The Federal Communications Commission should make use of caller ID and require adequate verification of the authenticity of the caller ID information to avoid illegal call spoofing, CUNA and other organizations wrote in comments filed this week with the FCC.

“Banks, credit unions, and other financial services providers – and their customers – are negatively impacted by bad actors that increasingly place calls that impersonate legitimate companies with intent to defraud," the comments read. “These bad actors at times illegally “spoof” phone numbers belonging to our members by causing the call recipient’s caller ID to display the name of a legitimate company instead of the name of the actual caller, who is seeking to defraud the recipient.”

The organizations also urge the FCC to not rely on factors that are common among legal calls and texts, including:

• Large bursts of calls in a short timeframe.
• Low average call duration.
• Low call completion rates.

Those three “may also characterize lawful calls placed by legitimate businesses.”

Instead, the FCC should require analytics include an “indicia of illegality” before blocking a call in order to be considered reasonable. Further, when a call is blocked based on reasonable analytics, the caller should be informed of the indicia of illegality that triggered the block.

The organizations continue to support the use of SIP Code 608 for notification of blocked calls, as well as the use of an enhanced version of SIP Code 603 (603+) after sufficient testing and implementation.

The comments also support the FCC’s efforts to eliminate illegal robocalls and robotexts, including its proposal to require Service Providers to block calls on a “reasonable do not originate” list and to require intermediate providers to block illegal calls when notified by the FCC.

CUNA filed the comments with NAFCU, the American Bankers Association, ACA International, American Financial Services Association, Consumer Bankers Association, Mortgage Bankers Association, and National Council of Higher Education Resources.