Several financial industry associations expressed their support for the Federal Communications Commission’s (FCC) proposed Robocall Mitigation Scorecard, but made some recommendations to improve upon it.
The FCC’s Scorecard is designed to empower consumers and encourage providers to combat illegal robocalls. It seeks to do this by providing the public with an assessment of the effectiveness of voice service providers’ efforts to protect consumers from illegal robocalls. The Scorecard will then give consumers a tool for choosing the provider that best protects customers from those calls.
Within the financial services industry, fraudsters routinely use spoofed calls to impersonate banks, credit unions, and financial institutions in an effort to steal login credentials, takeover accounts, make fraudulent transfers, and conduct other schemes.
While commending the FCC for its efforts to protect consumers from illegal spoofing and restore trust in communications networks, the associations made a few suggestions to improve the Scorecard.
Foremost, they urged the FCC to base the scorecard on measurable results rather than rating providers solely on their compliance with existing laws. They recommend that the scorecard report the number of illegally spoofed calls that pass through a provider’s network without being blocked as a percentage of the network’s total call volume.
The associations said the total number of calls blocked by a provider is not, by itself, an effective measure of success. A provider could block millions of illegal calls while still allowing a significant number to move across its network. Also, providers with strong “know your customer” or “know your upstream provider” controls could prevent illegal calls from entering their networks in the first place and therefore have fewer calls to block.
“We strongly believe the Scorecard should encourage prevention, not merely removal of illegally spoofed calls after they have entered the provider’s network,” the groups wrote in a letter to the FCC.
The letter was signed by the American Bankers Association, American Financial Services Association, America’s Credit Unions, Bank Policy Institute, Consumer Bankers Association, Defense Credit Union Council, Electronic Transactions Association, Mortgage Bankers Association, and Payments Leadership Council.
In addition, the associations recommended that the FCC rate originating and intermediate providers, and not solely providers that deliver calls to the recipient. This would create strong market incentives for every provider in a call’s pathway to prevent illegal spoofing.
The groups also encouraged the FCC to rate wireless providers on their effectiveness in keeping illegal text messages off their networks. The letter cites Federal Trade Commission data showing that consumers reported approximately $470 million in losses from scams initiated through text messages in 2024, more than five times the amount reported in 2020.