Telephone and Texting Compliance — Industry Traceback Group Makes Case to Remain Registered Consortium

Mintz - Technology, Communications & Media Viewpoints

On May 23, 2025, USTelecom, the leader of the Industry Traceback Group (ITG), submitted a letter presenting its case for continued designation as the registered traceback consortium (“Registered Consortium”) — the entity (or group of entities) responsible for privately led robocall traceback efforts. The letter was sent in response to a public notice soliciting letters of intent from entities seeking to be designated as the Registered Consortium that was issued by the FCC’s Enforcement Bureau (“Bureau”). Letters of intent were due by May 23, 2025, and no other entities submitted letters seeking to become the Registered Consortium. As the incumbent, USTelecom was not required to submit a letter, but chose to do so nonetheless.

USTelecom’s letter offered two justifications for its continued designation. First, it explained that the ITG has evolved its traceback approach to address the changing tactics of robocallers. For example, USTelecom noted that the ITG helped identify and disrupt the use of SIMboxes in robocalling campaigns — a new tactic used by scam callers to hide their identities. It also pointed out that it led a successful pilot program in conjunction with several financial institutions to trace the sources of spoofed calls falsely indicating they originated from banks. Second, USTelecom argued that the ITG continues to meet the statutory requirements to be the Registered Consortium: (i) neutrality, which it argued the ITG ensures by continuing to be a multi-member group; (ii) competent management of tracebacks, which it argued the ITG has demonstrated by leading over 25,000 tracebacks to date; (iii) adherence to best practices, which it argued the ITG does by reviewing and maintaining a set of ITG-developed traceback “Policies and Procedures”; and (iv) focusing on unlawful traffic, which it argued it accomplishes by limiting tracebacks to calls suspected of being illegal, fraudulent, or abusive and vetting all data before issuing a request.

Because no other parties submitted letters of intent, USTelecom will likely be retained as the Registered Consortium. Parties had the opportunity to submit comments and reply comments in response to USTelecom’s letter by June 11, 2025 and June 18, 2025, but no comments were filed.

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