Will you get fined?
ByIf you read my last blog and found it unbearably boring, don’t read this one since it is the “ … to be continued.” For those of you that are still with me, for toll-free services the FCC can enforce what is in the Code of Federal Regulations, Subpart D: Sections 52.101 through 52.111.
These sections refer to issues of hoarding, warehousing, and selling toll-free numbers. It’s a really short little part of The Code of Federal Regulations, but it is huge to the toll-free industry. The FCC Enforcement Bureau launched an investigation in 2010 which is focused on this little section. And, the truth of the matter is, most RespOrgs are guilty of violations to some extent. When I completed ATL’s response, I found six numbers (from the days when I owned a CLEC) that customers didn’t take with them when I sold the CLEC. We didn’t have an internal mechanism in place to alert us that we had a few numbers that had been turned off but not released back as “spare” in the national database. These weren’t numbers that spelled anything so no one ever asked us about them.
In reality, as was pointed out to me by the FCC in our meeting, ATL was guilty of hoarding because we had numbers with no usage and no customer. Will we get thousands of dollars in fines for these six numbers? I don’t know. 660 other companies probably didn’t think they would get fined $20,000 each for being late on one filing, but the FCC did just that.
In the meeting, I gained a real appreciation for how difficult it is for the FCC to determine who is wearing a Black Hat and who has on a White One. It will be interesting to see how this plays out, but I have great concern that the companies who really went out of their way to be white hat types will get treated just like the ones who the industry identified as black hats years ago.
