Reminder: Several Filing and Compliance Deadlines Approach
As the end of 2017 approaches, JSI reminds clients of upcoming deadlines, annual notice obligations, and end-of-year data to capture for reporting in 2018.
Designated Agents for Copyright Infringement
To protect themselves from copyright violations committed by their customers, all ISPs and broadband providers need to register in an online system a Designated Agent with the U.S. Copyright Office by December 31, 2017. (See JSI’s November 17 e-Lert.)
Mobility Fund Phase II Data Collection
Facilities-Based mobile wireless providers with qualifying 4G LTE coverage must respond to FCC data collection by January 4, 2018. Those without qualifying coverage must submit a certification.
Broadband Location Reporting in HUBB Portal
Recipients of A-CAM and recipients of Legacy support with buildout requirements (shown as having less than 80% 10/1 on FCC’s October 6, 2016, Public Notice – DA 16-1141) must submit geo-located broadband information into USAC’s High Cost Universal Service Broadband (HUBB) portal by March 1, 2018.
By this deadline, A-CAM recipients must submit all locations that were upgraded or newly deployed during calendar year 2017 in satisfaction of their buildout obligations. Carriers on Legacy support with buildout obligations must submit all locations that were upgraded to at least 10/1 or newly deployed at least at that speed for a 19-month period, from May 25, 2016, through December 31, 2017. The FCC has emphasized that carriers should file well in advance of the deadline to allow sufficient time to address any issues with the data and recommends filing data within 30 days of deployment.
Do Not Call Customer Notifications
Wireline local exchange carriers must notify customers annually of the national 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.
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 equipment compatibility, products and services, pricing, installation and service maintenance policies, channel positions, billing and complaint procedures, and signals which require converter boxes. The FCC now permits this “written” information to be provided via 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.
Operators also must provide a separate written statement regarding subscriber privacy upon service installation and annually to all video customers.
Power Backup Notifications
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 also must make an annual notice to all non-line powered customers sometime during the year. The notice must include specific information outlined in FCC rules.
Red Flag Rules – Annual Internal Report
All carriers must compile a report annually that provide the status of their identity theft prevention programs over the past year. There are no requirements to file these reports with the Federal Trade Commission (FTC) or other agency, but each company must provide its report to its Board, an appropriate committee of the Board, or a designated senior management employee. Specifically, these reports should cover: 1) the effectiveness of the company’s policies and procedures in addressing the risk of identity theft in connection with the opening of covered accounts and with respect to existing covered accounts; 2) service provider arrangements; 3) significant incidents involving identity theft and management’s response; and 4) recommendations for significant changes to the program.
December 31 Data Captures:
FCC Form 477
All fixed voice, facilities-based broadband, and facilities-based mobile wireless service. Report of this data will be due by March 1, 2018.
Semi-Annual Cable Copyright Statements of Account
Copyright royalty fees for the July 1-December 31, 2017 accounting period will be due by March 1, 2018.
Geo-Coding Location Broadband Deployment Report
By March 1, 2018, all A-CAM recipients must submit all locations that were upgraded or newly deployed during calendar year 2017 in satisfaction of their buildout obligations. Carriers on Legacy support with buildout obligations must submit all locations that were upgraded to at least 10/1 or newly deployed at least at that speed for a 19-month period, from May 25, 2016, through December 31, 2017. Legacy carriers also must report these locations by March 1, 2018.
Eliminated in 2018:
Section 43.62 International Traffic & Revenue Report
The FCC has eliminated this reporting requirement for all carriers. You no longer need to capture the traffic and revenue data that was previously filed in this report.