The American Bankers Association today joined other financial services associations to express strong support for the Federal Communications Commission’s proposed Robocall Mitigation Scorecard while recommending changes to ensure it provides consumers and businesses with meaningful information about voice service providers’ effectiveness in preventing illegally spoofed calls and texts.
Fraudsters routinely use spoofed calls to impersonate banks, credit unions, nondepository financial institutions and other trusted organizations, potentially facilitating the theft of login credentials, account takeovers, fraudulent transfers and other substantial losses. In a joint letter, the associations commend the FCC for its continued efforts to protect consumers from illegal spoofing and restore trust in the nation’s communications networks.
The associations urged the FCC to base the scorecard on measurable results rather than rating providers solely on their compliance with existing laws. Specifically, the letter recommends 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.
“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.
The associations cautioned that 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. Conversely, 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.
The associations also recommended that the FCC rate originating and intermediate providers, and not solely providers that deliver calls to the recipient, to create strong market incentives for every provider in a call’s pathway to prevent illegal spoofing. The letter notes that terminating providers and enterprise callers, including financial institutions, could use the scorecard’s information when deciding which voice service providers to do business with.
The groups 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.









