In this modern age of chatbots and instant customer service support practices, is a contact center even necessary? Well, yes, because people still like to speak to someone. All these other options are great, and add value, but there inevitably comes a time as a customer when picking up the phone and calling a real person who can walk you through a solution to your requirement is the only thing for it.
 
And in this globalized world, offering call center support in only one language is just not going to cut it. How then, do you effectively offer multilingual contact center support to your customer base? There are, as always, numerous options, varying in effectiveness and cost:

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PACE Regulatory Alert: FCC Comment Period for Call Blocking Public Notice
On December 20, 2019, Federal Communications Commission Chairman Pai, announced a review of the robocall blocking options. This began a study of unwanted call blocking services available to consumers across the country.  The full announcement is available at https://www.fcc.gov/document/chairman-pai-announces-review-consumers-robocall-blocking-options.

On December 30, 2019, a summary of the Call Blocking Public Notice was published in the Federal Register. Based on this announcement, the  Consumer and Governmental Affairs Bureau recently announced the Comment Dates for the first staff report on call blocking. Comments are due on or before January 29, 2020. Reply Comments are due on or before February 28, 2020.  More information including how to file a comment,  is available at https://docs.fcc.gov/public/attachments/DA-19-1335A1.pdf.

PACE will be contacting members on how they can assist with our comments. We will also keep you updated on any further developments.

PACE Regulatory Alert: President Trump Signs TRACED Act Into Law
After the Pallone-Thune TRACED Act (“Act”) passed almost unanimously in both the House and Senate, President Trump signed the Act on December 30, 2019. The Act will allow the Federal Communications Commission to implement new provisions of the law. President Trump made the final decision regarding the legislation targeting illegal robocalls; his signature makes the Act law and amends the Telephone Consumer Protection Act accordingly. 

The Pallone-Thune TRACED Act (“Act”) is named after Senators Frank Pallone, Jr. (D-NJ), and Sen. John Thune (R-SD). The bill is a result of a yearlong effort by legislators to clamp down on unwanted robocalls. Below is a summary of the most important parts of this Act.

Heightened Enforcement 

A significant aspect of the Act is the expansion of the FCC’s current enforcement mechanisms to ensure that it has sustained enforcement capabilities to further go after robocallers. These new mechanisms include:
- Expansion of forfeiture penalties under the Telephone Consumer Protection Act (“TCPA”), including for first time offenders
- Imposition of a $10,000 penalty for all “intentional violations” of the Act;
- The extension of the FCC’s forfeiture powers by expanding the statute of limitations from 2 years to 4 years.

Call Authentication 

Enhanced call authentication is the cornerstone of the Act. It requires that all voice service providers, over an 18-month period (subject to a reasonable extension), must implement SHAKEN/STIR technology that ensures caller-ID information is correctly authenticated free of charge to consumers.

Notably, the Act considers the importance of up-to-date technology for SHAKEN/STIR implementation to ensure rural areas receive the benefit of SHAKEN/STIR. Carriers that need additional time to implement this technology may be granted a reasonable extension.

Specific call authentication provisions include:

- No later than 18 months after the enactment of the Act, the FCC shall require a provider of voice service to implement STIR/SHAKEN in the provider’s voice service;

- No later than 12 months after enactment, the FCC must assess any burdens or barriers to implementation and take active measures such as delaying compliance for a reasonable period if there are identified burdens and barriers to implementation;

- In conjunction with small voice service providers, the FCC must strategically identify ways to ensure that consumers in rural areas have alternative effective methods to protect them from any unauthenticated calls during any compliance delay period;

- Voice service providers are prohibited from adding any additional charges to consumers or small business subscribers for call authentication technology;

- No later than 12 months after enactment, the FCC must issue best practices that voice service providers may use in implementing call authentication protocols;

- No later than 12 months after enactment, the FCC must promulgate rules for establishing when a provider of a voice service may block a voice call based on information provided by call authentication frameworks;

- No later than 12 months after enactment, the FCC must establish a safe harbor protecting those providers from liability for unintended or inadvertent blocking of calls or for the misidentification of individual calls based on the information supplied by the call authentication framework;

- No later than 12 months after enactment, the FCC must establish a process whereby an adversely affected calling party may verify the authenticity of its calls;

- Every 3 years after enactment, the FCC shall, after notice and comment, assess the call authentication framework and revise or replace the call authentication framework under the Act.

Enhanced Consumer Protections 

Under current law, some robocalls can be made without consent. The Act requires that the FCC implement consumer protections on the FCC’s exempted classes of robocalls to ensure that consumers are protected from receiving too many calls from too many people. These consumer protections must specifically include limits on:

- The classes of parties that may make such calls;
- The classes of parties that may be called; and
- The number of calls allowed under the exemption.

Robocall Blocking 

 The Act requires that robocall blocking services be provided to consumers. This service may be on an opt-out or opt-in basis and must be provided free of charge to consumers or callers. Most importantly, the Act requires that call blocking is provided with transparency and effective redress options for both consumers and callers. It is worth noting that the FCC issued a Declaratory Ruling allowing carriers to implement “blocking by default” for subscribers.

Heightened Traceback Efforts in Conjunction with Service Providers 

The Act requires that no later than one year after enactment, the FCC makes available on its website a report on the status of private-led efforts to trace back the origin of suspected unlawful robocalls by a registered consortium of voice service providers. The report shall include items such as:

- A description of private-led efforts to trace back the origin of suspected unlawful robocalls;
- A list of voice service providers identified by the registered consortium that registered in the efforts;
- The reason that a voice service provider identified by the registered consortium for not participating in the private-led efforts to trace back calls;
- How the FCC may use the information provided by the consortium to trace back the origins of robocalls and further help enforcement efforts.