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                           Before the
                Federal Communications Commission
                     Washington, D.C. 20554




In the Matter of                   )
                              )    File No. EB-00-TC-053
Verizon Communications             )    NAL/Acct. No. X3217-010                     
)

                              ORDER





          Adopted: October 16, 2000          Released: October 
          17, 2000



By the Chief, Enforcement Bureau:





In  this  Order,  we  adopt  a  Consent  Decree  terminating   an 
investigation    into    possible    violations    of     section 
64.1120(a)(1)(ii) of  the  Commission's rules  by  Bell  Atlantic 
Communications, Inc. d/b/a Verizon Long Distance (Verizon).  

On May 19, 2000, Verizon voluntarily disclosed to the Enforcement 
Bureau (Bureau) that it could  not locate records of  third-party 
verifications (``TPV'')  for an  estimated 20-25,000  residential 
consumers who had  recently switched their  preferred carrier  to 
Verizon during an inbound  call to one  of the residential  sales 
and   service   centers   (``RSSCs'').    Verizon's    subsequent 
investigation disclosed  that  the number  of  affected  customer 
lines was  approximately  34,000.   The Bureau  has  received  no 
evidence, such as complaints from any of the affected  customers, 
indicating  that   Verizon  changed   the  customers'   preferred 
interexchange carrier without proper authorization.  Accordingly, 
the issues before  us solely relate  to third-party  verification 
and record maintenance, and not to the practice commonly known as 
``slamming.'' 

The Bureau and  Verizon have  negotiated the terms  of a  Consent 
Decree that would terminate the staff's investigation.  A copy of 
the Consent Decree is attached and is incorporated by  reference.  
As detailed  in  the Consent  Decree,  Verizon has  taken  and/or 
agreed to take various actions to rectify the matter and  prevent 
a recurrence,  including,  but  not limited  to:  contacting  and 
crediting   affected   residential   consumers;   requiring   TPV 
contractors both to formally train their employees at the time of 
hiring and at least twice per year thereafter on Commission rules 
and policies,  and  to sign  an  agreement to  take  disciplinary 
action   against    their   employees    who   violate    section 
64.1120(a)(1)(ii); and periodic monitoring of TPV contractors  to 
ensure compliance with the Commission's third-party  verification 
and record retention rules.  Verizon has also agreed, inter alia, 
to observe  the  verification  activity of  the  TPV  contractors 
through regular on-site visits and/or telephonic monitoring,  and 
to perform monthly audits of all TPV contractor's operations.

We have reviewed the  terms of the  Consent Decree and  evaluated 
the facts  before us.   In light  of Verizon's  commitment to  be 
bound   by   various   principles   regarding   its   third-party 
verification and records  retention procedures,  we believe  that 
the public  interest would  be served  by approving  the  Consent 
Decree and terminating the investigation.

Based on the record before us, and in the absence of material new 
evidence relating to this matter,  we conclude that there are  no 
substantial and material questions of fact as to whether  Verizon 
possesses  the  basic  qualifications,  including  its  character 
qualifications,  to   hold  or   obtain  any   FCC  licenses   or 
authorizations.

Accordingly, IT  IS  ORDERED, pursuant  to  section 4(i)  of  the 
Communications  Act,  47  U.S.C.    154(i),  and  the  authority 
delegated by sections 0.111 and 0.311 of the Commission's  rules, 
47 C.F.R.  0.111,  0.311, that the  attached Consent Decree  IS 
ADOPTED.

IT IS FURTHER ORDERED that the Commission staff inquiry into  the 
matter described here IS TERMINATED. 





