There are two upcoming regulatory compliance deadlines that certain WISPA members should be sure to meet. April 1 -- Providers of interconnected voice over Internet protocol (VoIP) service must file the annual FCC Form 499A by April 1. FCC rules require many telecommunications carriers and interconnected VoIP providers to contribute to the costs of universal service, local number portability, numbering administration and the Telecommunications Relay Services Fund, and contributions are assessed based in part on information about interstate revenues provided by the carrier or provider on FCC Form 499A (annually) and FCC Form 499Q (quarterly). The requirement to file Form 499A applies even if the VoIP provider does not need to contribute to the universal service fund. For interconnected VoIP providers, if the company's contribution for a given year would be less than $10,000, the company does not need to file FCC Form 499Q quarterly, but the Form 499A requirements still apply. The FCC defines "interconnected VoIP" as a service that: "(1) Enables real-time, two-way voice communications; (2) Requires a broadband connection from the user's location; (3) Requires Internet protocol-compatible customer premises equipment (CPE); and (4) Permits users generally to receive calls that originate on the public switched telephone network and to terminate calls to the public switched telephone network." May 1 -- By May 1, any company that provides service in advance of payment (a "creditor") must implement a written customer protection program to identify and detect identity theft. This program must be designed to detect a "Red Flag," which is a pattern, practice or specific activity that indicates the possible existence of identity theft. The FTC has identified five categories of Red Flags and provided a list of examples of the types of Red Flags that fall under each category. If you are providing interconnected voice or VoIP services, the Red Flag compliance program can be combined with your CPNI program required by the FCC's rules. The customer protection program must include policies and procedures for: (a) detecting warning signs or "Red Flags" of identify theft; (b) responding to any such Red Flags in a manner that will prevent or mitigate the identify theft; and (c) updating the Program. The customer protection program must be managed by the Board of Directors or senior employees of the company if there is no Board. Also, the customer protection program must provide for staff training and oversight of your company's service providers. As a service to WISPA members, Rini Coran can assist your company in filing Form 499A for a flat fee of $250. Likewise, we can provide you with Red Flag Guidelines for a flat fee of $250. If you are interested in either or both, please contact Steve Coran at 202.463.4310 or [email protected] <blocked::mailto:[email protected]> . Thank you. Stephen E. Coran Rini Coran, PC 1615 L Street, N.W., Suite 1325 Washington, D.C. 20036 202.463.4310 - voice 202.669.3288 - cell 202.296.2014 - fax [email protected] <mailto:[email protected]> - e-mail www.rinicoran.com <http://www.rinicoran.com/> www.telecommunicationslaw.com <http://www.telecommunicationslaw.com/>
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