Letter to the FCC on "Know Your Upstream Provider"

Dear Chairman Carr,

The American Bankers Association (ABA) commends you and the Federal Communications Commission (Commission) for scheduling a vote on May 20 to issue a proposal to impose stronger “know your upstream provider” (KYUP) requirements on voice service providers that allow calls to pass through their network (Proposal). The Proposal also would require originating providers to take certain actions to ensure they do not originate illegally spoofed calls.

We appreciate your continued leadership to prevent criminals from impersonating banks and other legitimate businesses in calls placed to consumers. Last month, with ABA’s support, the Commission voted to issue a separate proposal that would impose stronger "know your customer" requirements on voice service providers that originate calls. The Proposal the Commission will consider on May 20 is an important complement to that action. It would require all voice service providers in the call’s pathway to collect certain information about the caller from the “upstream” provider—e.g., the provider that originated the call—to better ensure each provider is transmitting only lawful calls.

Significantly, the Proposal also seeks to strengthen the requirements for "A-level" or "B-level" attestations. Under the “STIR-SHAKEN” call authentication framework, calls are "signed" at origination with different levels of "attestation."

Download the letter to read the full text.