ABA/Joint Trades' Comment in Support of Stronger KYC Requirements for Originating Providers

INTRODUCTION AND SUMMARY

The American Bankers Association (ABA), ACA International, American Financial Services Association, America's Credit Unions, Bank Policy Institute, Consumer Bankers Association, Defense Credit Union Council, Electronic Transactions Association, Financial Technology Association, Mortgage Bankers Association, and Student Loan Servicing Alliance (collectively, the Associations) appreciate the opportunity to comment on the Federal Communications Commission's (Commission or FCC) Further Notice of Proposed Rulemaking that would impose stronger "know your customer" requirements on voice service providers that originate calls (Proposal).

Fraud and scams are a pervasive problem that often takes an extraordinary financial and emotional toll on consumers. In a December 2025 report, the Federal Trade Commission estimated that 2024 fraud and scam losses totaled a staggering $196 billion. The financial services industry spends billions of dollars each year to educate and protect consumers from fraud and scams, investigate/refer potential criminal activity, and help affected consumers recover their hard-earned money. But financial institutions cannot do this work alone.

Today, criminals perpetrate fraud and scams on consumers by illegally “spoofing” the number used in the caller ID.

Download the joint comment letter to read the full text.