CPNI Certifications Due March 1

On February 1, 2023, the Enforcement Bureau released an Enforcement Advisory reminding telecommunications carriers and interconnected Voice over Internet Protocol (“VoIP”) providers of their obligation to file their annual certification documenting compliance with the Customer Proprietary Network Information (“CPNI”) rules on or before March 1, 2023.  The certification must include:

  • A compliance certificate signed by an officer of the company.
  • A statement by the officer in the compliance certificate that he or she has personal knowledge that the company has established operating procedures that are adequate to ensure compliance with the CPNI rules.
  • A written statement accompanying the certification explaining how the company’s operating procedures ensure that it is or is not in compliance with the CPNI rules.
  • An explanation of any actions taken against data brokers.
  • A summary of all consumer complaints received in the prior year concerning unauthorized release of CPNI.

Frequently Asked Questions and responses are reference in Attachment 1 to the above Advisory.  A suggested template that can be used to prepare the filing is included in Attachment 2 to the above Advisory.  CPNI certificates are filed via the Commission’s Electronic Comment Filing System (“ECFS”) in EB Docket No. 06-36.

Failing to timely file the certificate may subject companies to enforcement action, including monetary forfeitures of up to $237,268 for each violation or each day of a continuing violation, up to a maximum of $2,372,677.

Please Contact Us if you have any questions.

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