ABA, Groups Submit Reply Comment to Urge FCC to Require Notification, Redress of Erroneously Blocked Calls

The Credit Union National Association, American Bankers Association, ACA International, American Financial Services Association, Consumer Bankers Association, Mortgage Bankers Association, National Association of Federally-Insured Credit Unions, National Retail Federation, and the Student Loan Servicing Alliance (the "Associations") file these reply comments to the above-captioned proceeding. These reply comments focus on the Commission's legal obligation under the TRACED Act to establish a real-time notification requirement to inform callers that their calls have been blocked or adversely labeled. The initial comments, including those filed by the undersigned jointly with other trade associations, reflect substantial support and need for such a notification requirement. The record also supports the establishment of a time certain to resolve blocking or labeling disputes.

I. The Commission Must Adopt a Notification Requirement to Discharge ItsObligations Under the TRACED Act

A. There is Widespread Support for a Notification Requirement

A wide range of commenters support establishing a per-call, real-time notification requirement. Real-time notification, as various commenters note, is required to fully implementthe TRACED Act's requirement for transparent and effective redress. Currently, many callers are unaware that their calls are being blocked and instead are presented with false busy signals or their calls simply drop into a "black box" where the caller receives no notification that their calls are being blocked or have been adversely labeled. While callers are trying to ascertain what is happening with their calls, consumers remain unaware that calls from legitimate businesses, often with critical information such as alerts, are being blocked or negatively labeled. Obscuring the fact that calls are being blocked by sending false busy signals or other inaccurate signaling information is the antithesis of the TRACED Act's transparency requirement. Lack of notification harms callers and their customers.

Download the comment letter to read the full text.