Annual CPNI Certificates Due March 1, 2016
The Federal Communications Commission (FCC) issued a Public Notice on February 5, 2016, reminding telecommunications companies that the deadline for filing annual certificates of compliance with the Customer Proprietary Network Information (CPNI) rules is Tuesday, March 1, 2016. The FCC includes the following types of providers in its non-exhaustive list of filers: telecommunications carriers, interconnected Voice over Internet Protocol (VoIP) providers, commercial mobile radio providers (CMRS), interexchange carriers, 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, as well as a description of those procedures. Further, the company must describe any actions taken against data brokers in 2015, as well as any customer complaints received regarding CPNI.
The FCC encourages companies to file their certificates electronically, either through the Electronic Comment Filing System (ECFS) in EB Docket No. 06-36, or through the web-based application which can be found here. Companies may also file their certificates in hard copy with the Office of the Secretary. More information about the filing can be found in the Public Notice, here. (DA 16-127, Enforcement Advisory No. 2016-01)
If you have any questions about this matter, please contact Katherine Barker Marshall, or the Arent Fox professional who handles your matters.