End of Year Reminders

As the end of 2018 approaches, JSI reminds clients of annual compliance obligations and end-of-year data to capture for reporting in 2019.

Annual Compliance and Customer Notices

Deadline for Completing Annual Red Flag Rule Report – Identity Theft Prevention Programs. Requires all “creditors” as defined by the Red Flag Rule to annually complete reports related to their Identity Theft Prevention Programs and keep the reports on file internally. In this context, “creditors” include telecoms, video providers and other entities that “extend credit” by allowing customers to pay for services after they are rendered. However, the Federal Trade Commission clarified that creditors are not required to maintain programs and complete annual reports if they do not “regularly and in the course of business” obtain or use credit reports or give information to credit reporting companies. JSI, however, recommends that as a good business practice, all companies that are considered creditors continue to complete the reports and update their programs as appropriate. Contact: Kim Waldvogel

Do Not Call Annual Customer Notices. Wireline local exchange carriers must notify customers annually of the Do Not Call Registry. Both wireline and wireless companies are required to send a one-time notification of the national do-not-call requirements to any person or entity to which the company provides service for the purpose of making telephone solicitations. Contact: Marty Kluh

Video Provider Customer Notices. At the time of service installation and then annually to all customers, video/cable operators must provide written information to customers regarding products and services, pricing, installation and service maintenance policies, channel positions, billing and complaint procedures, and signals which require converter boxes. Note that the FCC now permits this “written” information may be provided by email if (1) the notice is sent to a verified email address, and (2) there is a mechanism for video customers to opt out of email delivery and continue to receive paper notices. Also upon service installation and annually to all video customers, operators must provide a separate written statement regarding subscriber privacy. Contact: Marty Kluh

Power Backup Notices. All companies that use non-line-powered local loops, such as fiber to the home (FTTH), must offer at least eight hours of power backup to customers. In addition to notifying new non-line-powered customers, companies must send an annual notice to all non-line powered customers sometime during the year. The notice must include specific information outlined in FCC rules. The 24-hour minimum backup power requirement will take effect February 13, 2019. Contact: Valerie Wimer

December 31, 2018 Data Captures

FCC Form 477. Facilities-based broadband, fixed voice, and facilities-based mobile wireless data as of December 31 will be due by March 1, 2019. Contact: Marty Kluh

Semi-Annual Cable Copyright Statements of Account. Copyright royalty fees for the July 1-December 31, 2018, accounting period will be due by March 1, 2019. Contact: Kim Waldvogel