23 09, 2021

Need Assistance Managing Copyright Infringement Notices?

2021-11-02T13:06:07-04:00September 23, 2021|e-Lerts|

JSI knows some companies no longer manage copyright infringement notifications. Don’t be left without protection. If your current provider is withdrawing support or you have not already protected yourself from this copyright liability, JSI can help. ISPs receiving copyright infringement notices can obtain protection from liability under the Digital Millennium Copyright Act of 1998 (“DMCA”). The DMCA provides safe harbor protection and limits liability in the event of copyright infringement committed by one or more of your subscribers. To realize safe harbor protection, the ISP must:

  1. adopt and reasonably implement a Copyright Infringement Policy to terminate the accounts of repeat infringers; and
  2. register a Designated Agent with the Copyright Office.

JSI provides a subscription service to act as the DMCA Designated Agent. As your DMCA Agent, we manage the copyright infringement piracy notifications you receive because of infringement committed by your subscribers on your network. Copyright trolls can be unduly aggressive in their attempt to enforce copyrights by threatening a lawsuit or forcing a settlement. As your DMCA Agent, JSI will:

  1. conduct enforcement of your copyright policy by sending notifications to subscribers and
  2. manage the caseload.

JSI can also provide language for a Copyright Infringement Enforcement Policy. Under the policy, customers are warned that multiple infringement notices will cause their broadband service to route to a copyright tutorial which JSI can provide upon request.

To learn more about the service, to obtain assistance with registering a DMCA agent, or to obtain the Copyright Tutorial, please email Terri Parrilla in JSI’s Maryland office or call her at 301.459.7590.

20 09, 2021

Restrictions Begin Sept. 28 for Carriers without Robocall Mitigation Certifications

2021-11-02T13:06:16-04:00September 20, 2021|e-Lerts|

Beginning September 28, 2021, voice service providers and intermediate providers are prohibited from accepting traffic directly from any other provider that is not listed in the FCC’s Robocall Mitigation Database (RMD). All voice service providers were required to file certifications in the RMD by June 30, 2021, outlining their efforts to stem the origination of illegal robocalls on their networks (see JSI’s April 23, 2021 e-Lert for more on the RMD).

If your company is not listed in the RMD, connected carriers cannot accept traffic from your company as of September 28. In addition, your company must check the RMD and confirm that all connected carriers have filed their robocall mitigation plans with the FCC. If any have not, your company cannot accept traffic from the offending carrier beginning September 28.

When carriers filed their robocall mitigation program information with the FCC, each certified that they had either completed STIR/SHAKEN implementation, had partially implemented STIR/SHAKEN and are performing robocall mitigation, or that they had not yet implemented STIR/SHAKEN and are performing robocall mitigation.

For more information on the Robocall Mitigation Database, or anything robocall related, please contact Bridget Alexander White in JSI’s Maryland office at 301-459-7590.

Numbering & Porting Essentials Service

Clients interested in educating their staff on the cavalcade of numbering, porting and robocall mitigation requirements all service providers will face in 2022 should consider subscribing to JSI’s Numbering & Porting Essentials service. The subscription includes breaking news alerts, a free webinar and web-based education sessions designed to keep companies informed about important numbering, porting and robocall mitigation decisions that will impact their internal operations and customers. Contact Bridget Alexander White for more details and to sign up.

8 09, 2021

FCC Regulatory Fees Due September 24

2021-11-02T13:06:25-04:00September 8, 2021|e-Lerts|

The FCC announced that FY 2021 regulatory fees must be filed and paid by 11:59 p.m., EDT, on September 24, 2021. Payments received after that time will be assessed a 25% late payment fee, will immediately result in Red Light status and companies could face additional administrative and interest fees as a result of the late payment.

The FCC does not send regulatory fee bills or notices. All companies must begin the payment process by accessing the FCC’s Fee Filer system with their FCC registration number (FRN) and password, or with FCC CORES username and password.  All payments must be made online  by credit card (limited to payments $24,999.99 or less), ACH payment, wire transfer, or debit card. Be sure to arrange well in advance for any ACH or wire transfer payments to ensure the payment is credited by the September 24th deadline. Checks will not be accepted.

