ABA/Joint Trades Ex Parte Letter re: Immediate Notification of Blocking Through SIP Code 603+

Ms. Marlene H. Dortch
Secretary
Federal Communications Commission
45 L Street, NE
Washington, DC 20554

Dear Ms. Dortch:

On October 5, 2022, Jonathan Thessin with the American Bankers Association; Leah Dempsey with Brownstein Hyatt Farber Schreck, outside counsel to ACA International; Mark Brennan from Hogan Lovells, outside counsel to the American Association of Healthcare Administrative Management; Michael Pryor with Brownstein Hyatt Farber Schreck, outside counsel to the Credit Union National Association; James Akin with the National Association of Federally-Insured Credit Unions; Shelly Repp with the National Council of Higher Education Resources; and Gary Brind with American Express (the Associations) met virtually with Mark Stone, Karen Schroeder, Kristi Thornton, Jerusha Burnett, and Benjamin (Jesse) Goodwin with the Federal Communication Commission’s Consumer and Governmental Affairs Bureau (CGB). The purpose of the meeting was to discuss how the Commission can best ensure that the Associations’ members and other lawful callers are provided with meaningful, immediate notification when their outbound calls are blocked by telephone companies utilizing analytics.

The TRACED Act requires the Commission to "ensure . . . robocall blocking services . . . are provided with transparency and effective redress options for . . . callers . . . ." Time-sensitive calls are being wrongly blocked by voice service providers’ use of analytics engines. These erroneously blocked calls include emergency calls from public safety organizations, anti-fraud messages, safety recall messages, research calls on behalf of the Centers for Disease Control and Prevention, and necessary account updates and reminders needed to maintain financial health and well-being.

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