Archives: Transparency and Disclosure

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FCC Announces Enhanced Broadband Transparency Disclosures Will Become Effective Jan. 17, 2017

Small Provider Exemptions in Limbo On Thursday, December 16, the FCC announced that the Office of Management and Budget had approved the long-delayed “enhanced” Open Internet transparency requirements, which were originally approved in March 2015. As a result, the deadline for providers to comply with these enhanced requirements is January 17, 2017. Significantly, this deadline also […]

Top Takeaways from DWT’s April 26 Open Internet Webinar

As the communications industry anxiously awaits a decision from the U.S. Court of Appeals for the D.C. Circuit on the judicial challenge to the Federal Communications Commission’s Open Internet rules, the Commission is charging forward with new regulations.  On April 26, DWT held its latest in a series of webinars focusing on Open Internet developments.  […]

FCC Releases Open Internet Transparency/Disclosure Rule Safe Harbor in the Form of Broadband Service “Labels” for End User Customers

Broadband Disclosures Bear Striking Resemblance to Nutrition Labels  The FCC has released its safe harbor disclosure framework under the Open Internet transparency requirements for end user customer disclosures, which takes the form of a broadband “label” –not unlike the form of labels used by manufacturers of food products.  There are two separate safe harbor labels: […]

Advisory Alert: Annual FCC CPNI Certification Due by March 1, 2016

Upcoming Open Internet Rules Will Soon Expand CPNI-Type Obligations to Broadband This is to remind our clients that the Federal Communications Commission’s (FCC) rules require every telecommunications and interconnected VoIP service provider (including wireless, cable telephony, and even paging and calling card providers) to execute and file an annual officer certification that it is in […]

FCC Extends Exemption from Enhanced Disclosure Rules for Small Providers

On Wednesday, the FCC’s Consumer and Governmental Affairs Bureau extended the ongoing exemption from applying the enhanced transparency requirements of the 2015 Open Internet Order to small providers.  As a result, small providers (those with 100,000 or fewer broadband subscribers) will continue to be exempt from the agency’s new “enhanced” transparency requirements for the foreseeable […]

Deadlines Set for Comments on Small Provider Transparency Rule Exemption

As we wrote last month, the FCC’s Consumer and Governmental Affairs Bureau is seeking comments on whether small providers (those with 100,000 or fewer broadband subscribers) should continue to be exempt from the “enhanced” transparency requirements of the 2015 Open Internet Order.  The request for comments was published today in the Federal Register, establishing August 5, 2015 as […]

FCC Seeks Input on Open Internet Transparency Exemption

Smaller broadband providers now have an opportunity to convince the FCC to maintain the small provider exemption from the new “enhanced” transparency (disclosure) requirements of the 2015 Open Internet Order. As we explained in a recent advisory, the 2015 Open Internet Order temporarily exempts providers with 100,000 or fewer broadband subscribers from the FCC’s “enhanced” […]

FCC Proposes Record $100 Million Penalty for Alleged Violations of Open Internet Transparency Rule

If you work for a broadband service provider and haven’t recently reviewed your FCC-mandated network management “transparency” disclosures posted on your website, we suggest you make that the next thing you do after reading this blog.  That’s because yesterday the FCC proposed to impose a $100 million fine against AT&T Mobility (“AT&T”) for alleged violations […]

Are Your Disclosures Sufficient Under the “Enhanced” Transparency Rule?

Although not yet in effect, broadband providers should begin to consider how best to implement the FCC’s “enhanced” transparency (disclosure) requirements. As explained in our recent advisory, the Order retains the FCC’s 2010 transparency (disclosure) rule, but adopts “enhancements” which will require additional disclosures of broadband providers’ network management practices, network performance, and commercial terms […]
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