In a joint letter today, the American Bankers Association and four financial and healthcare trade associations expressed support for the Federal Trade Commission’s proposal to make it unlawful to provide goods or services “with knowledge or reason to know” that those goods or services will be used to “pose as” a government, business or individual. The FTC issued the proposal after it finalized a rule last month that makes impersonation of a government or business unlawful.
The associations urged the FTC to impose liability on voice service providers that provide consumers with unauthenticated or falsified caller ID information in the consumer’s caller ID display. “If a voice service provider provides a consumer with unauthenticated or falsified caller ID information, that provider has acted ‘with knowledge’ or with the ‘reason to know’ that its telecommunications services are being used to ‘pose as’ a government or business,” the associations said. “If a voice service provider delivers to the consumer a call with unauthenticated or falsified caller ID information, it must state ‘unknown caller’ or similar cautionary information in the caller ID display.”
The associations representing financial institutions also expressed appreciation that the proposal does not impose liability on a payment service that is used by a bad actor to receive or transfer funds facilitated by unlawful spoofing.
