On December
6, 2007, the FCC announced that its amended Customer Proprietary Network Information (“CPNI”) rules received OMB
approval and became effective December 8, 2007. The amendments generally tighten
CPNI regulations applicable to telecommunications carriers and VoIP providers. For
a summary of these rules, please visit http://www.tkcrowe.com/new_fcc_cpni_rules.html.
Since
the new rules are in effect, companies that have not updated their CPNI compliance policies are subject to FCC enforcement
actions and risk being assessed fines and penalties. These companies
should comply with the new regulations as soon as possible in order to minimize these risks.
Such
companies should first update their current CPNI policies to incorporate the new FCC requirements including, among other things,
stricter (a) authorization procedures, (b) marketing restrictions, and (c) procedures for responding to CPNI security breaches. In addition, such companies should generate a CPNI statement detailing the company’s
specific CPNI compliance policies.
The
FCC requires a company officer to certify that the provider is in compliance with FCC CPNI regulations. This certification must be filed with the FCC by March 1, 2008.
If your
company has not already revised its CPNI policies to conform to the new FCC regulations, it should do so as soon as possible. Please let us know if you would like assistance in updating your company’s
CPNI policies.
(December
2007)
