Mobile Virtual Network Enablers (MVNEs) provide network infrastructure and other services, such as business support systems, administration, and operations support systems to Mobile Virtual Network Operators (MVNOs).

By providing network enablement and the management of mobile services such as SIM provisioning and configuration, MVNEs allow MVNOs to offer services to customers under their own brands.

Both MVNEs and MVNOs are subject to a number of federal and state laws, regulations, and rules. As a wholesaler, an MVNE may be exempt from certain obligations if it qualifies as a “private service provider.”

However, this status is determined through a stringent set of conditions. The consequences of reaching the incorrect conclusion can be significant and very costly. Self-determination without expert counsel is strongly discouraged.

Both common carriers and private carriers are subject to obligations that include:

• CALEA (Communications Assistance for Law Enforcement Act)
• CPNI (Customer proprietary network information)
• 499 registration
• USF Contributions
• CVAA (Communications and Video Accessibility Act)
• FCC Regulatory Fee Contributions

In addition, MVNEs may be obligated to comply with:

• TRS contributions
• NANP contributions
• LNP contributions
• Hearing aid compatibility
• Outage reporting
• Discontinuance rules
• Truth in Billing rules

Non-compliance with these requirements can result not just in administrative hassles, but fines of thousands, tens of thousands, or even – in the case of CVAA violations, one million dollars (As much as $100,000 per violation or each day of a continuing violation up to a maximum of $1 million.)

The CommLaw Group’s experienced attorneys can guide you through the highly complex process of compliance with federal and state obligations, and safeguard your telecom business from potentially devastating penalties and fines.