On February 16, 2012, the Enforcement Bureau of the Federal Communications Commission (FCC) issued a Public Notice reminding carriers that the deadline for filing annual certificates of compliance with the FCC’s Customer Proprietary Network Information (CPNI) rules is Thursday, March 1, 2012 . The FCC includes the following types of carriers in its non-exhaustive list of entities that must file certificates: telecommunications carriers; interconnected Voice over Internet Protocol (VoIP) providers; commercial mobile radio service (CMRS) providers; interexchange carriers (IXCs); prepaid calling card providers; resellers; and calling card providers.

Certificates must contain an officer’s signature attesting that he or she has personal knowledge that the company has established procedures to protect CPNI and must provide a description of those procedures. Further, the company must describe any actions taken against data brokers in 2011, and any customer complaints received regarding CPNI.

The FCC encourages filers to file their certificates electronically via either the Electronic Comment Filing System (ECFS), identifying EB Docket No. 06-36, or through its new web-based application, which can be found here. Filers may also file certificates in hard copy through the Secretary’s office. More information about the filing can be found in the Public Notice here. (DA-12-170, Enforcement Advisory 2012-01)

For further information, please contact Katherine Barker Marshall or any of our attorneys in the Telecom Group.