Comment Letter

This comment builds upon an earlier bipartisan comment to the FCC, also co-led by Attorney General Davenport, on similar “Know Your Customer” (KYC) rules. Both sets of rules require phone companies to know who they are accepting call traffic from and what kinds of business these callers are conducting. With that information, phone companies can suspend or terminate callers or upstream providers who use their networks to make unlawful calls, or decline to do business in the first place with companies that don’t meet minimum standards of credibility before any harmful scam robocalls are even sent.

“New Jerseyans are fed up with a constant barrage of unwanted robocalls,” said Attorney General Davenport. “These proposed rules give companies more incentive to do their due diligence before allowing junk calls to reach our phones. The FCC should finalize and implement these rules immediately to give states more tools to hold companies that shirk their duties accountable.”

Phone calls sometimes get routed through a series of phone companies before they reach your phone. Even though providers are already required to know who their caller and upstream phone company customers are, the current requirements aren’t strong enough — as evidenced by the prevalence of robocall scams. Last year, Americans received more than 29.6 billion scam robocalls and texts and lost nearly $2 billion to such scams.

If scammers can’t get their calls onto the U.S. communications network, illegal robocalls won’t ever reach U.S. consumers’ phones. Similarly, every voice service provider in the path between the caller and the consumer represents an opportunity to halt harmful traffic before a consumer’s phone ever rings with an unwanted or illegal call. The attorneys general are therefore asking the FCC to strengthen voice service providers’ obligation to vet their upstream provider customers, and to require the same scrutiny and diligence of the entities involved as used in the “STIR/SHAKEN” framework developed to prevent caller ID spoofing.

In addition to what the FCC is already doing, recommendations from the coalition of attorneys general across the two comments included:

·    Requiring providers to better understand their customers’ business, so that upstream provider monitoring can more regularly to help prevent bad actors from operating unchecked.

·    Imposing additional requirements on custodians of the STIR/SHAKEN framework to require revocation of a noncompliant company’s ability to participate in STIR/SHAKEN, and to establish a strong conflict of interest policy.

·    Holding all originating providers to KYC standards, so that scammers cannot use smaller voice service providers to facilitate illegal calls are often facilitated by smaller voice service providers.

·    Requiring originating providers to collect additional information on high-risk customers more likely to make illegal robocalls, such as those subscribing to high-volume services.

These two letters come after a coalition of 49 attorneys general sent reply comments to the FCC earlier in July, encouraging it to crackdown on illegal robocalls by strengthening rules that would cut off scammers’ access to legitimate phone numbers.

Attorney General Davenport is part of the Anti-Robocall Multistate Litigation Task Force, which launched Operation Robocall Roundup in 2025.

In phase 1 of the operation, the task force sent warning letters to 37 smaller voice providers that were disregarding their obligations to mitigate the origination and transmission of illegal and/or suspicious robocalls by failing to comply with certain baseline mandates from the FCC. Just two weeks ago, the FCC issued an order to six of those companies, ordering them to fix their robocall protection issues or risk losing the ability to route any calls across the U.S. telephone network.

In phase 2, the task force:

·    Expanded its crackdown to four of the country’s largest intermediate voice service providers.

·    Pushed the FCC to strengthen its Know Your Customer rules to require phone companies to verify who is making calls using their networks and what kinds of business their customers are conducting.

Attorney General Davenport is joined in signing this letter by the attorneys general of Alabama, Alaska, American Samoa, Arizona, Arkansas, California, Colorado, Connecticut, Delaware, District of Columbia, Georgia, Hawaii, Idaho, Illinois, Indiana, Iowa, Kansas, Kentucky, Louisiana, Maine, Maryland, Massachusetts, Michigan, Minnesota, Mississippi, Missouri, Nebraska, Nevada, New Hampshire, New Mexico, New York, North Carolina, North Dakota, Ohio, Oklahoma, Oregon, Pennsylvania, Rhode Island, South Carolina, South Dakota, Tennessee, Utah, Vermont, Virginia, Washington, West Virginia, Wisconsin, and Wyoming.