BPI, Financial Services Trades Comment on FCC Robocall Mitigation Database Proposal

The American Bankers Association (ABA), ACA International,^[1] American Financial
Services Association, America's Credit Unions, Bank Policy Institute (BPI), Consumer Bankers Association, Defense Credit Union Council, Electronic Transactions Association, Financial Technology Association, Mortgage Bankers Association, and Payments Leadership Council (collectively, the Associations)^[2] appreciate the opportunity to comment on the Federal Communications Commission's proposal (Proposal) to strengthen the Robocall Mitigation Database.^[3]

The Associations strongly support the Commission's continued efforts to use every
available tool to protect consumers from illegally spoofed calls, including the current Proposal to strengthen the Robocall Mitigation Database. Fraudsters routinely use illegally spoofed calls to impersonate banks, credit unions, nondepository financial institutions, payment providers, government agencies, law enforcement, and other trusted organizations, causing substantial financial harm to consumers. A recent survey of banks indicates that these scams are on the rise.^[4] Illegally spoofed calls and texts can facilitate the theft of log-in credentials and takeover of a consumer's or business' account, and lead to fraudulent transfers and other substantial losses.^[5]

We commend the Commission for its recent proposals to require all voice service providers in a call's pathway to take meaningful steps to prevent illegally spoofed calls from reaching consumers^[6] and to propose a "Robocall Mitigation Scorecard" to rate voice service providers' effectiveness in combating illegal calls.^[7] Recent polling shows that strong majorities of Americans support the Commission's proposals: 82% of consumers said they support regulatory action that requires providers that originate calls to do more to authenticate the identity of a caller to prevent illegally spoofed caller IDs.^[8] Additionally, 81% of consumers support regulatory action that requires intermediate providers - i.e., providers that receive calls from "upstream" providers and transit the calls to a provider that is farther "downstream" - to do more to stop illegally spoofed calls that pass through their network, rather than delivering the illegal calls to recipients or to another provider.^[9] We urge the Commission to finalize its proposals as soon as feasible.

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

[1] ACA International is also filing separate reply comments on the proposed definition of a voice
service provider.

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

[3] In the Matter of Improving the Effectiveness of the Robocall Mitigation Database, Call
Authentication Trust Anchor, Advanced Methods to Target and Eliminate Unlawful Robocalls,
WC Docket Nos. 24-213 & 17-97, CG Docket No. 17-59, Further Notice of Proposed
Rulemaking, FCC 26-49 (July 23, 2026) [hereinafter, Proposal].

[4] See Tara Payne, Drew Ruben & Madison Stulga, Bank Policy Institute, Hijacking Trust: How
Scammers Exploit the Banking System's Most Valuable Asset (July 20, 2026),
https://bpi.com/wp-content/uploads/2026/07/Hijacking-Trust-How-Scammers-Exploit-the
Banking-Systems-Most-Valuable-Asset.pdf. The survey of 14 BPI member banks found that the
average number of identified bank-impersonation scams originated by a phone call or text
message increased 124 percent from 2024 to 2025. Id. at 2. Two surveyed banks reported that 40
percent of calls appearing to originate from bank-owned numbers had been spoofed. Id.

[5] See Protecting Seniors from AI Fraud: Hearing Before the S. Spec. Comm. on Aging, 119th
Cong. (2026) (testimony of Paul Benda, Exec. Vice Pres. for Risk, Fraud & Cybersecurity, Am.
Bankers Ass'n) (describing specific harms to consumers that often result from illegally spoofed
calls), https://www.aba.com/advocacy/policy-analysis/testimony-of-paul-benda-on-protecting
seniors-from-ai-fraud; 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, Reply Comments of the Am. Bankers Ass'n to the
Further Notice of Proposed Rulemaking (filed July 27, 2026),
https://www.fcc.gov/ecfs/document/26110059138/1 (summarizing comments submitted by
bankers that described how fraudsters spoof the telephone number of the bank's fraud
department or customer service line, pose convincingly as trusted bank employees, and persuade
customers to disclose sensitive account information that the fraudster uses to initiate funds
transfers).

[6] See 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, FCC 26-27, Further Notice of Proposed Rulemaking (rel. May 1, 2026) (proposing
to require originating providers to "know their customer"-i.e., to collect specific information
about a prospective customer-before that customer may originate calls on the provider's
network); 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, FCC 26-32,
Further Notice of Proposed Rulemaking (rel. May 21, 2026) (proposing to strengthen the
"STIR/SHAKEN" call authentication framework and impose "know your upstream provider"
requirements on "downstream" providers).

[7] Public Notice, In the Matter of Empowering Consumers through Robocall Scorecard,
Consumer and Governmental Affairs Bureau Seeks Comment on Robocall Scorecard, CG
Docket No. 26-239 (rel. Sept. 2, 2026).

[8] Press Release, Am. Bankers Ass'n, National Survey: U.S. Consumers Trust Banks Most for
Fraud Protection (Oct. 26, 2026), https://www.aba.com/about-us/press-room/press-releases/oct
2026-morning-consult-survey-us-consumers-trust-banks-most-for-fraud-protection. The poll was
conducted by Morning Consult on behalf of ABA from October 9-12, 2026, among a national
sample of 4,402 adults split into two representative groups for specific question sets. Results
from the full survey have a margin of error of plus or minus 1 percentage point.

[9] Id.