How May I Direct My Call? 

Getting Through to Credit Union Members in the Age of Call Blocking

We have all seen old-timey pictures of rows and rows of telephone operators sitting in front of banks of seemingly chaotic, thick wires and somehow effortlessly connecting people by simply unplugging them and plugging them back in with just the right sequence. We take it for granted that the primary job of telephone companies is ensuring callers get through to the person being called. Not anymore. More and more, telephone companies are being tasked with policing their networks to stop “unwanted” or illegal robocalls. Although this is a laudable goal, the methods being used are imperfect and many legitimate calls from legitimate operations, including credit unions, are either getting blocked or are mistakenly being labeled as “spam,” or “scam” calls.

It is important to note, at the outset, that CUNA fully supports efforts to stop illegal robocalls.  At the same time, we have worked tirelessly with regulators to minimize the possibility that legitimate calls get blocked or, if they do get blocked, to ensure that callers have redress mechanisms to get the calls unblocked as quickly as possible. Although CUNA and its trade association allies have made progress on this front, the possibility that legitimate calls will continue to be blocked or mislabeled cannot be ignored.

This blog post is designed to help you understand this new regulatory framework, and to encourage you to take 5 simple steps to maximize the chances that your calls go through so your members continue to receive the exceptional customer service they have come to expect from their credit union.   

Background       

Illegal or unwanted robocalls have been proliferating and many perpetrators, who are often overseas, could care less about legal consequences. In response, regulators have turned to technical fixes to try and stem the tide. One fix is to empower telephone companies to block calls that they suspect are unwanted or illegal before they reach the consumer. The telephone companies block calls based on “suspicious” calling patterns, such as a large number of short duration calls being made from the same telephone number. The problem is that many legitimate calling campaigns, such as fraud alerts or branch opening/closing notices, may follow the same pattern and are thus erroneously tagged for blocking. Reliance on “suspicious” calling patterns is a major cause of legitimate calls getting blocked. Regulators have provided telephone companies that block calls on this basis protection from liability and thus call blocking of this type will continue to increase.

Another major concern is that bad actors making fraudulent calls entice consumers into answering by falsely inserting phone numbers of legitimate entities, such as the IRS or Social Security Administration, into the caller ID (the number that shows up on your phone to identify who is calling). Consumers are bilked out of millions of dollars each year through these schemes. At the urging of regulators, the telephone industry has devised an entirely new calling framework, called STIR/SHAKEN, that is designed to stop this practice by having the phone company that serves the caller authenticate or verify that the caller is entitled to use the phone number showing up in the caller ID.  Telephone companies must implement this new framework by June 30, 2021, with some exceptions. Once this framework is fully implemented, information will be displayed on the phone receiving the call indicating that the calling number has been verified and can be trusted.  In other words, if appropriately implemented, a credit union member can be assured that a call from their credit union is actually a call from that credit union, not a scammer pretending to be legitimate.

Implementing this new framework, however, is tricky when calls come from businesses. One reason is that businesses may actually use several phone companies or there may be companies that provide some aspect of a credit union’s communications services, but are not entities that ultimately can verify the right of the credit union to use the calling numbers. Credit unions need to understand the telecommunications ecosystem that serves them and how that ecosystem fits into the new number verification framework.

Steps to Help Ensure Calls Get Through

There are several steps credit unions can take to minimize the possibility that their calls will be blocked.

1. Sign up with a company that can help you avoid having calls blocked.. The threat of erroneous call blocking or labelling has spawned a new industry of companies that work to make sure calls do not get blocked or mislabeled.  For a fee, these companies will register your numbers and inform telecommunications companies that these are valid numbers for your credit union that should not be blocked. They can also help track your calls and identify if the calls are being blocked and by which telephone company.
2. Take advantage of redress options. Recognizing that legitimate calls are sometimes being blocked, regulators now require telephone companies that block calls to establish mechanisms for callers to complain and to get the calls unblocked.  Telephone companies must publish information on their websites about how to notify them of erroneous call blocking. This may include a phone number or a web portal to lodge complaints.  The telephone companies must address and resolve these claims within a reasonable period of time and are required to provide a status report within 24 hours of receiving a complaint. 
3. Monitor your call connection success rates. One major problem is that currently, telephone companies do not have to notify you that they are blocking calls your calls. All the caller knows is that calls do not seem to be getting answered. Credit unions must thus engage in their own monitoring (or hire a company as described in #1 above). If you find that calls are not being answered at the rate you would expect, you should contact your telephone service provider to help you determine if your calls are being blocked.

At the urging of CUNA and others, the regulators have recently adopted a rule that telephone companies that block calls must immediately notify the caller if their calls are being blocked. This notification will be embedded in the telephone signaling that accompanies the call. This change will help enormously, but the notification requirement does not take effect until January 2, 2022, although some providers may start providing this notification sooner.  To take advantage of this notification requirement once it becomes effective, credit unions may have to make adjustments to their telecommunications equipment in order to receive the appropriate automatic telephone signaling information, and their telephone service provider must be able to send the notification to the credit union. Credit unions should begin discussions with their telephone service provider in the coming months about any service or equipment changes that they need to make to receive these notifications.

• 4.Determine if your calls will be verified. As described above, regulators are requiring telephone companies to authenticate or verify that a caller has the right to use the telephone number that appears on the Caller ID of the recipient’s telephone. Currently, however, this new framework only works if the calling company uses Voice over Internet Protocol (better known as “VoIP”) telephones and the call goes over IP networks all the way to called party. There are other limitations as well, including complications with calls from businesses as noted above. Many of these complications can be addressed through coordination among telephone providers and others that provide value-added communications services such as unified communications to businesses.  

Credit unions, particularly larger credit unions that may use multiple telecommunications providers, should contact their providers and ascertain how they plan to verify your phone numbers. Perhaps some telephone companies have already reached out to you.  When speaking with a telephone service or communications services provider you should ask them how they will ensure that your calls will receive the highest level of attestation or verification, which is called an “A” level attestation under the STIR/SHAKEN framework. Without this “A” level attestation, your calls are more likely to be blocked or go unanswered.  If the service provider does not know what you are talking about, consider getting a new provider.

• 5.Ask your telephone provider if they plan to implement “rich call data.”  Finally, there is another new technological change on the horizon and it is now taking hold in a few places called “rich call data.” This simply means that more information about the caller is displayed on the called person’s telephone (especially smart phones) beyond simply a name or number.  Rich call data could include the caller’s name, logo or even a short reason for the call. All of this information, particularly when combined with calling number verification, will help ensure your calls get answered.  Connecting with a telephone service provider now to see if they are using or contemplating use of rich call data may help ensure that your calls connect to your members in the future.

We hope that this information is helpful as you consider the most effective way to ensure that your important calls get through to your members and that they answer those calls.  As always, CUNA stands ready to provide our members more detailed information on how to navigate the brave new world of call blocking and number verification.  If you have any questions about these issues or other TCPA-related compliance questions, please email  cucomply@cuna.coop.  

We look forward to connecting with you soon.