Joint Trades Comment on FCC’s Notice of Proposed Rulemaking

The American Bankers Association (ABA), American Financial Services Association, America's Credit Unions, Bank Policy Institute, Consumer Bankers Association, Defense Credit Union Council, Electronic Transactions Association and Financial Technology Association (collectively, the Associations)^[1] appreciate the opportunity to comment on the Federal Communications Commission's (Commission) Notice of Proposed Rulemaking (Proposal) that would strengthen the Commission's numbering policies to combat illegal calls.^[2]

Fraud continues to be a pervasive problem that takes an extraordinary financial and emotional toll on consumers.^[3] A primary means by which bad actors perpetrate scams and other fraud is through illegal call spoofing. We appreciate that the Commission has advanced a number of proposals to combat illegal spoofing, including proposals that would impose stronger "know your customer" requirements on voice service providers that originate calls (originating providers)^[4] and on "upstream" providers that allow calls to pass through their network.^[5]

Criminals evade detection when placing illegally spoofed calls in part by engaging in the numbering practices the Proposal seeks to restrict. Specifically, the Commission proposes to restrict the resale of phone numbers to a single level-i.e., to require voice service providers that obtain phone numbers from another provider to provide those numbers to end users (i.e., consumers or businesses) and not resell the numbers to another party that will provide the number to an end user.^[6] We agree with the Commission that the resale of telephone numbers can undermine transparency, accountability, and effective enforcement in the numbering ecosystem. When phone numbers are obtained, transferred, or utilized through multiple layers of intermediaries, it obfuscates which entity is placing calls from the number (i.e., which entity controls the number), which provider vetted the caller and which actor should be held responsible for unlawful traffic.

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[1] A description of each Association is provided in Appendix A.

[2] In the Matter of Combatting Illegal Robocalls Through FCC Numbering Policies, Implementation of TRACED Act Section 6(a) - Knowledge of Customers by Entities with Access to Numbering Resources, Numbering Policies for Modern Communications, Telephone Number Requirements for IP-Enabled Service Providers, WC Docket Nos. 26-49, 20-67, 13-97, & 07-243, Notice of Proposed Rulemaking (rel. Mar. 27, 2026) [hereinafter, Proposal].

[3] In a December 2025 report, the Federal Trade Commission estimated that 2024 fraud losses totaled a staggering $196 billion. Fed. Trade Comm'n, Protecting Older Consumers 2024-2025: A Report of the Federal Trade Commission 28 (Dec. 1, 2025), https://www.ftc.gov/system/files/ftc_gov/pdf/P144400-OlderAdultsReportDec2025.pdf.

[4] In the Matter of Advanced Methods to Target and Eliminate Unlawful Robocalls, Rules and Regulations Implementing the Telephone Consumer Protection Act of 1991, CG Docket Nos. 17-59 & 02-278, Further Notice of Proposed Rulemaking (May 1, 2026).

[5] In the Matter of Call Authentication Trust Anchor, Advanced Methods to Target and Eliminate Unlawful Robocalls, WC Docket No. 17-97, CG Docket No. 17-59, Further Notice of Proposed Rulemaking, FCC-CIRC 2605-01 (rel. Apr. 29, 2026).

[6] Proposal, supra note 2, ¶ 48.