Comments of NCLC, EPIC and NACA have been submitted in response to FCC Notice of Proposed Rulemaking proposing to require that certain types of calls, those with the highest level of attestation under the STIR/SHAKEN framework which the agency thinks are unlikely to have spoofed calling numbers, must have the caller’s name transmitted to the call recipient along with the calling phone number.
Our Comments assert that while enhancing caller ID with the caller’s name could be a good thing in the future, the FCC’s assumption that the types of calls this would apply to are unlikely to be spoofed is mistaken. In fact even the calls with the highest level of attestation are not always safe, because callers can “rent” phone numbers for temporary use which makes their caller ID technically accurate but misleading, and some providers simply transmit inaccurate call attestations because they are bad actors. We propose the FCC should address those issues before building further on the STIR/SHAKEN framework.
Next, we support the FCC’s proposal to prohibit foreign originated calls from spoofing into US phone numbers. Allowing spoofing into US phone numbers misleads consumers about the location of the caller and the likelihood that the caller is in the US and subject to US laws. Consumers value knowing when they are speaking with someone who is outside of the United States and may not be able to be held accountable for their conduct in this country.
Third, we support revising the rules on revocation of consent under the TCPA, and propose a revocation rule that requires callers to honor any reasonable revocation request, except if the caller clearly and conspicuously discloses an easy, automated method of revocation in the call or text itself that can constitute the exclusive means of revoking consent.
Finally, we ask the commission not to change several other TCPA rules. Specifically the FCC should not modify the rules to
- allow telemarketers to use 900 numbers or other pay-per-call phone numbers as their contact numbers for do-not-call requests,
- repeal the call abandonment rules as allowing callers to abandon high rates of calls will result in more annoying dead air calls and silent voicemails which have been increasing lately as callers use AI to screen for live answers, and
- make only narrow changes to the rules for how financial institutions send fraud alerts.
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