http://www.mossadams.com/industries/telecom/default.htm

December 5, 2007


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Edited by
Chad Duval, Partner
Moss Adams Stockton
209.955.6124




Moss Adams LLP

You can reach our telecom professionals at these Moss Adams locations:

Spokane

601 W. Riverside Ave.
Spokane, WA 99201
(800) 888-4065
Rick Betts, Partner
Clay Sturgis, Partner

Stockton

3121 W. March Lane
Stockton, CA 95219-2303
(209) 955-6100
Bruce Nakamura, Partner
Chad Duval, Partner


Universal Service Joint Board Issues Recommended Decision

The Federal-State Joint Board on Universal Service has issued a Recommended Decision that outlines some potentially significant changes for the future of universal service.  The Recommended Decision outlines a three pronged approach to high cost support, including a Broadband Fund, a Mobility Fund, and a Provider of Last Resort (POLR) Fund.  While the Recommended Decision does not provide much detail on any of the proposed funds, it does provide a general outline of the principals that would guide each fund.  Following are some of the key components of the Joint Board's proposal:

  • The Joint Board has recommended a cap of $4.5 billion for the entire fund, which is the estimated amount of high cost support for 2007.

    • Broadband Fund set at approximately $300 million
    • Mobility Fund set at approximately $1 billion
    • POLR Fund set at approximately $3.2 billion 
  • Both the Broadband and Mobility Funds would be designed primarily as grants to fund buildouts for unserved and underserved areas, with a limited amount of support allowed for ongoing operating costs. 
  • The Provider of Last Resort Fund is designed to replace the existing High Cost Loop Support, Interstate Common Line Support, and Local Switching Support Funds.
  • The Draft Decision proposes the elimination of the identical support rule. 
  • The Joint Board did not provide algorithms to calculate support for any of the proposed funds. 

While this Recommended Decision signals some potentially significant changes in how universal service funding is calculated and distributed, it is important to understand that it is a very generic proposal. The devil will truly be in the details and significant input from interested parties will be vital in the development of those details. Please click here for a more detailed summary of the Joint Board's Recommended Decision. 

Contact:
Chad Duval  Stockton Office 209-955-6124


Customer Proprietary Network Information (CPNI) Deadline Approaching

The FCC recently issued new rules relating to the use of Customer Proprietary Network Information (CPNI), which are expected to become effective on December 8, 2007.  These rules generally state that, "Telecommunications carriers cannot use, disclose, or permit access to individually-identifiable information obtained from customers without customer consent, unless an exception applies."  These rules require a much greater level of caution in protecting CPNI.  Following is some additional information on CPNI that should help companies better understand the revised requirements:

  • What is CPNI?
    • Call detail information available to the carrier due to customer relationship
    • Information in customer bills on local and toll services
    • Inbound call detail not presented on customer bills
  • What is not CPNI?
    • Directory information
    • Billing telephone number and address
    • Information from public sources
    • Information not obtained from the customer as a result of the carrier relationship

  • What needs to be done to comply with the rules?
    • Identification of a CPNI Compliance Officer
    • Develop a CPNI compliance manual – train and certify employees
    • Establish policies governing customer authentication and disclosure of call detail
    • Develop customer opt-in or opt-out policies for the use of CPNI
    • Password protection and authentication procedures for online access
    • Law enforcement notification procedures for unauthorized disclosure of CPNI
    • Revise CPNI disclosure procedures for marketing purposes
    • Annual certification documentation procedures

Contact:
Lorrie Bernstein Stockton Office 209.955.6103


Industry Calendar

December 28
  • FCC Form 507 2Q (ICLS Line Counts) due to NECA
December 30
  • Quarterly High Cost Loop Support – 3Q due to NECA
December 31
  • FCC Form 509 (ICLS True Up) due to NECA
  • LSS True Up and Certification due to NECA
January 20
  • FCC Form 497 4Q (Lifeline and Linkup Worksheet) due to USAC (due 3rd Monday of January)
January 31
  • Entity Access/Usage Report due to NANPA
February 1
  • FCC Form 502 (Numbering Resource Utilization/Forecast Report) due to NANPA
  • FCC Form 499Q (USF Contribution) for the 4th quarter of 2007 is due to the FCC

Contact:
Lorrie Bernstein Stockton Office 209.955.6103

Remember to check your Red Light status frequently at https://svartifoss2.fcc.gov/redlight/login.cfm. Companies on the Red Light list are not eligible for payments from the federal USF.



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