WASHINGTON — America’s Credit Unions and the Defense Credit Union Council joined nine other financial services and payments trade associations in urging the Federal Communications Commission to strengthen its Robocall Mitigation Database to keep fraudulent callers from impersonating credit unions, banks and other trusted organizations.
In joint reply comments dated Nov. 9, the 11 associations supported the FCC’s proposed changes and called for prompt adoption, saying illegally spoofed calls can trick consumers into surrendering account credentials, enable account takeovers and lead to fraudulent transfers.
The database requires voice service providers to register and describe steps they take to prevent illegal calls from moving through their networks. Other providers rely on those registrations when deciding whether they may accept call traffic.

Five Changes Sought
The groups recommended that the FCC:
- Require providers to disclose the year they began offering voice service, helping regulators and other carriers identify potential successors to companies removed from the database.
- Require intermediate providers to consult database records, including past enforcement actions, when evaluating the risk posed by upstream providers.
- Carefully review new registrations before accepting them, initially placing applicants in a publicly visible pending status.
- Speed enforcement against providers facilitating illegal calls, including by adding Enforcement Bureau personnel.
- Clarify that companies’ in-house telephone systems and internal call centers do not have to register in the database.
The associations said removing a company from the database may not stop its activity if the operation reappears under another corporate name. They cited information provided to the American Bankers Association indicating that traffic associated with a provider removed in March 2026 shifted the following month to an apparently successor company.
They urged the FCC to compare identifying information about company officials and reject filings from entities determined to be successors to removed providers. The groups also backed an expedited, one-step removal process for particularly serious violations, including calls impersonating financial institutions.
The filing said one FCC enforcement action involving foreign-originated spoofed calls began 21 months after the calls were reported. It also noted that the agency removed approximately 1,200 noncompliant providers from the database in August 2025.
Industry Cites Rising Impersonation Scams
Citing a Bank Policy Institute survey of 14 member banks, the associations said the average number of identified bank-impersonation scams initiated by phone call or text rose 124% from 2024 to 2025. Two banks reported that 40% of calls appearing to come from bank-owned numbers had been spoofed.
The letter also cited an American Bankers Association-commissioned Morning Consult poll in which 82% of respondents supported stronger caller-identity authentication requirements for originating providers, while 81% supported requiring intermediate providers to do more to stop spoofed calls passing through their networks.
The groups said the FCC should make clear that its proposal to expand registration to certain private branch exchanges and call centers does not encompass a company’s own internal phone system or in-house call center.
Other signatories were the American Bankers Association, ACA International, American Financial Services Association, Bank Policy Institute, Consumer Bankers Association, Electronic Transactions Association, Financial Technology Association, Mortgage Bankers Association and Payments Leadership Council.
The comments were filed in FCC proceedings concerning the Robocall Mitigation Database, call authentication and unlawful robocalls.




