On April 2, 2007, the Federal Communications Commission released a Report and Order modifying its customer proprietary network information (“CPNI”) rules. These modified rules are now in effect. One of the rule modifications requires telecommunications carriers and interconnected VoIP providers to file with the Commission on or before March 1 of each year a CPNI certification in which an officer of the filing entity must certify that the entity’s operating procedures ensure compliance with the Commission’s CPNI rules. The certification must be accompanied by a statement explaining how the company’s procedures ensure compliance with the Commission’s CPNI rules. On January 29, 2008, the FCC’s Enforcement Bureau released a public notice providing a suggested template and filing procedures for CPNI certifications.
Kelley Drye has prepared a client advisory that provides more detailed information on the suggested filing procedures.