CFA, Consumers Union, Consumer Action, National Association of Consumer Advocates, National Consumer Law Center on behalf of its low-income clients, Public Citizen, and Public Knowledge have submitted reply comments to the Federal Communications Commission (FCC) in the matter of Advanced Methods to Target and Eliminate Unlawful Robocalls. We appreciate that the Commission has continued to make combatting robocalls a primary objective, and we reiterate points made in our original comments. In response to other comments submitted, we reiterate our view that (1) call recipients, except in the case of Do Not Originate, should be provided with sufficient information and be able to decide whether they want the call-blocking services described in the NPRM; (2) any universal “whitelisting” of calls should be limited to emergency numbers, and any “challenge mechanism” should be appropriately limited; and (3) the FCC’s definition of an “illegal robocall” for the purposes of this proceeding should encompass all illegal robocalls, and be able to accommodate technologies such as ringless voicemail and robotexts.

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