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FIELD NOTES PUBLISHED
PUBLISHED 2026-10-02

Forty-nine attorneys general ask the FCC to make KYUP prescriptive

National Association of Attorneys General  ·  source ↗

NAAG filed comments on 9 September for a bipartisan coalition of 49 state and territory attorneys general, led by Indiana, New Jersey, North Carolina, Ohio and Pennsylvania. The asks: providers collect, verify and regularly review information about their upstream providers and discontinue service to those that do not comply; evaluate them routinely rather than at contract renewal; add safeguards so that “only legitimate providers gain access to the authentication ecosystem”; and implement quickly, with meaningful penalties and retention of KYUP records. The full comments are posted.

The record-retention ask is the one written by people who litigate. The AGs want the vetting file to exist as evidence, so a provider’s own due-diligence record can be pulled into an investigation later.

52 state bankers associations filed on the same side. The usual framing of this docket is consumers against industry, and the banks are industry — they carry the fraud losses that arrive by phone. On the other side: AT&T, CTIA, NCTA and USTelecom, all opposing prescriptive KYUP mandates and asking for safe harbors and flexible industry best practices. TransNexus counted 28% of reply filings supporting the proposed rules and 44% opposed.

The split is not consumers versus industry. It is whoever eats the loss versus whoever carries the compliance cost, and those two groups do not sort by sector.

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