BPI, Financial Services Trades Comment on FCC Robocall Scorecard Proposal

The American Bankers Association (ABA), American Financial Services Association, America's Credit Unions, Bank Policy Institute (BPI), Consumer Bankers Association, Defense Credit Union Council, Electronic Transactions Association, Mortgage Bankers Association, and Payments Leadership Council (collectively, the Associations)^[1] appreciate the opportunity to comment on the Consumer and Governmental Affairs Bureau's proposed Robocall Mitigation Scorecard (Scorecard).^[2]

The Associations strongly support the Commission's continued efforts to use every available tool to protect consumers from illegally spoofed calls and to restore trust in the nation's communication networks. 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.^[3] 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.^[4]

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] 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) [hereinafter, Public Notice].

[3] 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

[4] 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.