collector.com/collectormagazine/202004
http://online.collector.com/collectormagazine/202003
http://online.collector.com/collectormagazine/202002
http://online.collector.com/collectormagazine/202001
http://online.collector.com/collectormagazine/201912
http://online.collector.com/collectormagazine/201911
http://online.collector.com/collectormagazine/201910/
http://online.collector.com/collectormagazine/201909/
http://online.collector.com/collectormagazine/201908/
http://online.collector.com/collectormagazine/201907/
http://online.collector.com/collectormagazine/201906/
http://online.collector.com/collectormagazine/201905/
http://online.collector.com/collectormagazine/201904/
http://online.collector.com/collectormagazine/201903/
http://online.collector.com/collectormagazine/201902/
http://online.collector.com/collectormagazine/201901/
http://online.collector.com/collectormagazine/201812/
http://online.collector.com/collectormagazine/201811/
http://online.collector.com/collectormagazine/201810/
http://online.collector.com/collectormagazine/201809/
http://online.collector.com/collectormagazine/201808/
http://online.collector.com/collectormagazine/201807/
http://online.collector.com/collectormagazine/201806/
http://online.collector.com/collectormagazine/201805/
http://online.collector.com/collectormagazine/201804/
http://online.collector.com/collectormagazine/201803/
http://online.collector.com/collectormagazine/201802/
http://online.collector.com/collectormagazine/201801/
http://online.collector.com/collectormagazine/201712/
http://online.collector.com/collectormagazine/201711/
http://online.collector.com/collectormagazine/201710/
http://online.collector.com/collectormagazine/201709/
http://online.collector.com/collectormagazine/201708/
http://online.collector.com/collectormagazine/201707/
http://online.collector.com/collectormagazine/201706/
http://online.collector.com/collectormagazine/201705/
http://online.collector.com/collectormagazine/201704/
http://online.collector.com/collectormagazine/201703/
http://online.collector.com/collectormagazine/201702/
http://online.collector.com/collectormagazine/201701/
http://online.collector.com/collectormagazine/201612/
http://online.collector.com/collectormagazine/201611/
http://online.collector.com/collectormagazine/201610/
http://online.collector.com/collectormagazine/201609/
http://online.collector.com/collectormagazine/201608/
http://online.collector.com/collectormagazine/201607/
http://online.collector.com/collectormagazine/201606/
http://online.collector.com/collectormagazine/201605/
http://online.collector.com/collectormagazine/201604/
http://online.collector.com/collectormagazine/201603/
http://online.collector.com/collectormagazine/201602/
http://online.collector.com/collectormagazine/201601/
http://online.collector.com/collectormagazine/201512/
http://online.collector.com/collectormagazine/201511/
http://online.collector.com/collectormagazine/201510/
http://online.collector.com/collectormagazine/201509/
http://online.collector.com/collectormagazine/201508/
http://online.collector.com/collectormagazine/201507/
https://www.nxtbookmedia.com