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Oregon AG Rayfield Leads 49-State Coalition Letter Urging FCC to Strengthen Robocall 'Know Your Upstream Provider' Vetting Rules

Federal Communications CommissionSeptember 8, 2026Oregon Attorney General

Summary

Oregon Attorney General Dan Rayfield, leading a bipartisan coalition of 48 other state and territorial attorneys general, sent a letter urging the FCC to strengthen its 'Know Your Upstream Provider' (KYUP) rule so phone companies must properly vet, continuously monitor, and cut ties with upstream providers that facilitate illegal robocalls and caller ID spoofing. The coalition asks the FCC to set minimum vetting standards, require periodic re-checks rather than one-time contract reviews, strengthen caller ID authentication across the call chain, impose meaningful penalties, and mandate record-keeping for investigators. No fine or injunction was imposed; the letter notes Americans received more than 29.6 billion scam robocalls and texts last year and lost nearly $2 billion to these scams.

Remedy

No remedies have been imposed through this action, which is a coalition letter petitioning the FCC for rulemaking. The coalition requests that the FCC: set clear minimum standards for vetting upstream providers (collecting verified information, checking rule compliance, ongoing monitoring, and terminating non-compliant partners); require periodic re-vetting beyond initial signing, renewal, or tip-driven reviews; strengthen and consistently enforce caller ID authentication across every company in the call chain; act quickly and impose meaningful penalties on non-compliant companies; and require companies to retain vetting records for use by law enforcement and attorneys general. The letter builds on the Anti-Robocall Multistate Litigation Task Force's Operation Robocall Roundup, under which warning letters were sent to 37 small phone companies and the FCC recently ordered six of those companies to fix their robocall problems or risk losing the ability to route calls on U.S. networks.

Contract Impact

In-house counsel—particularly at telecom carriers, VoIP providers, contact centers, and any business originating or routing high call volumes through third-party networks—should review carrier, interconnection, and upstream provider agreements for counterparty vetting and due diligence clauses, and confirm that contracts require verified counterparty identity, compliance certifications, ongoing monitoring with periodic re-vetting (not just one-time checks at signing or renewal), and clear suspension/termination rights for partners that facilitate illegal or suspicious traffic. Contracts should also impose record-retention obligations covering vetting decisions and traffic monitoring so records are available to regulators and state attorneys general, and include cooperation clauses for government investigations. Companies that engage telemarketing or robocall vendors should add representations and warranties that all calls comply with FCC KYUP requirements and caller ID authentication standards, backed by audit rights, indemnification for penalties arising from illegal calls, and immediate cure-or-terminate triggers.

Contract Search Terms

Know Your Upstream ProviderKYUPupstream providervendor vettingcaller ID authenticationrobocall compliancecarrier interconnection agreementongoing monitoringtermination for non-compliancerecord retention

Laws Cited

FCC Know Your Upstream Provider (KYUP) rule

Violation Types

Entity Details

Entity

Federal Communications Commission

Industry

Telecommunications

Multistate Coalition

Alabama AGAlaska AGAmerican SamoaArizona AGArkansas AGCalifornia AGColorado AGConnecticut AGDelaware AGDistrict of Columbia AGGeorgia AGHawaii AGIdaho AGIllinois AGIndiana AGIowa AGKansas AGKentucky AGLouisiana AGMaine AGMaryland AGMassachusetts AGMichigan AGMinnesota AGMississippi AGMissouri AGNebraska AGNevada AGNew Hampshire AGNew Jersey AGNew Mexico AGNew York AGNorth Carolina AGNorth Dakota AGOhio AGOklahoma AGPennsylvania AGRhode Island AGSouth Carolina AGSouth Dakota AGTennessee AGUtah AGVermont AGVirginia AGWashington AGWest Virginia AGWisconsin AGWyoming AGAnti-Robocall Multistate Litigation Task Force

Official Sources

Source Evidence

Entity Name
"is calling on the Federal Communications Commission (FCC) to close loopholes that let scammers flood the U.S. phone network with illegal robocalls"
Event Date
"9-8_LTR_to_FCC_Robocall_KYUP.pdf"
Document Urls
"/wp-content/uploads/2026/09/9-8_LTR_to_FCC_Robocall_KYUP.pdf"
Is Multistate
"the bipartisan coalition of 48 other attorneys general"
Co Enforcers
"Attorney General Rayfield is signing this letter along with the attorneys general of Alabama, Alaska, American Samoa, Arizona, Arkansas, California, Colorado, Connecticut, Delaware, District of Columbia, Georgia"
Laws Cited
"sometimes referred to as the "Know Your Upstream Provider," or KYUP, rule"

Related Enforcement Actions

VA

Federal Communications Commission

Virginia Attorney General Jay Jones, joined by a bipartisan coalition of 48 other attorneys general, sent a letter urging the FCC to strengthen its 'Know Your Upstream Provider' (KYUP) rules to keep illegal robocalls off the U.S. phone network. The coalition asks the FCC to mandate baseline vetting measures for upstream providers, add monitoring triggers, strengthen STIR/SHAKEN caller ID authentication, establish base penalties, and require retention of KYUP data. No company was fined in this action; it is regulatory advocacy that builds on the Anti-Robocall Multistate Litigation Task Force's Operation Robocall Roundup, which sent warning letters to 37 voice providers.

OR

Federal Communications Commission

Attorney General Rayfield and a coalition of 49 other attorneys general sent a letter to the FCC urging it to strengthen its Know Your Customer (KYC) rules to combat illegal robocalls. The coalition recommends requiring providers to understand customers' business, applying KYC standards to all providers, and collecting additional information on high-risk customers. No monetary penalty was imposed.

MN

Federal Communications Commission

Attorney General Ellison and 48 other attorneys general called on the FCC to strengthen rules to cut off scammers' access to legitimate telephone numbers. The coalition is responding to the FCC's proposed rules to combat illegal robocalls and texts, which cost Americans nearly $2 billion last year.

CT

Federal Communications Commission

Attorney General William Tong and 48 other attorneys general submitted comments to the FCC urging stronger rules to prevent scammers from accessing legitimate telephone numbers for illegal robocalls. The coalition is responding to the FCC's proposed rules and asks for measures such as stronger certification, reporting, and prohibitions on number cycling.

OR

RealPage, Inc.

An Oregon judge rejected RealPage’s attempt to have the state’s rent-pricing lawsuit dismissed, allowing the case to move forward. Oregon alleges that RealPage pooled landlords’ private pricing and availability information to recommend rents and encouraged property managers to accept those recommendations automatically; no penalty or final remedy was imposed in this ruling.

OR

National Highway Traffic Safety Administration (NHTSA)

Oregon Attorney General Dan Rayfield joined a multistate coalition in filing a lawsuit challenging NHTSA’s rollback of fuel economy standards. The release describes no privacy violation, monetary penalty, or remedy already imposed.