Dear FTC: How Will You Prevent Nomorobo Abuse?

Legitimate calls, such as those from airlines notifying thousands of passengers of weather-driven flight delays, could be intercepted, challenged by Nomorobo and then blocked. Same goes for card fraud alerts, appointment reminders, etc. So I am issuing my own Robocall the FTC.

A few months ago the Federal Trade Commission (FTC) announced the winners of its $50,000 Robocall Challenge, launched October 2012, which asked the public to come up with a technical solution to block illegal robocalls. At that time I wrote about my concerns with how the FTC was being careless in describing what constitutes an illegal robocall, and urged them to clearly distinguish illegal robo-MARKETING-calls as different than legal proactive customer service calls from companies to their customers. Since then, the commission has done a better job of describing what makes a recorded message illegal in their public pronouncements. I’m not sure my blog had anything to do with it, but absent any evidence to the contrary, I am going to take credit for that change.

Now, I have a new concern. After being named as one of the two challenge winners, a company called Nomorobo has supposedly been working hard to make their proposed solution a commercial product. While they have not yet announced availability of their service or final details on how it will work, there is an overview video available on YouTube. One feature described in the video is the ability of Nomoroboto intercept calls they suspect of possibly being an illegal robocall based on the frequency with which their originating CallerID is being used. Such suspected calls would be subjected to what the inventor calls an audio “Captcha”—a spoken challenge to the caller to enter a number announced by Nomorobo “to prove that you are a human.” Failure to correctly answer this prompt will result in the Caller ID being added to a robocall blacklist that will block any future calls from that number.

Anyone familiar with automated dialing technology, used by almost every mid-size or larger B2C company to communicate with their customers, can see the problem with this. Legitimate calls, such as those from airlines notifying thousands of passengers of weather-driven flight delays, could be intercepted, challenged by Nomorobo and then blocked. Same goes for card fraud alerts, appointment reminders, package delivery updates and collection calls, not to mention notifications from school districts to parents, healthcare providers to patients and numerous other completely legal communications.

So I am issuing my own Robocall challenge…to the FTC:

How will you prevent Nomorobo abuse?

If you don’t think this is your problem, you might want to review the Nomorobo video again. They expect you to maintain a white list of legal caller’s phone numbers and a black list of illegal robocallers. Even if this is in your plans, are you working with Nomorobo to make sure their solution will not intercept legal calls and automatically add them to the black list? And how are you going to fund this activity? I searched but could not find a reference to it in the administration’s budget proposal for 2014. But there was an interesting and related paragraph on the administration’s desire to use automated dialing technology to collect debt owned to the government:

Provide authority to contact delinquent debtors via their cell phones.—The Budget proposes to clarify that the use of automatic dialing systems and prerecorded voice messages is allowed when contacting wireless phones in the collection of debt owed to or granted by the United States. In this time of fiscal constraint, the Administration believes that the Federal Government should ensure that all debt owed to the United States is collected as quickly and efficiently as possible and this provision could result in millions of defaulted debt being collected.

Perhaps you plan on adding the government’s autodialer phone number to your white list so their calls won’t be blocked by Nomorobo. If so, you should also have a plan for adding the phone numbers of the thousands of companies that use the same technology for legitimate business purposes.

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  • dj righteous

    clearly written by the telemarketer and phone companies and anyone else making money off of phone scams. nice fake article.

  • Brian Dusel

    Nice try Brian Moore. I’m willing to bet you’re troll!!!! Personally, I’d like to see stakes driven through the hearts of every telemarketer!

  • Oingo Boingo

    The captcha is unworkable differences speech for one and the failure of people to be able to respond to an unexpected challenge. I had an anonymous caller challenge service about ten years ago and one of my older known callers could never respond to the simple challenge to announce their name which would be played at my end so I can determine if I want to answer it. I had to remove the service as a result.

  • jimmc1952

    Well, imagine that! A blogger who’s worried about the government collecting money it thinks is owed. I’m touched.

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Brian Moore

About Brian Moore

Brian Moore, senior principal, industry solutions of Nuance's Enterprise division, brings more than 25 years of experience in financial services, mortgage and collections operations and technology to the company. He is also our resident compliance expert, advising companies on how to comply with TCPA, CFPB, TSR and other customer communications compliance regulations.