As of COB yesterday, 3070 unique CPNI submissions were made in the FCC’s annual CPNI certification docket. That number is almost the same as the 3,107 CPNI filers in 2009. However, it still is about 500 fewer than the number of active USF filers, according to USAC’s most recent report, and is over 3,000 entities fewer than USAC has in its filer database. It looks like the FCC’s Enforcement Bureau will still have some work to do to track down potential CPNI violators.
For those who failed to file the certificiations, be warned that last year, the FCC released an Omnibus CPNI NAL proposing to fine over 600 carriers $20,000 each for failing to file the required annual certification or for filing a non-compliant certification. This year, the fine has increased to $25,000, at least according to two NALs released late last week (available here and here). No, this is not an inflationary increase. Instead, the Bureau reasoned that carriers were on notice of the requirement and had failed to file in past years as well. Therefore, the action this year was more culpable and deserving of a higher fine.
If you didn’t file your 2010 CPNI certification, you should do so soon.