Consumers Union, Consumer Action, Consumer Federation of America, National Association of Consumer Advocates, National Consumer Law Center on behalf of its low income clients, Public Citizen, and Public Knowledge submit these comments on the proposed rules regarding Advanced Methods for Blocking Robocalls.

We support the Commission’s proposal to clarify that all providers may block fraudulently spoofed calls under the following circumstances:

  • If the owner of a phone number, such as the Internal Revenue Service or a financial institution, asks the providers to block outbound calls purporting to be from that number, also known as “Do Not Originate,” or
  • If the Caller ID is clearly fraudulently spoofed: if the spoofed number is invalid (such as less than 10 digits), if the number has not been assigned to a provider, or if the number has not been provided to a customer.

These are great first steps. However, the Commission can and should do more. We urge the Commission to go further to limit spoofed calls and to facilitate the blocking of illegal robocalls. In particular, we urge the Commission to:

  • Explicitly permit and encourage the providers, where it can be done reliably and with the consumer’s consent, to use additional tools, such as advanced analytics, to identify and block clearly illegal robocalls.
  • Clarify that providers should make available to consumers the option to block calls that fail to authenticate their Caller ID information.
  • Continue to press providers to offer effective, optional, comprehensive, and free call blocking tools to all of their customers to help block legal but unwanted robocalls, which they already have permission to do.
  • Revise the definition of “illegal robocall” for the purposes of these rules so that it is clear that it includes autodialed or prerecorded text messages and voicemails.