Trades Support FCC Effort to Strengthen ‘Know Your Customer’ Safeguards on Telecom Providers

The American Bankers Association (ABA), ACA International, American Financial Services Association, America's Credit Unions, Bank Policy Institute, Consumer Bankers Association, Defense Credit Union Council, Electronic Transactions Association, Financial Technology Association, Mortgage Bankers Association, and Student Loan Servicing Alliance (collectively, the Associations)^[1] appreciate the opportunity to comment on the Federal Communications Commission's (Commission or FCC) Further Notice of Proposed Rulemaking that would impose stronger "know your customer" requirements on voice service providers that originate calls (Proposal).^[2]

Fraud and scams are 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 and scam losses totaled a staggering $196 billion.^[3] The financial services industry spends billions of dollars each year to educate and protect consumers from fraud and scams, investigate/refer potential criminal activity, and help affected consumers recover their hard-earned money.^[4] But financial institutions cannot do this work alone.

Today, criminals perpetrate fraud and scams on consumers by illegally "spoofing" the number used in the caller ID. Existing FCC rules require each originating provider to take "affirmative, effective measures" to prevent callers from "originat[ing] illegal calls, including knowing its customers…." (the Effective Measures Rule).^[5] But the Commission has not mandated specific standards for compliance with this rule.^[6] Unlike financial institutions that have know your customer (KYC) and customer due diligence (CDD) obligations to help identify and report potential fraud and other illicit activity, voice service providers are not held to commensurate obligations, which facilitates the exploitation of calling networks by fraudsters.

For example, an analysis of call records conducted for ABA identified an originating provider that opened for business in July 2025 and within two months of opening originated more than 136 million calls (in a single month) on its network.^[7] Further analysis showed that the majority of calls originated by this provider were illegal calls.^[8] Clearly, the originating provider did not adequately investigate the companies using its network to perpetrate fraud.

In a comment submitted to the FCC in January 2026, the Associations urged the Commission to specify the steps that voice service providers must take to prevent criminals from originating fraudulent calls.^[9] In this Proposal, the Commission has taken an important step toward requiring originating providers to "know their customer"-i.e., to collect specific information about a prospective customer-before the customer may originate calls on the provider's network. We strongly support the Proposal.

To read the full comment letter, please click here, or click on the download button below.

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

[2] 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) [hereinafter, Proposal].

[3] 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] See, e.g., Joseph Ibitola, Overcoming the Hidden Costs of AML Compliance, Flagright (updated July 1, 2025), https://www.flagright.com/post/overcoming-the-hidden-costs-of-aml-compliance#:~:text=AML%20compliance%20has%20become%20an,a%20financial%20firm's% 20annual%20revenue (reporting that, globally, banks and fintech companies spend an estimated $206 billion per year on financial crime compliance).

[5] 47 C.F.R. § 64.1200(n)(4).

[6] See In the Matter of Telnyx LLC, File No. EB-TCD-24-00037170, FCC 25-10, ¶ 2 (Feb. 4, 2025), https://docs.fcc.gov/public/attachments/FCC-25-10A1.pdf (summarizing 47 C.F.R. § 64.1200(n)(4)); In the Matter of Advanced Methods to Target and Eliminate Unlawful Robocalls, CG Docket No. 17-59, Fourth Report and Order ¶ 34 (Dec. 30, 2020), https://docs.fcc.gov/public/attachments/FCC-20-187A1.pdf (promulgating regulation that gave voice service providers "flexibility" in meeting KYC requirements). The Commission has endorsed certain due diligence steps in a consent decree reached with an IP-based Cloud voice and data provider involving deficient KYC controls, but has not mandated that others implement these KYC controls. See In the Matter of Lingo Telecom, LLC, Order, 39 FCC Rcd 9304, 9316-17, Att. 1 (2024).

[7] In the Matter of Advanced Methods to Target and Eliminate Unlawful Robocalls, Call Authentication Trust Anchor, Rules and Regulations Implementing the Telephone Consumer Protection Act of 1991, Dismissal of Outdated or Otherwise Moot Robocalls Petitions, CG Docket Nos. 17-59, 02-278, & 25-307, WC Docket No. 17-97, Comments of the Am. Bankers Ass'n et al., App. C, 12-13 (filed Jan. 5, 2026), https://www.fcc.gov/ecfs/document/10106019480304/1 [hereinafter, ABA/Joint Trades' Jan. 2026 Comments].

[8] As one piece of evidence that this originating provider was transmitting fraudulent calls, the provider had a Delaware address shared by approximately one hundred other entities and had a primary contact number in a foreign country.

[9] Id. at 22-23.