After six NALs and an Enforcement Advisory, the FCC is not finished with prepaid calling card marketing practices. On February 7th, the Enforcement Bureau issued a Notice of Apparent Liability against a prepaid card provider for failing to respond to the Bureau’s investigation. This action serves both as a reminder to carriers of the importance of responding fully to FCC investigations and as a warning to prepaid card carriers that, despite the previous actions, the FCC’s investigations are likely to continue. Any provider that receives or has received an inquiry from the FCC Enforcement Bureau should carefully consider its response.
Disclosures
FCC Proposes $5 Million Fines Against Multiple Prepaid Card Providers
By Kelley Drye on
We noted in April 2010 that the FCC was investigating prepaid calling card provider disclosures. We suspected that action was likely when we saw four notices of apparent liability against unidentified companies appear on the FCC’s items on circulation list in late June. Yesterday, it became official: the FCC announced four separate Notices of Apparent Liability against prepaid calling card providers for insufficient disclosures to consumers of its prepaid calling card rates. in each case, the FCC proposes a fine of $5 million for "unjust and unreasonable" practices in violation of Section 201(b) of the Communications Act.
The NALs follow a recent trend of large fines proposed against multiple carriers as a warning to the entire industry. Other prepaid card providers should examine their disclosures carefully to ensure that they clearly and conspicuously disclose all terms and conditions associated with the cards they sell.…
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