Some fee data is pre-populated in the Fee Filer system, but carriers are responsible for payment of all regulatory fees owed, regardless of whether data is displayed in the system. Among the FY 2021 fees are the following:

  • Interstate Telecommunications Service Providers (ITSPs) will be assessed a fee of $.004 per revenue dollar based on the April 1, 2021, Form 499-A.
    • Important Change this Year: NECA will no longer process ITSP regulatory fees on behalf of its members.  You must initiate payment via the Fee Filer system for all ILEC ITSP assessments, as well as for any other assessments that may be due for revenues of a separate entity CLEC, long distance or VoIP interstate ITSP.
  • Cable TV operators (including IPTV) will be assessed a fee of $0.98 per subscriber based on the company’s total basic cable TV subscribers as of December 31, 2020.

The de minimis exemption is $1,000. If the total FY 2021 annual regulatory fee liability for all categories of annual fees due for the same entity is $1,000 or less, that entity is exempt from payment of FY 2021 regulatory fees.

More information on regulatory fees and payment procedures can be found on the FCC’s Regulatory Fees webpage.

If you have any questions, please contact Kim Waldvogel  in JSI’s Maryland office at 301-459-7590.

3 09, 2021

FCC Form 477 Deadline Extended

2021-11-02T13:06:33-04:00September 3, 2021|e-Lerts|

In the aftermath of Hurricane Ida, the FCC announced that the September 1st deadline to submit the FCC Form 477, Local Telephone Competition and Broadband Reporting, filing for data as of June 30, 2021 has been extended to Wednesday, September 15.

For filers affected by Hurricane Ida, specifically in areas of Louisiana and Mississippi where the Federal Emergency Management Agency (FEMA) has designated eligible for Individual or Public Assistance for federal disaster relief as of September 3rd, the FCC announced the new deadline is October 1, 2021. Those entities that operate facilities or rely on personnel, records, or financial institutions essential to their business operations which are located in the FEMA designated parishes of Louisiana or the counties of Mississippi, are eligible for the October 1st deadline.

You must file this report if you provide:

  • Fixed Voice Service – This applies to all ILEC and CLEC local exchange, VoIP, and fixed wireless with end users in service.
  • Facilities-Based Fixed Broadband Service -This applies to providers who own last-mile facilities (or the rights to those facilities) with end users in service.
  • Facilities-Based Mobile Wireless Voice and Broadband Service – This applies to providers who own the wireless license (or the rights to the license) with end users in service.

In the meantime, JSI can assist with your Form 477 reporting including preparation of the upload files and developing good broadband deployment data.  If you have any questions about the Form 477 requirements or need assistance with your filing, please contact Kim Waldvogel in JSI’s Maryland office at 301-459-7590.

10 08, 2021

Clients Encouraged to Contact Local Governments About Broadband Funds

2021-11-02T13:07:43-04:00August 10, 2021|e-Lerts|

Window for funding requests is short so don’t delay

Broadband providers across the nation should be contacting their Non-Entitlement Units of Local Government (NEUs) – local governments serving populations of less than 50,000 – to confirm that they’ve requested their allocated Coronavirus Local Fiscal Recovery Fund payments from their state governments. The American Rescue Plan Act (ARPA) funds may be used for “necessary investments in water, sewer or broadband infrastructure.” Clients may be able to coordinate with their NEUs and leverage some of this funding for various broadband infrastructure projects or to strengthen future state and federal grant applications. But first, NEUs must send their requests to their states to receive the funding payments allocated to them.

NEUs can expect to receive Coronavirus Local Fiscal Recovery Fund payments through their state governments. States will receive, if they have not already, specific amounts from the U.S. Treasury Department for NEUs and are responsible for distributing these funds to NEUs within their state. Treasury expects to make two payments to states for distribution to NEUs approximately 12 months apart. NEUs must act quickly since ARPA requires each state to distribute these funds to its NEUs within 30 days following receipt of this funding from Treasury, but allows states to request extensions of this timeframe.

Treasury has shared a file online showing whether funding has been set aside for your local NEU. Award amounts are based on the population of the NEU. Each state has its own process and requirements for requesting and receiving Coronavirus Local Fiscal Recovery Fund payments.

