Tomorrow, March 1, 2019, telecommunications carriers and interconnected VOIP providers (“Filers”) will have filed their annual certification confirming they complied with the FCC’s Customer Proprietary Network Information (“CPNI”) rules.
The FCC’s CPNI rules require Filers to establish and maintain systems designed to ensure they adequately protect their subscribers’ CPNI. Consumer data protected by the CPNI rules includes account information, call detail information (including what numbers are called and when), and other sensitive information.
In addition to safeguarding this information, the FCC’s rules also require Filers to submit an annual certification – due March 1st of each year – documenting their compliance with the rules and detailing any complaints they received against data brokers. A template of the CPNI filing is available on the FCC’s website (here).
The CPNI deadline filing kicks off the FCC’s “Spring Filing Season.” On March 8th, facilities-based broadband providers must file data with the Commission on its Form 477 identifying where they offer Internet access service at speeds exceeding 200 kbps in at least one direction, as of December 31, 2018. The filing deadline typically is March 1st, but this was recently extended for an additional week by the Commission.
The Form 477 requires fixed broadband providers to identify the census blocks in which “a provider does, or could, without an extraordinary commitment of resources, provide service.” Mobile broadband providers file maps of their coverage areas for each broadband technology. The Form 477 reporting portal is available here.
On April 1st, the FCC requires service providers and equipment manufacturers that are subject to the Commission’s rules implementing the 21st Century Communications and Video Accessibility Act (“CVAA”) to file annual recordkeeping certifications. This certification confirms that the filer has taken steps to ensure its services and products are accessible by people with disabilities and that it maintains records detailing these accessibility considerations. The Commission’s CVAA filing portal is available here.
Also on April 1st, telecommunications providers and many VoIP providers must file their annual FCC Forms 499-A with USAC, summarizing their 2018 revenues and USF contributions and making adjustments to their 2018 contributions based on the estimates in their 2018 quarterly filings. Some states have established funds for universal service which require contributions based on revenues from certain services and impose reporting obligations.
It can be challenging to track these deadlines and determine which obligations apply to your company or the specific services it offers. Please contact us with questions about these – and other – ongoing compliance requirements.