Letter to the FCC on Improving the Effectiveness of the Robocall Mitigation Database, Call Authentication Trust Anchor

Dear Chairman Carr,

The American Bankers Association  (ABA) commends you and the Federal Communications Commission (Commission) for scheduling a vote on July 22 to issue a proposal (Proposal) to strengthen the Robocall Mitigation Database (RMD).

The RMD plays an important role in the Commission's efforts to prevent criminals from placing calls to consumers that impersonate banks or other legitimate businesses. All voice service providers must register in the RMD and submit information on their practices to prevent the transmission of illegal calls over their networks. However, as the Commission acknowledged last year, in the past certain providers "have not demonstrated the requisite level of diligence in ensuring that information submitted to the Database is accurate, complete, and up-to-date." We appreciate that, with ABA’s support,  the Commission issued a final rule last year that required RMD filers to update information more promptly, established a $10,000 base forfeiture amount for submitting false or inaccurate information to the RMD, and directed the Commission's Wireline Competition Bureau (WCB) to establish a mechanism for reporting deficient RMD filings,  which WCB established this past January. 

The Proposal builds on these steps by seeking to clarify which entities must file reports in the RMD, to require entities to file more specific information on their efforts to prevent the transmission of illegal calls, and to limit exemptions from filing requirements, among other steps. The Proposal also seeks comment on measures to prevent bad actor providers—and the individuals and entities leading those providers—from reentering the RMD after the Commission removes them. It is critical that providers file robust plans describing how they will prevent criminal callers from accessing the provider's network, and that the Commission hold providers accountable for following their plans and prevent bad actors from reentering the RMD under a new corporate identity.

We encourage the Commission to continue exploring measures that reduce the time required to identify and remove from the RMD providers that, based on objective evidence, appear to exist primarily to facilitate unlawful calling campaigns or other fraudulent communications. Accelerating the identification and removal of these bad actors will reduce consumer harm, strengthen confidence in the communications ecosystem, and better protect banks and their customers from impersonation fraud.

We look forward to continuing to work with the Commission to protect Americans from fraud.

Sincerely,

Jonathan Thessin
Vice President/Senior Counsel
Consumer & Regulatory Compliance
Regulatory Compliance and Policy