ABA Comment re: Robocall Mitigation Database

Dear Ms. Dortch,

The American Bankers Association (ABA) appreciates the opportunity to comment on the Notice of Proposed Rulemaking (Proposal) in the above-captioned proceeding.

Under the Federal Communications Commission's (Commission) existing rules, all providers carrying or processing voice traffic are required to file certifications to the Commission's Robocall Mitigation Database (Database) concerning the provider's implementation of the Commission's call authentication framework and the provider's plans to mitigate the transmission of illegal automated calls over its network. In the Proposal, the Commission seeks comment on measures to improve the quality and accuracy of submissions made to the Database. As the Proposal states, the Database is relied upon by the Commission for its enforcement activities, by other federal and state enforcement bodies, and by downstream providers, who are prohibited from accepting a provider's call traffic if the provider is not listed in the Database.

ABA supports the Commission's efforts to enhance the Database's effectiveness as a tool to combat illegal automated calls. We firmly believe that we need a "whole of government" approach to combatting fraud, including fraud perpetrated by criminals who use illegal calls and text messages. Strengthening the Robocall Mitigation Database so that it contains fulsome and accurate filings by providers and greater functionality for those who wish to search the Database is an important part of our government's overall strategy to combat fraud perpetrated through illegal phone calls.

We look forward to continuing to work with the Commission to protect Americans from fraud.

Sincerely,

Jonathan Thessin
Vice President/Senior Counsel
Consumer & Regulatory Compliance
Regulatory Compliance and Policy