The Industry Traceback Group (ITG), designated by the Federal Communications Commission (FCC) as the official U.S. Traceback Consortium, relies on the cooperation and collaboration of hundreds of domestic and foreign voice service providers in traceback requests. The ITG operates pursuant to established Policies and Procedures.
Cooperating with Traceback Requests
In late 2020, the FCC formally endorsed a mandatory traceback requirement, stating in December that all “voice service providers are now legally required to respond to traceback requests” from the ITG. The FCC also has indicated 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 federal TRACED Act.
Using a secure traceback portal developed by the ITG, suspected illegal robocalls are traced systematically back through various networks until the ITG identifies the originator of the suspicious calls, where the calls entered the United States if internationally originated, and often the identity of the calling party. The ITG traces the call back from the recipient to the caller – usually routing through 4 or more, or sometimes as many as 9 or 10 service providers (or “hops”) across the globe. As a call is being traced, the ITG’s semi-automated system contacts each services provider in the path of the call.
Providers do not need to proactively register with the ITG to cooperate with traceback requests and thus meet their legal obligation. Rather, providers simply need to cooperate with traceback requests they receive from the ITG, which they only will receive when a suspected illegal robocall transits that provider’s network. If the provider has not previously received a traceback request, the ITG will rely on contact information provided from the provider’s downstream partner to send the traceback request, after which the provider can register additional emails to receive the requests.
With the support of service providers, in 2020 the ITG improved the traceback process:
- Average time to complete a traceback fell by over 50% in 2020 to approx. 4 days
- Average time to complete an individual hop is now less than a day
- Many providers regularly respond in less than 30 minutes
The ITG operates under the auspices of the Communications Act which permit providers to disclose and/or permit access to call detail records and other customer proprietary network information certain circumstances. Most notably, section 222(d)(2) of the Communications Act permits providers to share such information in order to protect the rights or property of the provider, or to protect users of telecommunications services and other providers from fraudulent, abusive, or unlawful use of, or subscription to, those services. The FCC has made clear that sharing information as part of traceback requests do not violate the privacy obligations under the Communications Act and the agency’s rules.
Every Provider Has a Responsibility to Help Stop Illegal Robocalls
Traceback is just one mechanism to stop illegal robocalls. Indeed, merely responding to tracebacks, without taking reasonable steps to eliminate the origination of illegal calls after notification of such calls, is not sufficient to avoid being labeled a non-cooperative voice service provider by the ITG. Nor is merely cooperating with tracebacks consistent with emerging regulatory expectations for voice service providers. Beyond new affirmative robocall mitigation requirements imposed by the FCC, federal and state enforcement authorities increasingly have held voice service providers accountable for illegal robocalling and telemarketing activities enabled through their networks.
Supporting the ITG
The ITG relies on the support and collaboration of over 40 leading companies from across the wireline, wireless, VoIP, and cable industries. If you are interested in supporting the ITG, please review the ITG’s Policies and Procedures for more information and click here to make an inquiry.