Nine industry associations recently sent a letter to the Federal Communications Commission (FCC), pushing back against the regulator’s plan involving call blocking and offering suggestions so financial institutions can still contact their customers.

The associations responded because the FCC wants to deploy additional measures to combat illegal calls and address how to notify legitimate callers of erroneously blocked calls. The FCC also was seeking information on how frequently outbound calling numbers are erroneously labeled as “spam” or with another derogatory label, among other questions.

Responding via a 22-page letter to the FCC were:

—American Bankers Association
—ACA International
—American Financial Services Association
—Consumer Bankers Association
—Credit Union National Association
—Mortgage Bankers Association
—National Association of Federally-Insured Credit Unions
—National Council of Higher Education Resources
—Student Loan Servicing Alliance

“The associations strongly support the commission’s efforts to eliminate illegal automated calls,” they wrote. “Banks, credit unions, and other financial services providers — and their customers — are negatively impacted by bad actors that increasingly place calls that impersonate legitimate companies with intent to defraud. These 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.

“We agree with the commission that a caller ID device can be used to provide confirmation to the consumer that an incoming call was not illegally spoofed. We urge the commission to 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 associations continued.

“As the commission takes additional action to combat illegal calls, we also urge the commission to protect the lawful and consumer-benefitting calls that our members place,” they went on to say. “Banks, credit unions, and other financial institutions place large numbers of fraud alerts, past-due notifications, and other servicing calls in a short timeframe, and these calls may have low average call duration and low completion ratios — three attributes that the Commission has suggested voice service providers and their third-party analytics service providers use to block calls based on analytics.

“We urge the commission to state that these factors alone are not sufficient for a voice service provider to block calls based on ‘reasonable analytics’ generally or to conclude that calls are ‘highly likely to be illegal,’ ”

The associations noted the FCC has proposed to require all voice service providers to block calls using a “reasonable do not originate” (DNO) list, which would include phone numbers from which an outbound call is highly likely to be illegal and from which calls should not originate.

“We support the commission’s proposal but caution the commission not to expand the category of phone numbers that can be placed on a DNO list unless the agency has identified an additional category of numbers that have clear indicia that the calls were placed illegally,” the associations wrote.

The associations also agreed with the FCC that consumers and callers would benefit if the information displayed in the consumer’s caller ID device conveyed whether the call was illegally spoofed.

“Specifically, when the authenticity of calls cannot be adequately verified through a direct and verified relationship with the call originator, we urge the commission to prohibit the display of data on the consumer’s caller ID device,” the associations wrote.

“Only those calls that demonstrate a verified relationship between the originating provider and the call originator should be allowed to display any data in the caller ID device. This approach would let call recipients know whether the caller has a verified relationship with its originating provider, provide a strong incentive for legitimate callers and discourage bad actors from placing calls.”