USTelecom leads the efforts of the Industry Traceback Group (ITG), which was designated by the Enforcement Bureau of the Federal Communications Commission (FCC) as the single consortium registered to conduct private-led traceback efforts, in accordance with Section 13 of the Pallone-Thune Telephone Robocall Abuse Criminal Enforcement and Deterrence Act (TRACED Act) and consistent with the registration process established in the FCC’s rules. Below is a list of frequently asked questions regarding USTelecom’s ITG and its designated role as the registered traceback consortium.
What is the USTelecom Industry Traceback Group (ITG)?
The ITG is a collaborative effort of companies across the wireline, wireless, VoIP and cable industries that actively trace and identify the source of illegal robocalls. The ITG coordinates with voice service providers and federal and state law enforcement agencies to identify non-cooperative providers so they can take action, as appropriate, to protect consumers from illegal robocalls. The mission of the ITG is to facilitate a neutral coordination platform for voice service providers to trace and identify the source of illegal robocalls to protect voice networks and consumers from fraudulent, abusive and/or unlawful robocalls. In accordance with Section 13 of the TRACED Act, the ITG was designated by the FCC’s Enforcement Bureau on July 27, 2020 as the single registered consortium to lead and conduct private-led traceback efforts. (See DA 20-785).
Who are the members of USTelecom’s ITG, and can my company participate?
The ITG is a collaborative effort of more than 40 companies from across the wireline, wireless, VoIP, and cable industries that actively trace and identify the source of illegal robocalls. USTelecom manages and oversees the efforts of the ITG. A full listing of ITG members can be accessed here. Any voice service provider is both welcome and encouraged to participate in the ITG traceback process. Membership in, or financial support for the ITG itself, is not a requirement for participation in the traceback process. Thus far, hundreds of voice service providers have participated in ITG tracebacks of suspected illegal robocalls. If you are interested in becoming a member of the ITG, click here. For information on how to respond to tracebacks, become a cooperative voice service provider in the fight against illegal robocalls, and follow industry best practices, you can download the ITG Polices and Procedures here.
What Does the Industry Traceback Group Do?
The ITG facilitates a neutral coordination platform for voice service providers to trace and identify the source of illegal robocalls, in order to provide for the robust protection of voice networks and users of such services from fraudulent, abusive, and/or unlawful robocalls. Traceback is a cooperative effort by voice service providers that starts with a terminating service provider possessing evidence of suspicious traffic. Using a secure traceback portal managed by USTelecom, the call is traced systematically back through various networks until it reaches non-responsive providers or the originator of the suspicious call is identified. You can review our most recent Progress Report which highlights the efforts and activities of the ITG in 2019.
Is USTelecom’s ITG a law enforcement agency?
The ITG is not a law enforcement agency; nor is USTelecom or any ITG member an agent of law enforcement. However, consistent with the TRACED Act and the FCC’s rules, the ITG collaborates extensively with federal and state law enforcement agencies through its private-led efforts to identify call originators and/or non-cooperative providers so they can take enforcement action, as appropriate. These enforcement agencies include, but are not limited to, the Federal Trade Commission (FTC), the U.S. Department of Justice (DOJ), and state attorneys general (“State AGs”). Among the ongoing and federal and state enforcement activities, the FCC, FTC and DOJ are currently engaged in a “coordinated effort” to identify and target voice service providers that are “assisting and facilitating” illegal robocalls. Consistent with the TRACED Act, and in its capacity as the registered traceback consortium, the ITG will continue to assist federal enforcement agencies in these efforts.
Does the FCC permit the sharing of CPNI? What if my contracts prohibit such sharing?
In addition to the TRACED Act and the FCC’s accompanying rules, the ITG also operates under the auspices of Section 222(d)(2) of the Communications Act (which permits telecommunications carriers to disclose and/or permit access to Customer Proprietary Network Information (CPNI) if suspected fraud, abuse, or unlawful use of services exist. The FCC recently clarified that “voice service providers that share certain information to combat robocalls do not violate [CPNI] obligations under the Act and our rules.” (See FCC 20-96, ¶ 22).
The Policies and Procedures governing USTelecom’s ITG include provisions outlining the designation of a voice service provider as a “Non-Cooperative Voice Service Provider.” Such a designation by USTelecom’s ITG could occur if a voice service provider fails to identify the name of an end user customer originating suspicious traffic or to identify an upstream carrier delivering such traffic based on non-disclosure clauses in a contract. When it designated USTelecom’s ITG as the registered consortium, the FCC’s Enforcement Bureau concluded that “contractual provisions that prohibit, delay, or otherwise interfere with a voice service provider’s cooperation with private-led traceback efforts are contrary to the spirit and goals of the TRACED Act.” (See DA 20-785, ¶ 28). The Enforcement Bureau also “encourage[d] voice service providers to review their contracts and eliminate such contract provisions as soon as possible.” (See DA 20-785, ¶ 28).
What is the TRACED Act, and how does it relate to USTelecom’s ITG?
Unlawful prerecorded or artificial voice message calls—robocalls—plague the American public. Such calls are frequently coupled with misleading or inaccurate telephone numbers displayed as caller ID information, an act known as spoofing, and are often intended to facilitate fraudulent or other harmful activities. Federal and state law enforcement agencies have deployed a multi-prong strategy to combat these illegal calls. An important prong of this enforcement strategy is to trace the unlawful robocalls back to their origination, a process known as “traceback.”
Congress recognized the ongoing illegal robocall problem and, in December 2019, enacted the TRACED Act to further aid in these enforcement efforts. In the TRACED Act, Congress acknowledged the beneficial collaboration between law enforcement agencies and the private sector on traceback issues, and required the FCC to issue rules “for the registration of a single consortium that conducts private-led efforts to trace back the origin of suspected unlawful robocalls.” USTelecom was designated by the FCC in July, 2020, as the registered traceback consortium in accordance with the requirements of the TRACED Act.
For more information and to become a member:
Government Support of the Industry Traceback Group
The ITG has received recognition at all levels of government, including the Federal Communications Commission (FCC), the Federal Trade Commission (FTC) and all 50 State Attorneys General.
Federal Trade Commission
An FTC action against an illegal robocall specifically acknowledged the assistance of USTelecom in bringing to justice an individual responsible for generating millions of illegal robocalls and calls to phone numbers listed on the Do Not Call Registry, including calls using “spoofed” caller ID information.
Federal Communications Commission
FCC Chairman Ajit Pai publicly acknowledged that “USTelecom has been particularly helpful in making sure that we can quickly trace scam robocalls to their originating source” and called USTelecom an “important ally in promoting broad industry participation in these traceback efforts.”
In a letter commending the work of the ITG, the Chief of the FCC’s Enforcement Bureau stated that traceback information “has been invaluable in helping Enforcement Bureau staff identify patterns and common sources of harmful traffic.”
State Attorneys General
On August 22, all 50 State Attorneys General and 12 national voice service providers announced their shared commitment to ending illegal robocalls, including a commitment to “allow for timely and comprehensive law enforcement efforts against illegal robocallers, dedicate sufficient resources to provide prompt and complete responses to traceback requests from law enforcement and from USTelecom’s Industry Traceback Group.”