On February 24, the FCC announced its first major CPNI enforcement actions since the new CPNI rules went into effect in April 2007. In an Omnibus CPNI NAL, the Enforcement Bureau proposed fines of $20,000 each against over 600 telecommunications carriers that failed to file their annual CPNI certifications on time. Knowledgeable staffers tell us that the 600 carriers include those who filed certifications significantly after the deadline as well as those who never filed the 2008 certification. The respondents have 30 days to respond to the NAL.
The Bureau also released over a dozen smaller NALs for various deficiencies in carrier certifications. The deficiencies were hyper-technical: failures to state whether actions were taken against pretexters or failures to state whether the carrier received any CPNI complaints.
Update: It appears that a number of late-filers received citations instead of fines. Some have all the luck.