                         FEDERAL COMMUNICATIONS COMMISSION





                         David H. Solomon
                         Chief, Enforcement Bureau




                           Before the
                Federal Communications Commission
                     Washington, D.C. 20554



In the Matter of                   )
                              )    File No. EB-00-TC-053
Bell Atlantic Communications, Inc.      )    NAL/Acct No. X3217-
010
                              )
          






                         CONSENT DECREE




     1.   The Enforcement Bureau of the Federal Communications 
Commission (``FCC'' or ``Commission'') and Bell Atlantic 
Communications, Inc. d/b/a Verizon Long Distance (``Verizon'') 
hereby enter into a Consent Decree terminating an informal Bureau 
investigation into possible violations of section 
64.1120(a)(1)(ii) of the Commission's rules, which, among other 
things, requires telecommunications carriers to maintain and 
preserve records showing that they have verified consumer 
authorization to change the consumer's telecommunications service 
provider.  Verizon is a common carrier that provides interstate 
interexchange telecommunications services in the State of New 
York pursuant to tariffs on file with the Commission.  Verizon 
voluntarily brought this matter to the Bureau's attention.  
For the purposes of this Consent Decree the following definitions 
shall apply:

a)          ``Commission''   or   ``FCC''   means   the   Federal 
  Communications Commission;
b)   ``Bureau'' means  the  Enforcement  Bureau  of  the  Federal 
  Communications Commission; 
c)   ``Verizon'' means Bell Atlantic Communications, Inc.,  d/b/a 
  Verizon Long Distance;
d)             ``Parties'' means Verizon Communications Inc., its 
  affiliate Verizon, and the Commission or Bureau;
e)             ``Adopting Order'' means  an Order  of the  Bureau 
  adopting the terms and conditions of this Consent Decree;
f)             ``Effective Date''  means the  date on  which  the 
  Bureau releases the Adopting Order. 
g)             ``PIC Change'' is an order transmitted to a  local 
  exchange  carrier  (``LEC'') by  an  interexchange  carrier  or 
  request from  a consumer to  a LEC requesting  a change of  the 
  consumer's  preferred   interexchange  and/or  intraLATA   toll 
  carrier (``PIC'');
h)             ``Residence Sales and Service Centers'' refers  to 
  telephone  company  service  centers  that  serve   residential 
  service  consumers.  Among  other  things, employees  at  these 
  centers accept requests  from residential service consumers  to 
  change their  presubscribed interexchange carrier and  initiate 
  the processing of these requests.
               
The Parties  agree that  the provisions  of this  Consent  Decree 
shall be subject to final approval by the Bureau by incorporation 
of such  provisions by  reference  in an  Adopting Order  of  the 
Bureau. 

The Parties agree that this Consent Decree shall become effective 
on the  date on  which the  Bureau releases  the Adopting  Order.  
Upon release, the  Adopting Order and  this Consent Decree  shall 
have the  same  force  and  effect as  any  other  Order  of  the 
Commission and any violation of the terms of this Consent  Decree 
shall constitute a violation of a Commission Order entitling  the 
Commission to exercise any and all rights and to seek any and all 
remedies authorized by  law for the  enforcement of a  Commission 
Order.

Verizon admits the jurisdiction of the Commission for purposes of 
this Consent Decree and the Adopting Order.

Verizon waives any rights that it may have to further  procedural 
steps and  any rights  it may  have to  seek judicial  review  or 
otherwise challenge or contest the validity of the Adopting Order 
or this Consent Decree.

Verizon waives any rights it may have under any provision of  the 
Equal Access to Justice Act, 5 U.S.C.  504.



       Statement of Facts



Verizon provides  long distance  service to  residential  service 
customers in New York, and employees in its affiliated  telephone 
company residence sales  and service  centers (``RSSCs'')  handle 
incoming  calls  from   consumers  who  want   to  change   their 
presubscribed carrier.   On  May 19,  2000,  Verizon  voluntarily 
disclosed to  the Bureau  that  it could  not locate  records  of 
third-party verifications  (``TPV'') for  an estimated  20-25,000 
residential consumers who had  recently switched their  preferred 
carrier to Verizon during  an inbound call to  one of the  RSSCs.  
Verizon's subsequent investigation disclosed  that the number  of 
affected  customer  lines  was  approximately  34,000.    Verizon 
represented to the  Bureau that  it had  recently discovered  the 
problem, and  that the  missing records  related to  PIC  changes 
dating back to March 2000.  

