Thursday, February 26, 2009

CPNI Paperwork Due March 1

Are you CPNI Compliant?

Have you filed your CPNI paperwork with the FCC? It's due on Sunday, March 1.

The FCC this week fined about 20 companies between $1000-$4000 for being non-compliant with CPNI paperwork and certification. For example:

EGIX, INC. Notified of its Apparent Liability for Forfeiture in the amount of $2,000 against EGIX, Inc. for filing a non-compliant CPNI certification with the Commission. Action by: Chief, Enforcement Bureau. Adopted: 02/24/2009 by NALF. (DA No. 09-372). EB [FCC Daily]

This from WISPA's president Rick:

The following document was released by the FCC on the matter of Annual CPNI Certifications which were not filed in 2008. This filing is required for all telecommunication providers carrying voice, VoIP and paging services on their networks. There is an estimated 600 companies who were penalized $20,000 for not filing for their CPNI Certification in 2008. The full release including the penalized companies can be found at [PDF version]

If you sell VoIP services, you DO need to file for this CPNI Certification by March 1st, 2009 to avoid future penalties next year. Here is an excerpt of who is required to file:

The term “telecommunications carrier” is defined in the Act to mean “any provider of telecommunications services, except that such term does not include aggregators of telecommunications services (as defined in section 226)[1]…”47 U.S.C § 153(44). Telecommunications service is defined in the Act as “the offering of telecommunications for a fee directly to the public, or to such classes of users as to be effectively available directly to the public, regardless of the facilities used.” 47 U.S.C. § 153(46). · Companies that fall under the definition and must file an annual certification include, but are not limited to: LECs (including ILECs, rural LECs and CLECs), IXCs, paging providers, CMRS providers, resellers, prepaid telecommunications providers, and calling card providers. This list is not exhaustive. · Interconnected VoIP providers provide a service that: “(1) enables real-time, two-way voice communications; (2) requires a broadband connection from the user’s location; (3) requires Internet protocol-compatible customer premises equipment (CPE); and (4) permits users generally to receive calls that originate on the public switched telephone network and terminate calls to the public switched network.” 47 C.F.R. § 9.3

The public release reminder that you can search for is EB Docket No. 06-36 with the title, "Enforcement Bureau Reminds Carriers of March 1 Deadline and Provides Further Guidance on Filing of Annual Customer Proprietary Network Information (CPNI) Certifications Under 47 C.F.R. §64.2009(e)"

The Commission’s rules do not require a certain form or format to be used by companies subject to the rule in filing their annual CPNI certification. For convenience and to assist companies in meeting the requirements of the rule, the Bureau provides the attached suggested template that filing entities can use to meet the annual certification filing requirement of 47 C.F.R. § 64.2009(e). [from the PDF] The one page template form to submit is on page 5 of that PDF.

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