We strongly support the FCC’s proposal to require that prior express consent for some calls that use AI must include a “clear and conspicuous disclosure that the consumer consents to receive AI-generated calls.” We also strongly support the in-call disclosure proposed by the Commission. The distinguishing characteristics of calls that should trigger the specific consent requirement and the in-call disclosure relate to the extent to which the calls are likely to deceive or misrepresent to recipients the origin or the party responsible for the call, or to confuse the recipient regarding whether they are speaking to a real human being or not. The AI calls that are likely to deceive or confuse the recipient are calls that are either interactive, or in which AI is used to clone a human’s voice to misrepresent the true caller.
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