The American Bankers Association today expressed strong support for a Federal Communications Commission proposal to strengthen the Robocall Mitigation Database and recommended additional measures to stop illegally spoofed calls. Ten other trade associations representing banks, credit unions and other financial service providers joined ABA in signing the comment letter.
All voice service providers must register in the RMD and submit information on their practices to prevent the transmission of illegal calls over their networks. The FCC may remove a provider from the RMD for a deficient filing or for failing to implement effective measures to prevent callers from using the provider’s network to originate or transit illegal calls. The threat of removal from the RMD provides a strong incentive for providers to implement effective measures to prevent the origination or transmission of illegal calls.
The FCC’s proposal clarifies which entities must file reports in the RMD, requires entities to file more specific information on their efforts to prevent the transmission of illegal calls, establishes a more robust pre-screening process for RMD submissions, and limits exemptions from filing requirements, among other steps.
The associations expressed support for the FCC’s proposal while offering recommendations to strengthen it. They asked the FCC to require each provider to state in its RMD filing the year in which it started providing voice service. This data point may help identify a provider that is the successor to an entity that was removed from the RMD for good cause, they said.
The associations also expressed support for the FCC’s proposal to create a “pending” status for a voice service provider’s filing, and urged the commission to list all providers that submit new filings with a pending status. This would provide the agency (and the public) with the opportunity to review the provider’s submission before the provider can transmit voice calls, they said.
Additionally, they expressed support for the FCC’s proposal to establish a “one-step removal process” to allow the agency to remove from the RMD a provider that has originated or transmitted calls impersonating another entity, including facilitating bank impersonation calls, among other reasons that would trigger this process. The associations also urged the FCC to continue to make clear that a company’s in-house PBX or call center is not required to file in the RMD.
