All telecommunications and interconnected VoIP providers must file an annual Customer Proprietary Network Information (“CPNI”) report for calendar year 2015 by March 1, 2016.  The CPNI reports certify that telecommunications providers are in compliance with the Commission’s CPNI rules.

The FCC’s CPNI rules protect the security of personal data, like phone numbers and call log information, that consumers disclose to their service providers as a result of their business relationships.  The rules require telecommunications providers to establish and maintain systems that protect this CPNI.  The rules also require providers to file an annual certification that documents (1) their compliance with the rules, (2) complaints they received from consumers regarding CPNI, and (3) actions they took against data brokers.  The FCC intends to strictly enforce its CPNI rules, and if a telecommunications provider fails to comply with the rules or the certification requirement, then the Commission may impose a forfeiture of up to $160,000 for each violation, or each day of a continuing violation, up to a maximum fine of $1,575,000.

The Commission has released an Enforcement Advisory, which contains Frequently Asked Questions, a draft CPNI certification template, and the full text of the CPNI rules.  These documents may assist your completion of the CPNI report and may be helpful to review.

You can file your certification online at http://apps.fcc.gov/eb/CPNI.

Please do not hesitate to contact us with any questions.