Despite many high-profile forfeiture proceedings, significant outreach by the FCC and even a new app to facilitate filing, the level of CPNI certifications filed this year was on a par with 2010.

Last year, we reported about 3,000 CPNI certifications filed during the filing window. This year, 2,858 submissions were made through 3/2/11. While many filers certified on behalf of multiple USF filers, this total still is about a thousand carriers below the number of active USF filers as identified in USAC's most recent contribution factor report and is well below the 6,700 filers in USAC's database.

It appears that the FCC has achieved about as much compliance as it is going to receive from the universe of required filers. Now, the question is whether it will pursue more $25,000 fines from the remaining (mostly small) entities that failed to file a certification.