# Traceback Response Procedures Guide

## Implementation Handbook for Voice Service Providers

**Prepared by Performance West Inc.**
**Effective Date: 2026**

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## 1. What Is a Traceback Request?

A traceback is the process of identifying the originating source of an illegal robocall by tracing the call path backward through the network — from the terminating carrier, through intermediate/transit providers, back to the originating carrier and ultimately the customer who placed the call.

Traceback requests are issued by:
- **Industry Traceback Group (ITG)** — operated by USTelecom
- **FCC Enforcement Bureau**
- **State attorneys general**
- **Federal and state law enforcement**

**Your obligation:** Respond fully and completely within **24 hours**.

**Regulatory basis:** 47 CFR § 64.6305(d)(2)(iii), (e)(2)(iii), (f)(2)(iii)

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## 2. Implementation Steps

### Step 1: Designate a 24/7 Traceback Contact

You MUST have someone available to respond to traceback requests within 24 hours, including weekends and holidays.

**Recommended structure:**
- **Primary contact:** Your RMD compliance officer or NOC manager
- **Backup contact:** A second person with access to CDR systems
- **Email alias:** Create a dedicated email like traceback@yourcompany.com that forwards to both
- **Phone:** A direct line or on-call number (not a general IVR)

Register your traceback contact with the ITG at https://tracebacks.org

### Step 2: Ensure CDR Access

Your traceback contact must be able to:
- Search Call Detail Records (CDRs) by called number, calling number, and date/time
- Identify which customer or trunk group originated a specific call
- Export relevant CDR data for the requesting party
- Access records going back at least 18 months

**Systems to prepare:**
- CDR database or data warehouse with search capability
- SIP/SS7 log access (if available)
- Customer account lookup by trunk/SIP registration

### Step 3: Create a Traceback Response Template

When you receive a traceback request, respond with:

```
TRACEBACK RESPONSE
Date: [today]
Request Reference: [ITG/FCC reference number]
Responding Provider: [Your company name]
FRN: [Your FRN]
Contact: [Name, email, phone]

CALL DETAILS REQUESTED:
  Called Number: [number from request]
  Calling Number: [number from request]
  Date/Time: [from request]

FINDINGS:
  Call found in our records: YES / NO
  Originating customer/trunk: [customer name or trunk ID]
  Customer account number: [if applicable]
  Upstream source (if transit): [provider name, trunk ID]

  CDR excerpt attached: YES / NO

ACTION TAKEN:
  [e.g., "Customer notified of violation", "Traffic blocked",
   "Account suspended pending investigation", "Referred to upstream provider"]

Signed: [Name, Title]
```

### Step 4: Establish Response SLA

| Timeline | Action |
|---|---|
| **0–1 hour** | Acknowledge receipt of traceback request |
| **1–4 hours** | Search CDRs, identify the source |
| **4–12 hours** | Prepare response with CDR evidence |
| **Within 24 hours** | Send complete response to the requesting party |
| **Immediately** | If the source is a known bad actor, block the traffic |

### Step 5: Take Enforcement Action

After identifying the source:
1. **Notify the customer** that they are the subject of a traceback
2. **Review the customer's account** for patterns of abuse
3. **If abuse is confirmed:** suspend or terminate service per your AUP
4. **If the call was transit traffic:** forward the traceback to your upstream provider
5. **Document everything** — enforcement actions, customer communications, blocking orders

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## 3. Documenting Traceback Procedures in Your RMD Filing

Your RMD certification should include:

> "[Company Name] commits to respond fully and completely to all traceback requests from the Commission, civil and criminal law enforcement, and the industry traceback consortium, and to do so within 24 hours of receipt. [Company Name] cooperates with the Industry Traceback Group operated by USTelecom and provides requested call detail records and tracing information necessary to identify the origin of suspected illegal robocalls."

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## 4. What Happens If You Don't Respond

| Failure | Consequence |
|---|---|
| No response within 24 hours | Reported to FCC as non-responsive provider |
| Pattern of non-response | FCC enforcement action, potential RMD removal |
| RMD removal | Downstream carriers must block your traffic within 30 days |

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## 5. Common Mistakes to Avoid

| Mistake | Consequence |
|---|---|
| No 24/7 contact registered with ITG | Traceback requests go unanswered |
| CDRs not retained long enough | Cannot trace historical calls |
| Responding to ITG but not taking action against the customer | FCC views this as insufficient mitigation |
| No traceback language in RMD filing | Filing flagged as deficient |

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*This guide is provided for informational purposes as part of your RMD filing service. It is not legal advice.*

*Performance West Inc. — performancewest.net — 1-888-411-0383*
