REMINDER – Telecommunications carriers and interconnected Voice over Internet Protocol (“VoIP”) providers must file an annual Customer Proprietary Network Information (“CPNI”) certification with the FCC no later than March 1, 2018. Examples of telecommunications carriers include, but are not limited to, local exchange carriers (“LECs”) (including incumbent LECs, rural LECs, and competitive LECs), interexchange carriers, commercial mobile radio services (“CMRS”) providers, resellers, prepaid telecommunications providers, and calling card providers. There is no filing exemption for small companies.
The 2018 annual CPNI certification attests to calendar year 2017 CPNI compliance. Certifications should be electronically filed using the FCC’s Electronic Comment Filing System (“ECFS”). Filers must reference EB Docket No. 06-36 in the “proceeding” field when filing. Separate certifications must be filed for each affiliate in possession of a unique FCC Form 499 Filer ID. Failure to timely file the 2018 CPNI certification may result in an FCC enforcement action, including fines of up to $196,387 for each violation or each day of a continuing violation, up to a maximum of $1,963,870.
Because past certifications have contained informational deficiencies, the FCC has released a CPNI Certification Template. The CPNI Public Notice, which includes the CPNI Certification Template, can be accessed at CPNI Public Notice.