A coalition of 13 leading financial services trade associations filed joint comments on the Federal Communications Commission’s proposed Know-Your-Upstream-Provider and caller ID authentication requirements. The groups emphasized that voice service providers should be held accountable for verifying callers before assigning the highest-level caller ID trust signal.
The coalition expressed support for the FCC’s efforts to combat illegal robocalls and impersonation fraud while calling for additional requirements for voice service providers to prevent bad actors from exploiting telecommunications networks.
In 2023, the FCC expanded its Effective Measures Rule to require every provider involved in a call’s pathway to take “reasonable and effective steps” to ensure that it does not transmit illegal calls, even when the provider did not originate the call.Â
However, the coalition noted that the commission has not established specific measures providers must take to comply with these requirements.Â
As a result, bad actors can take advantage of originating providers that conduct little or no due diligence before granting “A-level” attestation to calls. A-level attestation represents the highest form of caller number authentication available under the commission’s STIR/SHAKEN caller ID authentication framework.Â
Key Drivers and the Fraud ProblemÂ
Scammers frequently spoof phone numbers associated with bank fraud departments, debt collectors, credit unions and other trusted organizations. By posing as representatives of legitimate institutions, fraudsters can attempt to obtain account credentials or persuade consumers to initiate unauthorized wire transfers.Â
Federal Trade Commission data cited in the comments shows fraud and scam losses totaling $196 billion, with an estimated 15.1 million U.S. adults falling victim to scams in 2025.Â
Financial institutions spend billions of dollars each year on fraud prevention and consumer education. However, the coalition noted that financial institutions cannot independently prevent telecommunications-based impersonation scams.Â
Flaws Identified in Current Telecom RulesÂ
The trade groups identified a systemic issue involving how calls are authenticated across telecommunications networks.Â
Under the STIR/SHAKEN caller ID framework, A-level attestation is the highest level of trust a call can receive. It indicates that the originating voice provider knows the customer and has verified that the customer has the legal right to use the telephone number displayed on caller ID.Â
The coalition said bad actors can exploit originating providers that conduct weak or nonexistent due diligence and grant A-level attestation without properly verifying ownership or authorization to use a telephone number.Â
Terminating providers may then rely on the A-level status when displaying green checkmarks or verified caller indicators on consumers’ smartphones. This can lead consumers to view a call as trustworthy when the underlying authentication was not properly established.Â
The coalition stated that an improper A-level attestation falsely indicates that the originating provider knows who the caller is and has verified the caller’s legal right to use the number displayed to the recipient.Â
Financial Industry Recommendations to the FCCÂ
The joint trade groups urged the FCC to adopt concrete and enforceable requirements for telecommunications providers, including:Â
- Mandatory Verification for A-Level Status: Require originating voice providers to verify that callers have the legal right to use the specific telephone number displayed on caller ID before granting A-level attestation.Â
- Know Your Customer and Know Your Upstream Provider Requirements: Require entities that sell voice services or operate intermediate call pathways to conduct appropriate background and authorization checks on upstream providers and reseller customers.Â
- Reseller Oversight: Require voice service providers that sell services to callers, when another underlying provider performs call origination, to make appropriate and verified STIR/SHAKEN attestations rather than passing unverified traffic through the network.Â
- Enforcement Against Negligent Providers: Increase penalties and establish swift disconnection procedures for voice providers that fail to implement reasonable anti-fraud measures or knowingly carry illegal spoofed traffic.Â
- Protection of Legitimate Communications: Ensure that the rules target bad actors without disrupting lawful communications from legitimate financial institutions, loan servicers and collection agencies, including account alerts, fraud notifications and servicing calls.Â
The comments state that adopting the proposed revisions could reduce consumer harm, improve accountability throughout the voice ecosystem, strengthen the reliability of caller ID authentication and provide additional protections against impersonation scams and other types of fraud.Â
Related FCC Know-Your-Customer ProposalÂ
The FCC also recently proposed enhanced Know-Your-Customer requirements focused on strengthening the obligations of voice service providers to vet customers before allowing them to place calls.Â
The proposal would move the FCC toward a more formalized compliance system for customer identification, verification and record retention. Financial services trade groups have supported establishing a standardized baseline for these processes.Â
Under the current framework, voice service providers are required to take “affirmative, effective measures” to prevent illegal calls. However, the FCC has not previously codified specific Know-Your-Customer standards.Â
The proposed requirements would establish more defined expectations for providers and could provide additional clarity regarding the responsibilities of companies involved in originating and transmitting voice traffic.
Author:Â Jennifer Evancic
Jennifer.Evancic@ResourceManagement.com
Jennifer Evancic is a third-party auditor valued by creditors and large organizations for her knowledge in call monitoring within the collections industry. With meticulous attention to detail and a firm grasp of regulatory requirements, she ensures compliance with clients’ criteria and state and federal regulations.
Jennifer audits collections calls, ensuring they meet client-specific criteria and comply with regulations, providing valuable insights and maintaining industry standards.
Beyond her auditing responsibilities, Jennifer takes the lead in organizing and facilitating monthly call calibrations. These sessions serve as a collaborative forum where clients and their vendors come together to discuss call monitoring results and address any findings or areas for improvement. Jennifer’s guidance fosters open communication and ensures alignment between clients and vendors, driving continuous improvement in collections practices.
Jennifer stays up-to-date with compliance and industry best practices by participating regularly in peer meetings, regulatory updates and industry webinars. This keeps her informed about emerging issues and ensures she remains a knowledgeable leader in collections compliance.
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