Annual FCC CPNI Certification Due by March 1, 2015; Potential Title II Reclassification Could Soon Expand CPNI Obligations to Broadband

This is to remind our clients that, pursuant to 47 U.S.C. § 222(c), the Federal Communications Commission (FCC) requires every telecommunications and interconnected VoIP service provider (including wireless, cable telephony, and even paging and calling card providers) to execute and file an annual officer certification that it is in compliance with the FCC's Customer Proprietary Network Information (CPNI) regulations. The annual certification for calendar year 2014 must be filed with the FCC by March 1, 2015.

The FCC has taken aggressive enforcement actions in this area against thousands of providers for a mere failure to file this annual certification, with penalties of up to $100,000. Moreover, this past September, Verizon agreed to pay $7.4 million to settle an FCC action arising from a failure to send CPNI “opt-out” notices to new customers.

Continue reading here.