Client Alert

Customer Proprietary Network Information Certification Due on or Before March 1, 2008

January 17, 2008

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CPNI Certification Due - Applies to Carriers and VoIP Providers

Each carrier providing telecommunications service and each provider of interconnected VoIP service is required to file an annual CPNI certification with the Federal Communications Commission (“FCC”) on or before March 1, 2008.

The certification must be signed by an officer of the company. In the certification, the officer must state that s/he has personal knowledge that the company has established procedures that are sufficient to comply with the FCC’s CPNI rules. The officer also must include a statement explaining how its operating procedures ensure that the company is in compliance with the FCC's CPNI rules. Under the rules in effect as of December 8, 2007, the carrier also must include a summary of all actions taken against data brokers and a summery of all customer complaints received in the past year pertaining to the unauthorized release of CPNI.

The FCC continues to devote significant resources to enforcing its CPNI rules. Carriers and interconnected VoIP providers must ensure that they are prepared to submit a certification by March 1, 2008. To this end, if your company has not done so to date, it would be prudent to review and update your company’s CPNI policies and procedures and to train employees in the use of CPNI under the new rules.

Please contact us if you have any questions regarding the CPNI certification or any of the CPNI rules, or if you would like any assistance with your company’s FCC filing.

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