The National Association of Attorneys General (NAAG) sent a letter signed by 49 attorneys general in response to a request for comments by the Federal Trade Commission (FTC) on a federal rule to combat impersonation scams. The letter raises concerns about the plethora of impersonation scams targeting consumers and the current lack of a national rule to outlaw these fraudulent acts and protect Americans.

A robust national standard outlawing impersonation scams should:

• Deter bad actors and reduce consumer harm.
• Provide needed clarity on what conduct constitutes impersonation, since government and business impersonation scams can range from overt pretense to misleading subtlety.
• Deprive bad actors of the excuse that they were allegedly not aware their activities were illegal in some jurisdictions as opposed to others.
• Provide more opportunities for the states to collaborate with the FTC on multistate enforcement actions against imposter scammers.
• Allow states to enforce their own standards, free of any preemption by a federal rule.