FCC Releases PN on Electronic Filing of SSI Plans and Seeks Comment on Mandating Electronic Filing

On June 1, 2022 the Public Safety and Homeland Security Bureau (“Bureau”) released a Public Notice (“Notice”) providing initial information about the upcoming launch of the Communications Assistance for Law Enforcement Act (“CALEA”) Electronic Filing System (“CEFS”) and seeking comment on mandating use of the system six months after its activation.   Section 1.20005 of the Commission’s rules requires all providers subject to CALEA to file their System Security and Integrity Policies and Procedures (“SSI Plans”) prior to commencing service and to re-file a complete updated SSI Plan within 90 days following any changes to information contained in a previously-filed SSI Plan.  CEFS will allow these providers to file their SSI Plans confidentially and securely online, eliminating the need for paper filings.

Once activated, at least initially, providers may voluntarily, but are not required, use CEFS to file their SSI Plans.  Providers will be able to access CEFS using their CORES username and password.  Electronically filed SSI Plans must be in the same format as traditionally has been used for paper SSI Plan filings, and the uploaded SSI Plan must contain all information listed under sections 1.20003 and 1.20004 of the Commission’s rules.  Users that electronically file their SSI Plan will be able view their prior electronic SSI Plan filings in CEFS, allowing entities to refer back to prior filings to ensure they are updating and keeping their SSI Plans current when required.

The Bureau will release a Public Notice later this year announcing the date that covered entities may begin filing their SSI Plan electronically via CEFS.  Until then, members of the public with FCC Registration Numbers (“FRNs”) and FCC User Registrations may log in and view the CEFS filing screen for informational purposes, but electronic filing of SSI Plans in CEFS will not be enabled.  During the comment period, filers can access CEFS here: https://www.fcc.gov/cefs.  Further information about the CEFS system use and functions are available on the CALEA website at: https://www.fcc.gov/public-safety-and-homeland-security/policy-and-licensing-division/general/communications-assistance, including the CEFS User Manual.

The Bureau also seeks comment mandating electronic filing of SSI Plans via CEFS six months after CEFS is activated.  During the six month period, the Bureau will continue to accept paper filings, until it releases a notice announcing a mandatory CEFS filing date.

Comments will be Due: 30 Days after publication in the Federal Register

Reply Comments will be Due: 45 Days after publication in the Federal Register

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