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.
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.
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.
Entity
Federal Communications Commission
Industry
TelecommunicationsOfficial Press Release
https://www.doj.state.or.us/media-home/news-media-releases/ag-rayfield-pushes-fcc-to-close-loopholes-that-flood-u-s-phone-network-w-robocalls/
9 8 LTR to FCC Robocall KYUP
https://www.doj.state.or.us/wp-content/uploads/2026/09/9-8_LTR_to_FCC_Robocall_KYUP.pdf
Oregon Attorney General Enforcement Page
https://www.doj.state.or.us/consumer-protection/
"is calling on the Federal Communications Commission (FCC) to close loopholes that let scammers flood the U.S. phone network with illegal robocalls"
"9-8_LTR_to_FCC_Robocall_KYUP.pdf"
"/wp-content/uploads/2026/09/9-8_LTR_to_FCC_Robocall_KYUP.pdf"
"the bipartisan coalition of 48 other attorneys general"
"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"
"sometimes referred to as the "Know Your Upstream Provider," or KYUP, rule"
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.
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.
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.
Attorney General Dan Rayfield and a coalition of 21 attorneys general and Pennsylvania filed lawsuits against the U.S. Department of Transportation, FMCSA, and AAMVA to block demands for a database containing personal information of 17 million commercial drivers. The federal government threatened to withhold $10 million in funding unless the data was turned over, which the coalition argues violates privacy law.
Oregon Attorney General Dan Rayfield co-led a coalition of 10 states in a federal lawsuit against the Office of the Comptroller of the Currency (OCC) to block a rule that invalidates state laws requiring mortgage lenders to pay interest on escrow accounts. The lawsuit argues the OCC's rule oversteps federal authority, gives national banks a competitive advantage over state-chartered banks, and takes money away from homeowners.
A federal judge ruled that Nexstar Media Group violated a court order requiring it to keep TEGNA Inc. operating as an independent company while a multistate antitrust lawsuit challenging the merger proceeds. The court found that Nexstar installed its own executives on TEGNA's board, failed to disclose the appointments, and lacked candor with the court. The court ordered Nexstar to comply immediately, file status reports, respond to discovery, and turn over board and financial documents, with a special master to oversee compliance.