Joint Letter to the FCC Supporting the Proposals to Combat Illegal Calls

Dear Chairman Carr,

The undersigned 52 state bankers associations represent banks across our nation that see firsthand the enormous harm caused by criminals who impersonate financial institutions in illegally "spoofed" calls to consumers and businesses. We write to thank you and the Federal Communications Commission (Commission) for advancing proposals that would address this pervasive problem. We urge you to finalize these proposals as soon as feasible.

Criminals can place illegally spoofed calls in part because originating providers typically perform no diligence, or minimal diligence, before allowing full access to phone networks. Every day, millions of illegally spoofed calls are delivered to consumers and businesses even though the calls pass through one or more providers—any one of which could have blocked the illegal call but did not. These "downstream" providers often take few steps to ensure they transmit only legal calls, and not fraudulent or scam calls.

The status quo is unacceptable. We applaud the Commission for proposing rules that will help stop illegal calls at every stage of the calling ecosystem. Specifically, we support the Commission's proposal to require originating providers to "know their customer"—i.e., to collect specific information about a prospective customer—before that customer may originate calls on the provider's network. We also support the Commission's proposal to specify the criteria that originating providers must satisfy before providing an attestation to a call under the "STIR/SHAKEN" call authentication framework. When an originating provider improperly provides an "A-level" attestation to a call, it may lead a terminating provider to apply a green "checkmark" or other signal indicating (falsely) the number is not illegally spoofed. In addition, we support the Commission's proposal to require downstream providers to take specific steps to know the "upstream" providers from which they accept call traffic, to monitor those providers' traffic and compliance practices, and to refuse or discontinue service when the evidence shows that an upstream provider is facilitating illegal calls.

Together, these reforms will help ensure every provider takes meaningful responsibility for keeping illegal calls off our telecommunications network. We appreciate your leadership to stop illegal calls and urge the Commission to finalize these proposals without delay.

Sincerely,
Alabama Bankers Association
Alaska Bankers Association
Arizona Bankers Association
Arkansas Bankers Association
California Bankers Association
Colorado Bankers Association
Connecticut Bankers Association
DC Bankers Association
Delaware Bankers Association
Florida Bankers Association
Georgia Bankers Association
Hawaii Bankers Association
Idaho Bankers Association
Illinois Bankers Association
Indiana Bankers Association
Iowa Bankers Association
Kansas Bankers Association
Kentucky Bankers Association
Louisiana Bankers Association
Maine Bankers Association
Maryland Bankers Association
Massachusetts Bankers Association
Michigan Bankers Association
Minnesota Bankers Association
Mississippi Bankers Association
Missouri Bankers Association
Montana Bankers Association
Nebraska Bankers Association
Nevada Bankers Association
New Hampshire Bankers Association
New Jersey Bankers Association
New Mexico Bankers Association
New York Bankers Association
North Carolina Bankers Association
North Dakota Bankers Association
Ohio Bankers League
Oklahoma Bankers Association
Oregon Bankers Association
Pennsylvania Bankers Association
Puerto Rico Bankers Association
Rhode Island Bankers Association
South Carolina Bankers Association
South Dakota Bankers Association
Tennessee Bankers Association
Texas Bankers Association
Utah Bankers Association
Vermont Bankers Association
Virginia Bankers Association
Washington Bankers Association
West Virginia Bankers Association
Wisconsin Bankers Association
Wyoming Bankers Association