Friday, February 26, 2010

CPNI Due March 1

The Filing of Annual Customer Proprietary Network Information (CPNI) Certifications to the FCC is due on March 1st. Being late is expensive:

ANNUAL CPNI CERTIFICATION OMNIBUS NOTICE OF APPARENT LIABILITY FOR FORFEITURE. Notified companies listed in Appendix I of an Apparent Liability for Forfeiture in the amount of $25,000 for failure to submit an annual customer proprietary network information (CPNI) compliance certificate. [see notice here]

"Telecommunications carriers and interconnected VoIP providers must file annual reports certifying their compliance with the Commission's rules protecting Customer Proprietary Network Information (CPNI). CPNI includes some of the most sensitive personal information that carriers have about their customers as a result of their business relationship (e.g., phone numbers called; the frequency, duration, and timing of such calls; and any services purchased by the consumer, such as call waiting). In prior years, many companies have failed to file, or have filed certificates that failed to comply with our rules in material respects. Failure to file a timely and complete certification calls into question whether a company has properly complied with the rules requiring it to protect its customers' sensitive information. As a result, the Commission has initiated enforcement action against a large number of non-compliant companies to ensure adequate consumer protection and future compliance with these important regulatory requirements."

Also, if you provide voice and if you want E-Rate money, you have to file form 499Q and 499A - Q is quarterly, A is annual.

"All intrastate, interstate and international providers of telecommunications within the United States, with very limited exceptions, must file the FCC Form 499-A Telecommunications Reporting Worksheet." [Who Must File]

When to File? USAC Schedule says April 1 for the Annual, Feb. 1, May 1, August 1 and November 1 for the quarterly form.

Why Must You File? This from the Law Offices of T.K. Crowe: "Virtually all telecommunications providers, including long distance resellers, prepaid card providers, wireless providers, Mobile Virtual Network Operators (MVNOs), and now interconnected VoIP providers, seeking to provide service in the U.S. must first register to do so with the FCC. Registration is accomplished by filing with the Universal Service Administrative Company (USAC) a signed copy of selected portions of the FCC Form 499-A. The FCC Form 499-A Registration is particularly important. One reason is that it automatically ties a provider into the FCC's Universal Service Fund (USF) contribution system, identifying a company as a payer under the program. Another is that registering companies are added to the FCC's online, searchable database of registered companies. Under the FCC's rules, underlying facilities-based carriers are only allowed to contract with providers on the FCC registration list. Thus, failing to register could prevent a provider from being able to enter agreements with underlying facilities-based carriers."

I've written about this before, but a reminder is needed, since someone filed late. Maybe Jerry stopped reading my blog!

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