Verizon's auditing of the billings  from its TPV contractor,  The 
Sutherland Group, Ltd. (``Sutherland''), revealed that Sutherland 
was charging  Verizon for  fewer  TPV transactions  than  Verizon 
expected  based  on  the  number  of  carrier  selection   orders 
generated through the  RSSC.  Although not  all inbound  requests 
for long  distance  service required  TPV,  Verizon  nevertheless 
recognized that a problem existed.  

Verizon represents that Sutherland contributed to the problem  of 
locating verification records by  storing verification data in  a 
manner that was  difficult to track  and retrieve.  For  example, 
Verizon noted  that  Sutherland,  after  verifying  a  customer's 
carrier selection  for  multiple  lines at  a  single  residence, 
stored the information according to the billing telephone number, 
which created problems when retrieving and recording the  related 
working telephone  numbers in  the  accounts that  were  verified 
during the same  transaction.  In addition,  Verizon pointed  out 
that Sutherland stored verifications for PIC changes on  existing 
additional lines under  the billing telephone  numbers, and  that 
Sutherland stored some residential verifications in its  business 
validation database.  

Verizon  also  represents  that  it  encountered  other  problems 
reconciling the data.  For  example, an area  code split in  Long 
Island, New York  resulted in verification  records being  stored 
under the original area  code rather than the  new one. In  other 
cases,  Verizon  states  that  when  its  service  representative 
assigned a  telephone  number to  a  subscriber whose  area  code 
changed  prior   to  completion   of  the   order,  the   service 
representative performed the TPV under the old area code, but the 
completed  service  order  record  reflected  the  new  one.   In 
addition,  Verizon   admits  that   in  some   cases,  the   RSSC 
representative may  have inadvertently  given incorrect  customer 
information to Sutherland, or  Sutherland may have  inadvertently 
entered incorrect information into its database.

Verizon represents that it promptly and voluntarily implemented a 
number of remedial actions  with respect to approximately  34,000 
residential customers for whom it  could not locate TPV  records.  
These actions include the following:

a)     It  has  contacted  customers  to  reconfirm  PIC   change 
  authorizations  and is   crediting these  consumers up  to  the 
  date of  the completed TPV or  the consumers' stated desire  to 
  switch to another  carrier.  Verizon represents that, to  date, 
  some 10,000 of these customers still have not responded to  its 
  repeated  attempts to  reach  them.  Verizon  will  credit  the 
  consumers  that  it has  been  unable  to reach  for  all  long 
  distance charges  since they were  switched to Verizon  through 
  October 18, 2000.   If any of these customers contacts  Verizon 
  to dispute his or her carrier selection before April 19,  2001, 
  Verizon will  process a PIC  change at its  expense and  credit 
  the customer for  all Verizon charges billed since October  18, 
  2000.

b)     It  continues  to work  with  Sutherland  to  ensure  that 
  source  code  modifications  are  implemented  to  address  the 
  database  entry  and  retrieval  problems  identified  in   the 
  operational review.

c)     It has held, except during the August 2000 work  stoppage, 
  and will continue to hold, monthly performance review  meetings 
  and  discussions  with  senior  executives  of  Sutherland   to 
  discuss programming and system changes and staffing levels,  to 
  review changes in procedures, and to conduct joint  observation 
  sessions  to  identify  any  training  process  or  performance 
  issues.  

d)     It deployed  a new  feature in its  ordering systems  that 
  prevents  a service  representative  from initiating  an  order 
  before  TPV  has been  successfully  obtained  by  requiring  a 
  confirmation code  on every Verizon  presubscription order  for 
  which TPV is necessary.  This code is communicated to the  RSSC 
  by  the   third-party  verifier   only  after   TPV  has   been 
  successfully  completed.  The  service order  systems will  not 
  process  such  an order  if  it has  no  code or  if  the  code 
  provided  does   not  conform  to   the  encryption   algorithm 
  established  with the  third-party verifier.  Any  questionable 
  orders are immediately forwarded to a special group in  Verizon 
  for investigation and resolution.

