CPNI Officer Compliance Certificate Due On or Before March 1 

All interconnected VoIP and voice telephony providers must file their annual CPNI Officer’s Compliance certificate on or before March 1, 2012.  

FCC rules require an annual compliance certificate, signed by a corporate officer, stating with personal knowledge that the provider has established and followed operating procedures adequate to ensure compliance with the FCC’s CPNI rules.  The filing must include a statement explaining how the operating procedures ensure compliance with the FCC’s CPNI rules.  

The provider must also include, if applicable, an explanation of any actions taken against data brokers and a summary of all customer complaints concerning any unauthorized release of CPNI received in the past year.  The certificate, as well as the information noted above, must be filed in EB Docket No. 06-36, or through the FCC’s CPNI Certification Template (http://apps.fcc.gov/eb/CPNI/).   

Failure to submit an annual CPNI certification may lead to FCC enforcement action.  In past years, the FCC has issued Notices of Apparent Liability proposing fines of up to $20,000 against companies that failed to comply with the certification requirement, late-filed certifications, or incorrectly filed certifications.  

Universal Service Annual Reports (499A) Due April 2

All VoIP and voice telephony providers must file their USF annual reports (Form 499A) on or before April 1, 2012.   This includes any entity that relies on the de minimus exception for contributions to universal service. 

Form 499-A calculates the support contributions an entity must pay into the federal universal service, Telecommunications Relay Service, North America Numbering Plan, and Local Number Portability Administration funds.  It is required of all entities providing voice service including those that rely on the de minimus exemption.

VoIP providers must complete the Form 499-A worksheet (available here) using revenue data from the 2011 calendar year.

If you have any questions regarding these filings, please contact James Moskowitz at (202) 872-6881 or jmoskowitz@cm-chi.com, or Bruce Beard at (314) 394-1535 or bbeard@cm-chi.com.