ABA, Financial Services Trades Urge FCC to Adopt Outcome-Based Robocall Scorecard

In a new comment letter filed today, the American Bankers Association, American Financial Services Association, America's Credit Unions, Bank Policy Institute, Consumer Bankers Association, Defense Credit Union Council, Electronic Transactions Association, Mortgage Bankers Association and Payments Leadership Council expressed strong support for the Federal Communications Commission's proposed Robocall Mitigation Scorecard while recommending changes to ensure it provides consumers and businesses with meaningful information about voice service providers' effectiveness in preventing illegally spoofed calls and texts.

Fraudsters routinely use spoofed calls to impersonate banks, credit unions, nondepository financial institutions and other trusted organizations, potentially facilitating the theft of login credentials, account takeovers, fraudulent transfers and other substantial losses. In the letter, the associations commend the FCC for its continued efforts to protect consumers from illegal spoofing and restore trust in the nation's communications networks.

The associations urged the FCC to base the scorecard on measurable results rather than rating providers solely on their compliance with existing laws. Specifically, the letter recommends that the scorecard report the number of illegally spoofed calls that pass through a provider's network without being blocked as a percentage of the network's total call volume.

"We strongly believe the Scorecard should encourage prevention, not merely removal of illegally spoofed calls after they have entered the provider's network," the groups wrote.

The associations cautioned that the total number of calls blocked by a provider is not, by itself, an effective measure of success. A provider could block millions of illegal calls while still allowing a significant number to move across its network. Conversely, providers with strong "know your customer" or "know your upstream provider" controls could prevent illegal calls from entering their networks in the first place and therefore have fewer calls to block.

The associations also recommended that the FCC rate originating and intermediate providers, and not solely providers that deliver calls to the recipient, to create strong market incentives for every provider in a call's pathway to prevent illegal spoofing. The letter notes that terminating providers and enterprise callers, including financial institutions, could use the scorecard's information when deciding which voice service providers to do business with.

The groups encouraged the FCC to rate wireless providers on their effectiveness in keeping illegal text messages off their networks. The letter cites Federal Trade Commission data showing that consumers reported approximately $470 million in losses from scams initiated through text messages in 2024, more than five times the amount reported in 2020.

Read the joint comment letter.

About the American Bankers Association
The American Bankers Association is the voice of the nation's $26.5 trillion banking industry, which is composed of small, regional and large banks that together employ over 2 million people, safeguard $20.7 trillion in deposits and extend $13.9 trillion in loans.

About the American Financial Services Association
The American Financial Services Association (AFSA) is the national trade association for the consumer credit industry, protecting access to credit and consumer choice. AFSA members provide consumers with closed-end and open-end credit products including traditional installment loans, mortgages, direct and indirect vehicle financing, payment cards, and retail sales finance.

About America's Credit Unions
America's Credit Unions is the unified voice for not-for-profit credit unions, representing more than 96% of the industry's assets and their more than 146 million members nationwide. America's Credit Unions provides strong advocacy, resources and services to advance, empower, and protect credit unions and the people and communities they serve. For more information about America's Credit Unions, visit AmericasCreditUnions.org.

About the Bank Policy Institute
The Bank Policy Institute is a nonpartisan public policy, research and advocacy group that represents universal banks, regional banks and the major foreign banks doing business in the United States. The Institute produces academic research and analysis on regulatory and monetary policy topics, analyzes and comments on proposed regulations, and represents the financial services industry with respect to cybersecurity, fraud and other information security issues.

About Consumer Bankers Association
The Consumer Bankers Association represents America's leading retail banks. We promote policies to create a stronger industry and economy. Established in 1919, CBA's corporate member institutions account for 1.7 million jobs in America, extend roughly $4 trillion in consumer loans and provide $275 billion in small business loans annually. Follow us on X @consumerbankers.

About the Defense Credit Union Council
The Defense Credit Union Council (DCUC) is the trusted national association representing credit unions through defense and military financial expertise alongside industry advocacy, policy coordination, and legislative and regulatory priorities that impact the readiness and welfare of more than 145 million credit union members. Founded in 1963 to advocate for credit unions on military installations, DCUC has grown into a national voice for credit unions serving all who serve across the United States and overseas. For more information, visit dcuc.org.

About the Electronic Transactions Association
The Electronic Transactions Association (ETA) is the world's leading advocacy and trade association for the payments industry. Our members span the breadth of significant payments and fintech companies, from the largest incumbent players to the emerging disruptors in the U.S. and in more than a dozen countries around the world. ETA members make commerce possible by processing approximately $52.7 trillion annually in purchases and P2P payments worldwide and deploying payments innovation to merchants and consumers.

About the Mortgage Bankers Association
The Mortgage Bankers Association (MBA) is the national association representing the real estate finance industry, an industry that employs more than 275,000 people in virtually every community in the country. Headquartered in Washington, D.C., the association works to ensure the continued strength of the nation's residential and commercial real estate markets, to expand homeownership, and to extend access to affordable housing to all Americans. MBA promotes fair and ethical lending practices and fosters professional excellence among real estate finance employees through a wide range of educational programs and a variety of publications. Its membership of more than 2,000 companies includes all elements of real estate finance: independent mortgage banks, mortgage brokers, commercial banks, thrifts, REITs, Wall Street conduits, life insurance companies, credit unions, and others in the mortgage lending field. For additional information, visit MBA's website: www.mba.org.

About the Payments Leadership Council
As a CEO-led organization, the Payments Leadership Council is committed to expanding global commerce and driving inclusive growth by encouraging public policies that protect consumers, foster inclusion, and promote innovation and competition in payments.

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About the American Bankers Association

The American Bankers Association is the voice of the nation's $26.5 trillion banking industry, which is composed of small, regional and large banks that together employ over 2 million people, safeguard $20.7 trillion in deposits and extend $13.9 trillion in loans.