📢 CAIDP Provides Comments to FCC on AI, Consumer Protection, and Robocalls (Oct. 10, 2024)
The Center for AI and Digital Policy has provided detailed comments to the Federal Communications Commission regarding a proposed rule on the implications of AI on communications technologies.
CAIDP commended the FCC's initiative to "protect consumers from the abuse of artificial intelligence (AI) systems, particularly considering the exacerbation of AI-driven risks of crime, fraud, and annoyance, by undertaking rulemaking that centers the privacy and security of consumers."
⚠️🤖 📞 CAIDP explained, "As the FCC is aware, robocalls are not new. However, the breakthroughs in AI and machine learning (ML) systems also pose novel threats to human interaction, and trust and existing regulatory paradigms are inadequate to address these threats. Now more than ever, the FCC must adopt regulations that are human-centric, and place the public interest, privacy, and security of consumers above all else.
⚠️🤖 📞 CAIDP also warned, "Machine learning systems mimic and manipulate human behavior. Understanding this fundamental nature of the technology is also key to contextualizing the potential uses and abuses of AI systems."
CAIDP recommended that the FCC:
➡️ Establish an “opt-in” regime for calls, messages, and AI-generated communications
➡️ Enhance accountability measures to limit AI risks to consumers
CAIDP also wrote:
🔥 "To ensure that its definition of “AI-generated calls” remains relevant and effective, the Commission should use broad, technology-neutral language that focuses on the functionality and impact of AI rather than specific technical implementations. "
🔥 "The definition adopted by the Commission should cover both generative and predictive AI technologies, as both can be used in ways that increase risks to consumers. "
CAIDP also cautioned against carrying forward opt-in consent from pre-AI generated communications:
🔥 "The Proposed Rule seeks to address the seismic shifts in technology with the introduction and commercialization of GenAI systems. Therefore, grandfathering existing consents under the proposed rule would defeat the very purpose of the rule. We recommend implementing an opt-in system where consumers specifically opt-in to receive AI-generated calls, even where extant requirements provide for express consent."
The Federal Communications Commission will receive reply comments until October 25, 2024 and will then issue a final rule.
Christabel R. Marc Rotenberg Merve Hickok Rupali Lekhi Bhawna M. Ngonidzaishe Gotora Peter Zhang
Executive Legal |Tech Law| | Data Protection | Contracts |Compliance | Policy Development| AI
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