JSI encourages clients to reach out to their local governments to determine if these funds have been requested and/or accepted and whether the NEUs are planning to use the funds for broadband. We are here to help in identifying NEUs, determining how much time an NEU has left to request funds, and how the NEU can request its funding. If you have any questions about the rules surrounding NEUs or the Coronavirus State and Local Fiscal Recovery Fund, please contact Anna Galanis or Chresanthe Staurulakis in JSI’s Maryland office at 301-459-7590.

3 08, 2021

Don’t Forget to Update Your Number Portability Procedures

2021-11-02T13:07:57-04:00August 3, 2021|e-Lerts|

Number portability has lost its headliner status recently to robocall prevention, but it cannot be forgotten entirely. New FCC-authorized iVoIPs and competitors are entering rural LEC territories and your company will likely have to port with them. It is important to maintain Number Portability Procedures (NPPs) to ensure that the necessary information is being exchanged by providers to successfully complete port requests. These NPPs also remind porting partners of the FCC port rules, as well as define your business’s port procedures.

The standard information exchanged includes, but is not limited to, your company’s dedicated number portability email address for order submission, your hours of operation, LSR validation fields, and port contacts. However, more information often is needed for successful porting. It is important to review your port procedures regularly to make sure the document accommodates the following:

  • Contact changes due to recent retirements, departures, or promotions;
  • Staff changes/new personnel;
  • New port request processes;
  • Permanently disconnected telephone number requirements;
  • Robocall mitigation procedures;
  • New interconnection agreements with CLECs/WSPs; and
  • New iVoIPs in your service area.

If any of the above changes are applicable to your company, it’s time to revise your Number Portability Procedures. JSI has created NPPs in compliance with FCC port rules and NANC standards beneficial to rural LECs. In addition, your company should confirm that your port partners have your updated number portability procedures business rules and that you have the current NPPs for your port partners.

For assistance updating or creating a set of procedures for your company or with exchanging NPPs with your port partners, contact Lisa Cover in JSI’s Maryland office at 301-459-7590.

3 08, 2021

AT&T to Add Number Transfer PIN to Wireless Port Requests

2021-11-02T13:08:04-04:00August 3, 2021|e-Lerts|

Clients that port wireless telephone numbers from AT&T will soon have another step to complete in the pre-port and port submission process. AT&T is implementing a new port protection policy on postpaid accounts due to a rise in unauthorized port activity in the wireless industry. Beginning in September, companies must acquire a six-digit number transfer PIN from the customer prior to submission of the port request to AT&T and the PIN must be posted on the port request.

AT&T sent this notice to port partners recently:

Effective September 21, 2021, AT&T Mobility will implement a new policy whereby Consumer Postpaid customers must obtain a Number Transfer PIN to use when porting from AT&T to another service provider. This change is being implemented to further protect post-paid customers against unauthorized or fraudulent port outs.

Customers will generate the 6-digit number transfer PIN via the myAT&T app, by dialing *PORT from the AT&T device, or from their myAT&T account online.

The 6-digit Number Transfer PIN will be entered in the PIN/password field on the Wireless Port Requests. The AT&T Mobility Account PIN will no longer be used to validate port outs for Consumer Postpaid TNs. All other validations and assessments remain the same.

If the Number Transfer PIN provided is incorrect, the port request will receive a resolution required response with the error code of “6B-AT&T Number Transfer OIN needed or incorrect” and the remarks will include “AT&T Number Transfer PIN Needed or Incorrect: www.att.com/portout”.

Additional details will be communicated prior to launch, including an overview, specific steps for each customer option and FAQs. All information will be available at www.att.com/porting.

Companies should make note of this change and add it to their internal porting procedures before it begins next month. If you have questions regarding the new AT&T Number Transfer PIN policy, contact Lisa Cover at 301-459-7590.

23 07, 2021

FCC Reiterated EAS Requirements for Persons with Disabilities

2021-11-02T13:08:24-04:00July 23, 2021|e-Lerts|

Providers also reminded of August 11 nationwide EAS test

The FCC this week reminded Emergency Alert System (EAS) participants, including all video/cable operators, that they must transmit EAS alerts in a way that visually and aurally impaired customers are able to fully understand the content being delivered. Noncompliance with the requirements can result in fines and sanctions.

All EAS participants should be sure to include the requirements for individuals with disabilities during the upcoming 2021 nationwide EAS test scheduled for August 11, 2021 at 2:20 p.m. EDT. Visual messages must be easily readable and audio messages should be at pace for a listener to understand.

