This email serves as a reminder that all
telecommunications carriers and interconnected VoIP
providers are required to file an annual Customer
Proprietary Network Information ("CPNI") certification,
including a CPNI compliance statement, with the Federal
Communications Commission ("FCC") by March 1, 2012. It
is particularly important that all providers subject to
the requirement comply by filing the necessary
certification in a timely fashion as the FCC's
Enforcement Bureau has imposed penalties of up to
$25,000 against non-compliant companies.
Accordingly, it is absolutely crucial that all
telecommunications service providers and interconnected
VoIP providers subject to the FCC's CPNI rules submit
this year's required filing by March 1, 2012. Failure
to do so will most likely lead to significant penalties
in the near future.
If your company has entered into a Consent Decree
settlement with the Enforcement Bureau regarding past
CPNI violations, it is also critical that your company
ensure compliance with the conditions of the agreement,
including timely filing of the upcoming CPNI
certification and accompanying statement, and providing
copies to the Enforcement Bureau as required.
Non-compliance could be viewed as violations of the
settlement, exposing the company to further action by
the Enforcement Bureau.
As mentioned above, particular care should be taken to
ensure compliance with the CPNI requirements as the FCC
has demonstrated a repeated willingness to levy
penalties against violators. If your company would like
our assistance with preparing its CPNI compliance
statement, filing the certification due March 1, 2012 or
implementation of other CPNI compliance obligations,
please do not hesitate to contact us.
Cheng Yi Liu, Partner
Law Offices of Thomas K. Crowe, P.C.
1250 24th Street, N.W.
Suite 300
Washington, D.C. 20037
(202) 263-3640 (voice)
(202) 263-3641 (fax)
firm@tkcrowe.com
www.tkcrowe.com
This
Legal Alert is provided for informational purposes only,
and is intended neither to provide nor to substitute for
legal advice. This Legal Alert may be forwarded or
redistributed on the condition that complete attribution
of authorship is included (covering author name(s), firm
name and address and all included contact information).
