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by JONATHAN S. MARASHLIAN
FAIR WARNING
Choosing the Right Phone Repair Parts Supplier: To All Telecommunications Resellers How to Make the Right Choice and the Harsh FCC Enforcement No Longer the Exclusive Domain of the FCC; Outside Agencies and Agents Now Perform Much of the Dirty Work
Consequences of Failing to do so
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By Jamil Hindi, president and founder of Q ualit y Repair Par ts
ver the past several years, our firm has witnessed a major shift in the way the Federal Communications Commission’s (“FCC”) This article is directed at informing Enforcement Bureau: (A) uncovers possible those currently in, or considering violations of the Communications Act and FCC Rules and (B) develops evidentiary phone records used to trigger entering thethegrowing repair aindustr Notice of yInquiry and support eventual Notices of about the variety of avenues Apparent Liability for Forfeiture and other enforcement in which a repair shop owner may actions. Historically, FCC enforcement actions were pursuein in repair parts. initiated oneobtaining of two ways, either through an Enforcement Bureau initiated investigation on its own The article briefly motion or in will response to aintroduce complaint.the Ingrading recent years, however, Enforcement has increasingly system inthe which parts areBureau classified by quality. I relied upondive outside anddifferent governmental will then intoagencies the many routesagents that to “dig up” the proverbial “dirt.” The two primary the vast majority repair shops pursue in obtaining excavators are Team Telecom and the Universal Service their parts andCompany explain why not using the highestAdministrative (“USAC”). grade parts serves an injustice to your customer and We believe that industry awareness of this developing poses devastating effects to your business. Given trend is important. Knowing, in advance, that the the fact that thecompany most popular performed disclosures your may be repair asked to disgorge during a USAC is audit or Team Telecom national will security by technicians a screen repair and screens review (when seeking a 214 Authorization or approval constitute the majority of a repair shop’s inventory in of a merger / sale of assets) could lead to potentially terms of dollars invested, this article will specifically significant fines & forfeitures from the FCC’s focus on replacement screens, which consists a Enforcement Bureau will help companies that areof already in the market avoid careless mistakes. For new combination of themaking LCD and digitizer components.
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companies considering entry into the regulated telecom, VoIP and non-interconnected VoIP industries, awareness that the FCC’s Enforcement Bureau is watching through The ‘Un-official’ Grading System the eyes of other governmental agents will dissuade There are a varietyand of different quality screensofout unlawful operations actions, prior to receipt all necessary FCC authorizations. in the marketplace that a repair shop can choose to use to perform their repairs. Below is a compilation,
USAC — You can run, an unofficial however, accurate, list of the various but you can’t hide…
qualities available and the attributes that they possess: USAC is an independent non-profit company designated to administer Universal Service Fund (“USF”) programs. The Internal Audit Division, responsible for identifying The “B Grade” - Quite arguably areas of non-compliance withScreen the Universal Service Fund program, issues audit reportsscreen that are automatically thefinal lowest quality available in the referred to the FCC. The FCC often uses the information market. This grade often has a defective gathered during the course of USAC audits and rate of roughly 60%. Defects for Grade B up screens documented in USAC’s audit reports to open parallel include: multiple dead spots on the digitizer, stress investigations of possible Communications Act and FCC rule violations. What is unearthed during a USAC audit marks, severe discoloration and dead pixels on the will often times be used as the evidentiary foundation LCD. With most B grade screens, you will notice of a Notice of Apparent Liability for Forfeiture (“NAL”). that the screens do not fit flush on the device as the
In July 2009, example, USAC a report to the original partfor did. You will also referred notice on B Grade FCC “for potential enforcement action,” alleging that screens that the LCD brightness is incredibly low. “Globalcomm had failed to comply with the Commission’s It would be similar to going to your phones settings rules requiring Telecommunications Carriers to contribute and brightness 75%.a Notice of to thedecreasing USF.” Thethe FCC soon afterbyissued