JSI Reminds Clients of Expected 24-Hour Traceback Response Interval

Expected 24-hour Traceback Response Interval

Traceback is the process of following the call path of a telephone number back to the point of origin.

Time is of the essence to identify both callers placing illegal calls and the voice service providers that facilitate them. Because rapid traceback is essential, in 2020, the Federal Communications Commission (FCC) adopted rules that required a traceback response from all voice service providers “fully and in a timely manner” and stated they generally expected responses within a few hours, and certainly in less than 24 hours absent extenuating circumstances.

To make sure voice service providers adhere to the 24-hour response expectation, the FCC has modified the traceback rule to now require all voice service providers, regardless of their position in the call path, to fully respond to traceback requests from the FCC, civil and criminal law enforcement, and the industry traceback consortium within 24 hours of receipt of a request. This replaces the existing requirement for voice service providers to respond to traceback requests “fully and in a timely manner.”

The response must include information about the provider from which it directly received the call and patterns of delayed response may lead to FCC enforcement.

Effective January 8, 2024, the 24-hour traceback response is required under the Seventh Report & Order, Advanced Methods to Target and Eliminate Unlawful Robocalls, and Call Authentication Trust Anchor.

Traceback Clock

For some voice service providers, managing requests outside of business hours pose a problem (i.e. small, rural carriers that do not have staff available to monitor and receive traceback requests after hours); therefore, the FCC adopted restrictions on the 24-hour clock:

  • The 24-hour clock does not start outside of business hours, and requests received during that time are deemed received at 8:00 a.m. on the next business day.
  • If the 24-hour response period would end on a non-business day, either a weekend or a federal legal holiday, the 24-hour clock does not run for the weekend or holiday in question, and restarts at 12:01 a.m. on the next business day following when the request would otherwise be due.
    • For example, a request received at 3:00 p.m. on a Friday will be due at 3:00 p.m. on the following Monday, assuming that Monday is not a federal legal holiday.
  • “Business Day” is defined as Monday through Friday, excluding federal legal holidays.
  • “Business Hours” is defined as 8:00 a.m. to 5:30 p.m. on a business day.
  • All times are local time for the office that is required to respond to the request.

Future Traceback Requirement

The Seventh Report & Order will also require a statement of the voice service provider’s commitment to respond within 24 hours to all traceback requests from the FCC, law enforcement, and the industry traceback consortium, and to cooperate with such entities in investigating and stopping any illegal robocallers that use its service to originate calls. The statement likely will be required in voice service providers’ Robocall Mitigation Plans or as part of the STIR SHAKEN certification options voice service providers must select in the Robocall Mitigation Database.

This requirement will become effective following publication of a document in the Federal Register announcing approval of the information collection and the relevant effective date. JSI will notify clients of the effective date and the mandated statement requirements.

Please contact Bridget Alexander White or call 301-459-7590 with any questions.

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