Due to the 1 year statute of limitations for proposed fines against common carriers, the release of a Notice of Apparent Liability for failing to file CPNI certifications has become an annual late-February event. This year's order, released late on Friday, proposes fines against 10 entities for failing to file the CPNI certification due on March 1, 2010. Despite what has been a roller coaster in CPNI fines and in CPNI settlements, the Order proposes a $25,000 fine for failing to file the certification (the same amount proposed last year). Moreover, each of the 10 entities was accused of failing to respond to the Enforcement Bureau's Letter of Inquiry, resulting in an additional proposed fine of $4,000.
For those who have not yet filed their 2011 certifications,today is the last day.