Leveraging AI in the Fight Against Robocalls

The FCC's latest Notice of Proposed Rulemaking (NPRM) in CG Docket No. 23-362 emphasizes the growing importance of artificial intelligence (AI) in combatting unwanted robocalls and robotexts. This effort seeks to protect consumers while simultaneously investigating good uses of AI, particularly for people with impairments. The NPRM proposes new regulations and solicits public feedback on several areas of AI-generated communication, which have important implications and prospects for federal government contractors.

The NPRM describes the existing situation under the Telephone Consumer Protection Act (TCPA), which prohibits robocalls and robotexts without the recipient's prior affirmative consent. As AI technologies become more advanced and widely used, the potential for abuse in the form of fraudulent or deceptive robocalls grows. In response, the FCC proposes defining "AI-generated call" as any call that employs technology to artificially generate a voice or text through computational tools, machine learning, predictive algorithms, or huge language models.

One of the major recommendations is to demand explicit and prominent disclosures when utilizing AI-generated content in calls or texts. This would ensure that customers are aware of the nature of the call and may make an informed decision about whether to participate. The NPRM specifically proposes that callers notify receivers at the start of each AI-generated voice call that AI technology is being used. Furthermore, any consent received from consumers for artificial or prerecorded calls must expressly include agreement to receive AI-generated content.

The NPRM also discusses AI's beneficial applications, such as improving telephone network accessibility for people with disabilities. For example, the FCC recommends exempting from TCPA requirements any artificial or prerecorded voice calls made by people with speech or hearing problems who use AI technologies to communicate. This exemption demonstrates the FCC's commitment to ensuring that regulations do not inadvertently impede the beneficial applications of AI.

The NPRM is seeking public feedback on developing and deploying technology that can detect and alert customers to potentially fraudulent or AI-generated calls in real time. This contains comments on privacy implications and whether the FCC should impose regulations to preserve the privacy of both callers and call recipients. The goal is to strike a balance between consumer protection and the development of innovative technologies that improve communication.

For government contractors, the proposed reforms bring both obstacles and opportunity. Compliance with increased disclosure standards, as well as the development of AI detection and alerting solutions, will most certainly necessitate investment and adaptation. Contractors who specialize in AI and telecoms, on the other hand, can use these regulatory changes to provide new services and solutions to their clients, particularly in terms of improving communication system security and transparency.

Furthermore, the NPRM's focus on accessibility is consistent with broader federal programs promoting inclusion and equal access to technology. Contractors who build AI applications for people with impairments may discover new ways to grow their business and contribute to these socially useful projects.

In conclusion, the FCC's NPRM on AI-generated calls and texts is a significant regulatory step toward tackling the dual difficulties of safeguarding customers from fraudulent communications while also encouraging the constructive uses of AI. Federal government contractors should stay up to date on these developments, participate in the public comment process, and consider innovative solutions that are consistent with the proposed requirements. By doing so, businesses may position themselves as leaders in the rapidly changing world of AI and telecoms, ultimately helping both their company and the larger community.

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