Still working its way through the 2009 Omnibus CPNI NAL, the FCC released a forfeiture order against prepaid card provider 88 Telecom.  The Commission imposed the full $20,000 penalty proposed in the NAL, rejecting 88 Telecom's arguments that its violation was not willful and that it could not pay the forfeiture.  What is most significant about the order, however, is that the provider did not settle the allegation via a consent decree.  Most of those who did were able to settle for a few hundred to a few thousand dollars.