e)     All  customer  service  representatives  and   supervisory 
  employees in the  RSSCs were retrained on TPV requirements  and 
  procedures,  emphasizing  the  legal  requirements  and  making 
  clear that failure  to comply with these requirements was  also 
  a violation of the  company's code of conduct and would  result 
  in disciplinary action, including dismissal.  

f)     Where  Sutherland's   records  indicated   that  an   RSSC 
  employee had a high incidence of unverified PIC change  orders, 
  the  company   monitored  the  employee's  customer   contacts.  
  Consistent with the company's labor practices, if any  problems 
  were found with these representatives or other  representatives 
  identified through  random monitoring,  the representative  was 
  reinstructed on the required procedures.  As a result of  these 
  actions,  the company  has  taken initial  disciplinary  action 
  against  several  employees, had  ``second  discussions''  with 
  some of those  from the initial group, and subsequently  issued 
  formal warnings of potential dismissal against some  employees.  
  In  addition,  the   company  terminated  one  supervisor   for 
  falsifying reports of her monitoring activities. 

g)     It  appointed compliance  managers in  each RSSC  director 
  group  to serve  as the  primary contact  point for  compliance 
  issues,    including   compliance    with   the    Commission's 
  requirements regarding PIC conversions.

During  its  May  19,  2000  meeting  with  the  Bureau,  Verizon 
described the corrective  actions taken  and the  schedule to  be 
followed with  respect to  further corrective  actions.   Verizon 
made follow-up  visits and  calls  to the  Bureau to  update  the 
Commission staff  on  the course  of  the investigation  and  the 
status of the corrective actions taken.  Verizon memorialized the 
information presented to the Bureau in subsequent letters.1





       Terms of Settlement



In consideration  for  the  termination  by  the  Bureau  of  its 
investigation  into   whether   Verizon  has   violated   section 
64.1120(a)(1)(ii)  of  the  Commission's   rules,  47  C.F.R.    
64.1120(a)(1)(ii), pertaining  to TPV  record retention,  and  in 
accordance with the terms of this Consent Decree, Verizon  agrees 
to the following terms.  

Verizon shall make a voluntary contribution to the United  States 
Treasury in  the  total amount  of  $250,000 (two  hundred  fifty 
thousand dollars).  This amount shall  be paid within 30 days  of 
the date on which the order adopting this Consent Decree  becomes 
final.  Such contribution shall be made, without further  protest 
or recourse, by certified check,  cashiers check, or money  order 
drawn to the order of the Federal Communications Commission,  and 
shall be mailed  to the Federal  Communications Commission,  P.O. 
Box 73482, Chicago, Illinois 60673-7482.

Verizon agrees to  subject its employees  and TPV contractors  to 
the following oversight mechanisms to help insure compliance with 
PIC change rules:

a)   Upon entering into  any contract with  a TPV contractor  and 
  within 30  days of the  effective date of  this Consent  Decree 
  for existing TPV contracts, Verizon shall require that the  TPV 
  contractor:
  1)           both at the time  of hiring and  at least twice  a 
     year  thereafter,  formally  train  its  employees  on   the 
     Commission's rules  regarding PIC-change  requests.   Should 
     those rules and orders change, Verizon will ensure that  its 
     TPV contractors  are promptly  apprised of  such changes  so 
     that the TPV contractors can promptly update their  training 
     material to reflect the new rules. 
  2)           sign an agreement with Verizon specifying that any 
     of the verifiers  found to  have engaged  in practices  that 
     violate section 64.1120(a)(1)(ii) of the Commission's  rules 
     shall be  subject to  disciplinary action,  including, at  a 
     minimum,  periodic   telephonic  monitoring   described   in 
     paragraph 16(b)  and  retraining  on  Commission  PIC-change 
     rules and policies. Further,  any pattern of such  practices 
     by the  contractor shall  subject the  contractor to  prompt 
     termination of its relationship with Verizon.
          b)  Verizon shall observe the verification activity  of 
          the  TPV  contractor  through  regular  on-site  visits 
          and/or  telephonic  monitoring   to  ensure  that   the 
          verifiers  are   operating  in   compliance  with   the 
          Commission's verification and record retention rules. 
          c) Verizon  shall perform  monthly  audits of  all  TPV 
          contractors' operations comparing  orders forwarded  by 
          the Verizon representative to the verifier, and  orders 
          actually verified by the verifier.  If this  comparison 
          reveals that  any of  the  unverified orders  were  the 
          result of noncompliance with Commission rules,  Verizon 
          agrees to further audit  the verifier's operations  and 
          implement necessary corrective measures. 

