Internal Policy Summary
- Applies to: Engineering, NOC, Security, Regulatory
- SLA: ITG requests must be responded to within 24 hours of receipt
- Primary objective: Accurate, compliant, evidence-backed responses aligned with FCC expectations
- Retention: Minimum 5 years for all associated artifacts
Overview
This policy defines the required steps, responsibilities, and data elements for completing Industry Traceback Group (ITG) traceback requests involving calls originating from or transiting Crexendo’s network. The procedure ensures responses are accurate, compliant, and submitted within 24 hours.
Purpose
This policy defines the required steps, responsibilities, and data elements for completing Industry Traceback Group (ITG) traceback requests. The objective is to ensure all responses are accurate, compliant with FCC expectations, and submitted within the required 24-hour window.
Scope
This applies to all engineering, NOC, security, and regulatory personnel responsible for handling inbound traceback requests related to calls originating from or transiting Crexendo’s network.
Definitions
- ITG Traceback: A formal request to identify the source of a suspicious, illegal, or fraudulent call.
- ANI: Billing/Calling telephone number.
- Attestation: STIR/SHAKEN trust level (“A”, “B”, or “C”).
- Originating Provider: The first provider to place the call into the PSTN.
- Intermediate Provider: Any carrier routing the call between the originator and termination point.
Responsibilities
Engineering
- Search for the call within VIP, SBC logs, CDRs, and/or SIP traces.
- Validate whether the ANI belongs to Crexendo or a partner.
- Provide technical confirmation (or confirmation of absence) of call records.
Security / Regulatory
- Complete and submit the ITG traceback form/response.
- Confirm accuracy of all data elements and wording.
- Ensure compliance with the 24-hour response window.
- Maintain a historical log of all submissions.
NOC
- Escalate relevant events to Engineering.
- Assist with gathering traces if required.
Required Data for an ITG Traceback Response
The following information must be gathered before completing any traceback request.
Call Information
- Calling Number (ANI): +E.164 format
- Called Number
- Date & Timestamp (UTC) of the call
- SIP Call-ID (if available)
- Point of Entry: SBC, proxy, or upstream provider
Network & Ownership Validation
- ANI status: Owned by Crexendo / Assigned to customer / Reserved but unused / Not part of our inventory
- Attestation Level: A / B / C (as presented on the call, if available)
- Originating / Ingress IP (as seen on the SBC or core)
- Call presence: Whether the call was actually found in the system
Internal Contact Information (When ANI Is Not Assigned / Not Validated)
If ANI is NOT assigned or cannot be validated, include:
- Internal contact name: Crexendo Engineering
- Email address for follow-up: (use the approved internal distribution/mailbox)
- Reason: “No associated customer record exists for this ANI.”
Policy Requirements
- 24-hour response window: Measured from time of receipt by Crexendo.
- UTC normalization: All timestamps must be expressed in UTC.
- Evidence retention: Maintain artifacts and submission confirmations for 5 years minimum.
- Traceability: All traceback activity must be recorded in the Traceback Log Register.
Compliance Warning
Failure to respond to ITG requests within the required window may result in regulatory exposure and penalties. This SOP is mandatory for all personnel handling traceback requests.
Procedure
Step 1: Validate Receipt and Record Time
- All ITG requests must be responded to within 24 hours.
- Log the request in the Traceback Log Register (date/time, ticket number, requester).
- Record date/time received and assign Engineering and Security/Regulatory owners.
Step 2: Search for the Call
Engineering should perform the following:
- Search SBC CDRs by ANI and timestamp (UTC).
- Search VIP logs for inbound, outbound, or SIPREC activity.
- Review SIP traces if available.
- Confirm if the call exists in any signaling or media logs.
Step 3: Determine Call Ownership
- Check internal number inventory.
- Validate whether the ANI is assigned, owned, reserved, or unassigned.
- Confirm customer identity if assigned.
If ANI is NOT in our system:
- Mark as Not Owned/Not Assigned.
- Prepare internal contact information for submission.
Step 4: Gather Technical Data
Collect the following:
- Ingress IP address
- SIP headers (if found)
- Attestation provided by Crexendo (if any)
- Routing path if applicable
- Any abnormalities (spoofing indicators, missing PASSporT, etc.)
Step 5: Complete the ITG Form
- Populate the traceback form using:
- Verified call details
- Ownership status
- Technical findings
- Internal contact info when necessary
- Ensure wording is factual, concise, and free of assumptions.
Step 6: Submit the Response
- Submit via the official ITG portal or email.
- Copy Security/Regulatory for record-keeping.
- Add submission confirmation to the Traceback Log Register.
Step 7: Retain Documentation
Keep:
- Call search results
- Screenshots or logs
- Final submitted form/response
- ITG confirmation of receipt
Retention minimum: 5 years.
Best Practices
- Always default to conservative assumptions—if the ANI cannot be validated, treat as not assigned.
- Use STIR/SHAKEN records whenever possible to confirm attestation.
- Escalate immediately if multiple traceback requests refer to the same ANI or IP.
- Maintain an updated internal numbering database to reduce search time.
- Continue exploring NSS-based signing to improve attestation accuracy.
Troubleshooting & Common Scenarios
The call cannot be found in SBC/CDRs/VIP logs
- Confirm the timestamp is in UTC and expand the search window if needed.
- Validate ANI formatting is +E.164.
- Document “No matching call records found” and list the systems searched.
- Do not infer origin; respond only with confirmed findings.
ANI is not owned/assigned by Crexendo
- Mark as Not Owned/Not Assigned.
- Provide internal contact: Crexendo Engineering and the approved follow-up email.
- Include reason: “No associated customer record exists for this ANI.”
Multiple ITG requests reference the same ANI or ingress IP
- Escalate immediately to Security/Regulatory.
- Check for patterns (repeated ingress IP, repeated customer association, repeated time blocks).
- Ensure each response references the correct request ID and evidence set.
Attestation (A/B/C) is missing or unclear
- Use available STIR/SHAKEN records and SBC signaling headers when present.
- If not available, mark the field as unavailable and state the limitation factually.
FAQ
What is the required SLA for ITG requests?
All ITG requests must be responded to within 24 hours of receipt.
What timestamp format should we use?
Always normalize and report timestamps in UTC.
How long do we retain traceback artifacts?
Minimum retention is 5 years for all logs, screenshots, submitted responses, and confirmation receipts.
Compliance Statement
Failure to respond to ITG requests within the 24-hour window can result in regulatory penalties. This procedure ensures Crexendo maintains compliance with FCC expectations and demonstrates good-faith participation in traceback efforts.