Compliance with a carrier's CPNI certification obligations has provided steady fodder for this blog, with the annual Omnibus CPNI fines, unusual settlements and consistent enforcement focus from the FCC's enforcement bureau. With the start of a new year, the CPNI season begins anew. Yeasterday, the FCC unofficially kicked off the 2012 CPNI certification season with an Enforcement Advisory stressing the requirements of the FCC's CPNI rules.
The Enforcement Advisory (which is itself almost becoming an annual ritual with the FCC) reminds carriers of the annual March 1 CPNI certification filing deadline, identifies common certification errors and highlights the monetary penalties associated with certification errors and failures to file. The Commission’s issuance of this CPNI Advisory is an indication that the FCC considers the submission of the CPNI certifications to be a high priority., and that its past history of enforcement will not change in the near term Telecommunications carriers and interconnected VoIP providers should review the advisory carefully to ensure that they are in compliance with the certification obligations of the rules.