Joint Trades Comment on FCC’s Proposal for Know Your Upstream Provider Requirements

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, National Council of Higher Education Resources, Payments Leadership Council, 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 to enhance "know-your-upstream-provider" (KYUP) requirements and strengthen the "STIR/SHAKEN" caller ID authentication framework.^[2]

Fraud and scams continue to be 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] A separate 2026 report found that, in 2025, 6% of U.S. adults - an estimated 15.1 million people - say they were scammed out of money.^[4]

Banks, credit unions, and other financial service providers see firsthand the enormous harm caused by criminals who impersonate trusted financial institutions in illegally "spoofed" calls to consumers and businesses. Individual bankers recently submitted dozens of comments in a parallel FCC proceeding that described the harm that criminals perpetrate through illegal calls.^[5] Bank comments 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] We commend the Commission for recently issuing a warning to alert consumers to bank impersonation scams.^[7] This advisory complements our industry's ongoing efforts to educate consumers about impersonation scams, such as through ABA's #BanksNeverAskThat campaign.^[8]

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 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 26-32 (rel. May 21, 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] Gallup & Stop Scams Alliance, United States of Scams: The Financial and Emotional Fallout 3, https://www.gallup.com/analytics/711827/scams-in-america.aspx (2026).

[5] 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 banker comments) [hereinafter, ABA Reply Comments].

[6] See id. at 3-5, n.5-7 and accompanying text.

[7] Press Release, Fed. Commc'ns Comm'n, FCC Consumer Alert: Bank Impersonation Scams: Bank Imposters Pressure Consumers to Take Immediate Action to Protect Their Money (July 21, 2026).

[8] Am. Bankers Ass'n, #BanksNeverAskThat, https://www.banksneveraskthat.com/ (last visited Aug. 5, 2026).