Joint Trades Comment to the FCC re: TCPA Reform and Illegal Call Spoofing

Introduction and Summary

The American Bankers Association (ABA), American Financial Services Association, America's Credit Unions, Bank Policy Institute (BPI), Consumer Bankers Association, Defense Credit Union Council, Mortgage Bankers Association, and Student Loan Servicing Alliance (the Associations) appreciate the opportunity to comment on the Federal Communications Commission's (Commission or FCC) Ninth Further Notice of Proposed Rulemaking (Proposal).

Fraud is 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 losses totaled a staggering $196 billion. Increasingly, criminals perpetrate fraud by impersonating banks and other legitimate companies through voice calls, text messages, and advertisements on social media websites. Criminals illegally "spoof" the number used in the caller ID – i.e., to cause a call recipient's caller ID to display the name, or solely the number, of a legitimate company instead of the name and number of the actual caller – with the intent to defraud the consumer.

The financial services industry spends billions of dollars each year to protect consumers from fraud, investigate potential criminal activity, and help affected consumers recover their hard-earned money. But financial institutions cannot do this work alone. We need a whole-of-government strategy to address this serious problem, and the FCC has a critical role to play. Currently, fraud committed through voice calls and text messages continues unabated because, unlike banks and credit unions that have customer identification obligations, wireless providers take few steps to stop fraudsters from impersonating legitimate companies and gaining consumers' trust. That must end.

We commend the Commission for proposing enhancements to the "STIR/SHAKEN" call authentication framework that promise to keep bad actors off calling networks and promote consumers' confidence that the calls they receive are legitimate. But the Commission should go further. We urge the Commission to finalize rules that specify the steps that voice service providers that originate calls (originating providers) must take to comply with an existing rule that requires providers to take effective steps to ensure that it does not transmit illegal calls. We also urge the Commission to require providers to verify the caller has the legal right to the number that will be displayed in the recipient's caller ID.

We also support the Commission's efforts to advance the use of "Rich Call Data" (RCD), which uses encrypted tokens to securely transmit the caller's name, logo, and/or website to the recipient's caller ID display.

Download the joint comment letter to read the full text.