Letter Supporting Issuance of FNPRM re: "Know Your Customer" Requirements for Originating Providers

Dear Chairman Carr,

The American Bankers Association (ABA) commends you and the Federal Communications Commission (Commission or FCC) for scheduling a vote to issue a proposal (Proposal) that would impose stronger "know your customer" requirements on voice service providers that originate calls. We appreciate your leadership in combating fraud perpetrated by bad actors that impersonate banks and other legitimate businesses in calls placed to consumers.

Today, criminals perpetrate fraud on consumers by illegally "spoofing" the number used in the caller ID. Criminals can place illegally spoofed calls in large part because originating providers do not regularly engage in meaningful investigation of callers before allowing them to originate calls on the provider's network. Existing FCC rules require each originating provider to take "affirmative, effective measures" to prevent callers from "originat[ing] illegal calls, including knowing its customers . . . ." (the Effective Measures Rule). But the Commission has not mandated specific standards for compliance with this rule.

In a recent comment, ABA urged the Commission to specify the steps that voice service providers must take to prevent criminals from originating fraudulent calls. In that comment, we shared an analysis conducted for ABA that identified a fraudulent originating provider that increased its calling operations from originating no calls in July 2025 to more than 136 million calls by September 2025. Further analysis showed that the majority of calls originated by this provider consisted of illegal calls. Clearly, the provider did not adequately investigate the (bad actor) companies permitted to originate calls on the provider’s network.

We agree with the Commission's suggestion that it should specify, at a minimum, a basic set of identifying information from callers—such as name, physical address, government-issued identification number, alternate phone number, and intended purpose of the calls—before the originating provider allows the caller to originate calls on the provider’s network. If a caller seeks access to thousands of phone numbers to place millions of calls, the provider should investigate why the caller seeks access to so many numbers. We also agree with the Commission that it should codify a base forfeiture amount when a provider violates the FCC's rules requiring providers to take effective measures to prevent the origination of illegal calls. The analysis conducted for ABA referenced above strongly suggests that requiring originating providers to collect certain information—and imposing forfeitures for violations of the FCC’s rules—would lead providers to investigate callers and avoid doing business with criminals who seek to defraud consumers through illegal calls.

We look forward to the Commission’s consideration of the Proposal at its April 30 meeting and to seeing it finalized.

Sincerely,