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Telecom Alert: $300K Fine for Filing Violations; Cybersecurity Labeling Program Deadline Extended; E-Rate Eligible Services List; USF Contribution Factor [Vol. XX, Issue 38]

$308,451 Fine Proposed for Failure to File CPNI and Maintain CORES Information

The FCC issued a Notice of Apparent Liability for Forfeiture against Stage 2 Networks, LLC (“Stage 2”) last week for failing to file annual and quarterly reporting worksheets, to respond to an Enforcement Bureau inquiry in a complete and timely manner, to file customer proprietary network information (“CPNI”) certifications, and to maintain current information in CORES. Under FCC rules, telecommunications providers are required to file worksheets to allow the Commission to assess regulatory fees. Additionally, providers must certify compliance with rules designed to protect CPNI and maintain CORES information for contact purposes. The Enforcement Bureau has proposed a $308,451 penalty against Stage 2 for failure to adhere to Commission rules over a three-year period. For more information, please contact Casey Lide (; 202.434.4186) or Tim Doughty (; 202.434.4271).

Cybersecurity Labeling Program Pleading Cycle Extended

The FCC released an Order last week extending the comment deadline for the Notice of Proposed Rulemaking seeking to establish a voluntary cybersecurity labeling program (the “Program”) (Vol. XX, Issue 35).  The Program seeks to improve consumer confidence and understanding of the security of connected devices by labeling smart devices and products that meet widely accepted security and privacy standards with the U.S. Cyber Trust Mark Logo.  Several trade associations requested a 30-day extension on the original September 25 comment deadline and a 45-day extension for replies.  Comments and reply comments are now due October 6 and November 10, respectively.  For more information, please contact Tracy Marshall (; 202.434.4234).

Proposed E-Rate Eligible Services List

Last week, the FCC’s Wireline Competition Bureau issued a Public Notice seeking comment on the proposed eligible services list (“ESL”) for the E-Rate Program for funding year 2024.  The Commission proposes several minor revisions to the ESL, including clarifying that the software necessary to operate or maintain Category One equipment is eligible and consulting fees not related to the installation and configuration of eligible components are ineligible.  It invites comment on these revisions as well as the proposed services list for 2024.  Comments and reply comments are due by October 12 and October 26, respectively.  For more information, please contact Sean Stokes (; 202.434.4193).

USF Contribution Factor

The FCC’s Office of Managing Director issued a Public Notice announcing that the proposed universal service contribution factor for the fourth quarter of 2023 will be 34.5 percent, absent any action from the Commission.  The 34.5 percent assessment on end-user interstate and international telecom service revenues is projected to meet the fourth quarter’s requirement of $2.078 billion for the four original universal service programs (E-Rate, rural health care, high-cost, and Lifeline) and the Connected Care Pilot Program.  For more information, please contact Casey Lide (; 202.434.4186).

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