On November 2, 2016, the FCC issued its 2016 Privacy Order. With limited exceptions, the provisions adopted by the FCC in the 2016 Privacy Order will become effective on January 3, 2017. As part of these provisions, the Order relieved telecommunications carriers and interconnected VoIP providers of their Customer Proprietary Network Information (“CPNI”) recordkeeping and certification requirements provided in Section 64.2009(c) and (e) of the Commission’s rules.
Accordingly, once the Order becomes effective on January 3, 2017, telecommunications carriers and interconnected VoIP providers will no longer need to maintain CPNI records or submit their annual CPNI certifications with the FCC.
Should you have any additional questions regarding this change in Commission rules and requirements, please contact Alan Tilles or Georgina Feigen.
Alan S. Tilles
301-231-0930
Georgina L.O. Feigen
301-945-9292
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