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Home Compliance and Risk

State AGs urge FCC to impose stronger ‘know your upstream provider’ requirements

September 14, 2026
Reading Time: 2 mins read
ABA urges FCC to modernize calling rules, strengthen fraud protections

Forty-nine state attorneys general last week urged the Federal Communications Commission to impose stronger “know your upstream provider” requirements to keep calls off the U.S. calling network. Last month, the American Bankers Association led a group of 13 trade associations representing banks, credit unions and nondepository institutions in urging the FCC to advance the proposal.

The FCC’s proposal would require the “downstream” provider in the call’s pathway to collect certain information about the caller from the “upstream” provider — that is, the provider that originated or otherwise transmitted the call to the downstream provider — to better ensure each provider is transmitting only lawful calls. The proposal also would require downstream providers to monitor upstream providers’ call traffic and compliance practices, and to refuse or discontinue service when the evidence shows that an upstream provider is facilitating illegal calls.

In addition, the proposal would strengthen the requirements for “A-level” and “B-level” attestations, citing data ABA previously provided demonstrating that originating providers are improperly assigning attestation levels. Under STIR/SHAKEN, calls are “signed” at origination with different levels of “attestation.” A call that receives an “A-level” attestation – the highest form of attestation – means the originating provider knows the caller and knows the caller has the legal right to the number that will be displayed in the recipient’s caller ID. If a call receives A-level attestation, it is eligible for vendors’ call branding designed to signal that the call is from a legitimate source, such as a green “checkmark.”

“The FCC needs to hold telecom providers accountable at the source for allowing and profiting from the illegal traffic in the first place,” said Idaho Attorney General Raúl Labrador, who led the letter. “I am urging the FCC to strengthen its rules and crack down on scammers before they can target Idaho families.”

Tags: FCCFraudScamsTelecommunications infrastructure
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