Hey VoIP providers (and the few remaining POTS providers too):

Annual CPNI filings are due on Tuesday, March 1st, but I suggest getting it
done at least by the week prior because ECFS is really slow (or even
crashes) on the deadline day. This filing is mandatory for all retail VoIP
providers. Yes, regardless of what your upstream or wholesale provider
tells you (or doesn’t tell you), all companies selling VoIP to end users
must complete this filing (and you should be ready to file a 499-A by April
1st). Failure to do so could result in a $25,000 fine from the FCC or at
least a nasty letter in a manila envelope threatening a fine from the
Enforcement Bureau. They take this filing very seriously, at least they
used to anyway. Here’s the notice from the FCC Wireline Competition Bureau:

I file dozens of these every year for my clients to make sure it gets done
properly. If you'd like me to file this for you, please let me know and
I'll forward this year's revised template for signature. The flat fee is
$250 for FISPA or WISPA members, $350 for non-members. Or do it yourself,
whatever, just get it done.

For those new to CPNI (defined as name, address, telephone number, call
detail records, and services provided), this filing is important as it
confirms with the FCC that you have not been hacked or been running around
selling CPNI to telemarketers. Keep in mind that there are two additional
pieces for CPNI compliance required.  VoIP providers need a CPNI employee
handbook and to have completed employee training. In fact, in the
compliance statement you'll need to certify (under penalty of perjury) that
the company has completed both of these steps. I can help with those pieces
if needed as well. If your company is not in compliance with all the myriad
federal and state VoIP regulations and you need some help, I have a flat
fee for that too. More info can be found on all that on the Resources page
of my website, www.lokt.net. For those that recently purchased the VoIP
compliance flat fee, this CPNI filing is included and I’ll be sending the
templates out later this week.

You can stop reading here unless you are wondering why you didn’t have to
file last year, or are a bit of closet regulatory nerd. Here’s what
happened. The previous FCC issued new privacy guidelines in 2016 just as
they were heading out the door after the election. Although those privacy
rules expanded FCC privacy authority over broadband, the rules also
eliminated the CPNI annual filing requirement. In January 2017, Congress
used the Congressional Review Act to kill the privacy guidelines. That
effectively reinstated the old rules requiring annual CPNI compliance
filings going forward, beginning this year. Yes, I am proud of myself for
getting through this paragraph without making one snarky political comment.

Feel free to reply to this email on-list if you have any general questions,
or off-list for something company-specific to k...@lokt.net.


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Law Office of Kristopher E. Twomey, P.C.

202 681-1850

Counsel to the Competition®


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