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January 12, 2007


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Edited by
Chad Duval, Sr. Manager
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
Roger Barker, Partner
Bruce Nakamura, Partner


CALEA Compliance Deadlines Looming

Several very important CALEA compliance deadlines are rapidly approaching over the next 5 months. While having a CALEA Manual on file with the FCC for both voice and broadband/IP networks is important, there are other items that must be resolved in order to be fully CALEA compliant. Some upcoming dates of vital importance include:

    February 12, 2007 – Monitoring Reports (FCC Form 445) are due to the FCC for facilities based broadband Internet access and interconnected VoIP service providers. This form outlines the methods by which carriers will become CALEA compliant by May 14, 2007.
    March 12, 2007 – Security and Integrity Plans (105 Statements) due to the FCC for all facilities based broadband Internet access and interconnected VoIP service providers. This plan must outline policies and procedures for employee supervision and control, and maintaining secure and accurate records related to the interception of communications or access to call-identifying information under CALEA. This is in addition to your existing CALEA manual for voice services, and there is some question as to whether it should be a separate manual.
    May 14, 2007 – Deadline for hardware and software implementation for all facilities based broadband Internet access and interconnected VoIP providers to comply with CALEA requirements. In addition to hardware and software implementation, it is also important to ensure that this hardware and software be tested to ensure compliance.
There are a couple of options available to carriers to ensure CALEA compliance, including performing all of the functions internally or using a "Trusted Third Party", where the carriers outsource CALEA requirements to an outside vendor. We are currently aware of four (4) Trusted Third Party vendors: Neustar, Subsentio, Verint, and Verisign, but there may be others. NECA is sponsoring a CALEA compliance webinar on Tuesday, January 16th, that will feature representatives of Subsentio and Verint, and other webinars are in the works.

We encourage all companies that do not have the above deadlines covered to get as much information as possible and ensure that these deadlines are met. If you would like assistance with these CALEA compliance issues, contact Lorrie Bernstein. CALEA imposes significant fines (up to $10,000 per day per request) for carriers that are not able to meet the requests of law enforcement agencies within 10 days of the request.

Contact: Lorrie Bernstein Stockton Office 209.955.6103



Industry News

  • Remember to check your Red Light status frequently. Companies on the Red Light list are not eligible for payments from the federal government, including federal USF.


Industry Calendar

January 22

  • FCC Form 497 4Q (Lifeline and Linkup Worksheet) due to USAC
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 4th quarter of 2006 is due to FCC
March 1
  • FCC Form 477 (Local Competition and Broadband Reporting Form) due to FCC
Contact: Lorrie Bernstein Stockton Office 209.955.6103



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