All Multichannel Video Programming Distributors (MVPDs) are required to participate in the national EAS test. If your company is listed in the FCC’s Cable Operations and Licensing System (COALS), you are expected to participate. If your company has recently exited the video business, confirm that your company has properly removed its COALS registration.

Video/cable providers also are reminded that after the EAS test on August 11, they must file their “day of test” data on ETRS Form Two on or before August 12. EAS participants must then complete the detailed post-test data, which is due by September 27. By now all EAS participants should have completed their Form One filing that was due on July 6 in the EAS Test Reporting System.

If you have questions about the EAS national test or would like assistance with completing any of the required filings, please contact Kim Waldvogel in JSI’s Maryland office at 301-459-7590.

13 07, 2021

NTIA Funding Application Deadlines Quickly Approaching

2021-11-02T13:08:42-04:00July 13, 2021|e-Lerts|

Two NTIA grant programs providing more than $1 billion for broadband projects are accepting applications but the deadlines for both programs are right around the corner. NTIA’s Broadband Infrastructure Program (BIP) has $288 million in funding for government entities. And the Tribal Broadband Connectivity Program will distribute $980 million for tribal broadband deployment and adoption. Broadband providers are not eligible stand-alone applicants of either program, but many of the government and tribal entities vying for the grants will need support from current broadband providers to make a successful application. These programs provide a unique opportunity to build relationships in the community and serve areas that are not economical without grant funding. If you are considering participating as a partner with a government entity or a Tribal group, you must act soon. BIP program applications are due August 17. The Tribal Broadband Connectivity Program applications are due September 1.

NTIA’s BIP is looking for both last mile and middle mile project applications between $5 million and $30 million, but applications outside those ranges will be considered (See JSI’s May 24, 2021, e-Lert for more information). In addition, the partner can be the owner of the plant constructed if they comply with the other requirements of the grant. Lastly, there is no matching requirement, but there is additional scoring if a 10% match is provided.

The NTIA Tribal program is looking for applications between $1 million and $50 million for broadband deployment applications and between $50,000 and $2.5 million for increased adoption applications.  However, like the NTIA BIP applications outside those ranges will be considered.  There is no restriction for the commercial partner from owning the constructed plant and there is no matching requirement.

If your company is hoping to participate in an application for either program, you will need to act now. If you need assistance, JSI can support your application with maps, check lists, financial projections, project management, support for the narratives, and engineering support. If you would like our assistance or if you have questions about the requirements for either program, please contact Amanda Molina at 321-985-5709, Lans Chase at 770-569-2105 or Valerie Wimer at 301-459-7590.

2 07, 2021

Reminder: Carrier Identification Code Reports Due July 31

2021-11-02T13:09:18-04:00July 2, 2021|e-Lerts|

Carriers must submit their semi-annual Carrier Identification Code (CIC) Entity Access and Usage reports covering the period from January 1 through June 30, 2021, to the North American Numbering Plan Administration (NANPA) CIC Administrator by July 31, 2021.

For purposes of usage and reporting, CICs are assigned as Direct Trunk Access Feature Group B or D (FG B / FG D) or Switchless Reseller. Companies assigned Direct Trunk Access CICs must have trunk access with a facilities-based LEC. The trunk access must be reported to NANPA by both the CIC assignee and the facilities-based LEC from which the CIC assignee purchases access.

Holders of Switchless Reseller CICs must report the underlying carrier with which the CIC has FG D usage.

Semi-annual CIC reports are the sole tool used by NANPA to confirm if a CIC is being used in accordance with the CIC Assignment Guidelines or to determine if a CIC is subject to reclamation by NANPA.

CIC reminders:

  • Failure to submit the required semi-annual reports may result in CIC reclamation by NANPA.
  • Make sure the CIC reports are accurate before submission as information provided is considered certified.
  • CICs must be used in the manner they were requested and assigned within the CIC guidelines.
  • Verify your company’s CIC contact on file with NANPA is current and accurate. If not, updates should be filed with NANPA.

For more information about the required reporting and how JSI’s CIC Management Service can help you better manage your CICs in the future, contact Lisa Cover in JSI’s Maryland office at 301-459-7590.

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