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.
- 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.
- 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.
- 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.