While this  Consent  Decree  is  in  effect,  Verizon  agrees  to 
maintain and make available to  the Bureau, on a quarterly  basis 
and within 14 days of the receipt of any specific written request 
from the Bureau, business  records demonstrating compliance  with 
the terms and provisions of this Consent Decree.  

In light of  the covenants  and representations  in this  Consent 
Decree, and in light of the fact that Verizon brought this matter 
voluntarily to  the  Bureau's  attention, the  Bureau  agrees  to 
terminate its investigation into  possible violations of  section 
64.1120(a)(1)(ii) of  Commission  rules in  connection  with  the 
facts specified above,  without any finding  of liability on  the 
part of Verizon.  

Nothing in this Consent Decree shall prevent the Commission  from 
adjudicating complaints  against Verizon  or its  affiliates  for 
alleged misconduct regarding unauthorized PIC conversions or  for 
any other  type of  alleged misconduct  regardless of  when  such 
misconduct took place, or from instituting new investigations  or 
enforcement proceedings against Verizon  in the event of  alleged 
future misconduct.  If such enforcement proceeding is  initiated, 
Verizon's earlier conduct as set  out in this Consent Decree  may 
be adduced,  but  not  for  the  purpose  of  assessing  monetary 
forfeitures.

This Consent Decree is for  settlement purposes only and  Verizon 
does not admit  any liability for  violating Commission rules  in 
connection with the matters that are the subject of this  Consent 
Decree. 

The Commission expressly  reserves the right  to investigate  and 
take enforcement action against  Verizon if the Commission  staff 
receives consumer complaints or other information indicating that 
Verizon may have violated section  258 of the Communications  Act 
of 1934, as amended,  (Act) and the  Commission rules and  orders 
governing PIC conversions by  failing to obtain authorization  to 
effect the  PIC changes  that  are the  subject of  this  Consent 
Decree.  Such  enforcement  action  may include,  inter  alia,  a 
monetary forfeiture pursuant to Section 503(b) of the Act. 

The Parties agree that any  provision of the Consent Decree  that 
conflicts with  any  subsequent  rule or  order  adopted  by  the 
Commission will be superseded by such Commission rule or order. 

The Parties agree that this  Consent Decree shall expire  twenty-
four (24) months from the release date of the Order adopting this 
Consent Decree.   Verizon  shall issue  a  report to  the  Bureau 
within 60  days from  the release  date demonstrating  compliance 
with the terms and provisions herein.  

This Consent Decree may be signed in counterparts.





For the Enforcement Bureau,                  For  Bell   Atlantic 
Communications, Inc.
Federal Communications Commission            


________________________________        ________________________
David H. Solomon                        Maura Breen
Chief                                   Group President - Verizon 
Long Distance                           


_______________________________         ________________________
Date                               Date










_________________________

1    Letters from Marie T. Breslin, Director Federal Regulatory, 
Verizon Communications, to Catherine W. Seidel, Chief, 
Telecommunications Consumers Division, Enforcement Bureau, 
F.C.C., File No. EB-00-TC-053 (July 5, 2000 and August 16, 2000).