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                                   Before the

                       Federal Communications Commission

                             Washington, D.C. 20554


                                             )                               
                                                                             
     In the Matter of                        )                               
                                                 File No. EB-06-IH-0902      
     Compass, Inc. d/b/a Compass Global,     )                               
     Inc. f/k/a Forva, Inc.                      NAL/Acct. No. 200732080006  
                                             )                               
     Apparent Liability for Forfeiture           FRN No. 0010611416          
                                             )                               
                                                                             
                                             )                               



                          NOTICE OF APPARENT LIABILITY

                            FOR FORFEITURE AND ORDER

   Adopted: December 22, 2006   Released: December 27, 2006

   By the Commission:

   I. INTRODUCTION

    1. In this Notice of Apparent Liability for Forfeiture ("NAL"), we find
       that Compass, Inc., d/b/a Compass Global, Inc. ("Compass Global"), has
       apparently failed to meet its statutory and regulatory obligations
       related to payphone compensation. Based upon our review of the facts
       and circumstances in this matter, we find that Compass Global is
       apparently liable for a total forfeiture of $466,000.

    2. Specifically, as discussed in detail below, we find that Compass
       Global has apparently violated: (1) sections 64.1310(a)(1) and
       64.1320(c)(1) of the Commission's rules, by willfully and repeatedly
       failing to establish, on a timely basis, a call tracking system that
       accurately tracks coinless access code or subscriber toll-free
       payphone calls to completion; (2) section 64.1320 of the rules, by
       willfully and repeatedly failing to have its call tracking system
       audited, to file a System Audit Report, or to comply with any of the
       Commission's audit-related requirements in the payphone rules; (3)
       sections 64.1300 and 64.1310(a)(2) of the rules, by willfully and
       repeatedly failing to compensate payphone service providers ("PSPs")
       for each completed payphone call; (4) section 64.1310(a)(4) of the
       rules, by willfully and repeatedly failing to provide to PSPs call
       data reports that satisfy the Commission's requirements; and (5)
       section 64.1310(a)(3) of the rules, by willfully and repeatedly
       failing to make available to PSPs a sworn statement from its Chief
       Financial Officer certifying payment accuracy and completeness. In
       addition, we find that Compass Global apparently violated a Commission
       order by willfully failing to respond on a timely basis to a directive
       of the Enforcement Bureau to provide certain information and
       documents.

    3. We order Compass Global to submit a report within thirty (30) days,
       either as part of its response to this NAL or separately. Compass
       Global's report must be supported by a sworn statement or declaration
       under penalty of perjury of a corporate officer, and must set forth in
       detail its plan to come into compliance promptly with the relevant
       payphone compensation rules discussed herein. We also order Compass
       Global to correct its past failures by having its call tracking system
       audited in compliance with Commission rules, by compensating each PSP
       for each payphone call it has completed and for which payment was
       already due, by filing with each PSP any overdue call data reports for
       payphone calls it has completed, and for providing each PSP any
       overdue statements of an officer certifying payment accuracy and
       completeness.

   II. BACKGROUND

   A. Payphone Compensation Regime

    4. In the Telecommunications Act of 1996, Congress added section 276,
       captioned "Provision of Payphone Service," to the Communications Act
       of 1934, as amended (the "Act"). Section 276(b) directed the
       Commission to adopt implementing regulations "[i]n order to promote
       competition among payphone service providers and promote the
       widespread deployment of payphone services to the benefit of the
       general public." In particular, section 276(b)(1) directed the
       Commission to "establish a per call compensation plan to ensure that
       all payphone service providers are fairly compensated for each and
       every completed intrastate and interstate call using their payphone."

    5. The Commission adopted its current rules in 2003, with some
       modifications on reconsideration in 2004, and they became effective on
       July 1, 2004. As envisioned in section 276, the rules govern the
       manner in which a PSP is compensated for a "subscriber toll-free
       call," (e.g., 800-FLOWERS), and a "coinless access code call," (e.g.,
       800-CALL-ATT).

    6. As a general matter, the rules require "Completing Carriers" to
       compensate PSPs for completed payphone calls at a rate agreed upon by
       contract," or in the absence of such an agreement, "at a per-call rate
       of $.494." A "Completing Carrier" is defined as "a long distance
       carrier or switch-based long distance reseller that completes a
       coinless access code or subscriber toll-free payphone call or a local
       exchange carrier that completes a local, coinless access code or
       subscriber toll-free payphone call." In other words, a Completing
       Carrier is a facilities-based long distance carrier, including a
       switch-based reseller ("SBR"), or a local exchange carrier that
       completes a toll-free payphone call. The Commission imposed the
       compensation obligation on Completing Carriers and SBRs because they
       "are the primary economic beneficiaries of coinless payphone calls
       transferred to their switch and because they possess the most accurate
       call completion information for such calls."

    7. To ensure that Completing Carriers compensate PSPs for each and every
       completed payphone call, a Completing Carrier must establish a call
       tracking system that (among other requirements) accurately tracks all
       toll-free payphone calls to completion. The deadline for establishing
       such a call tracking system was July 1, 2004.

    8. As an additional safeguard, the call tracking system must be audited
       and verified to comply with the Commission's defined requirements. A
       "System Audit Report" regarding the Completing Carrier's compliance
       with the call tracking system requirements must conform to certain
       standards, and was to be filed with the Commission, PSPs, and
       Intermediate Carriers by the effective date of the rules. At the same
       time it filed its System Audit Report, a Completing Carrier was also
       required to file a statement that includes its name, as well as the
       name, address, and phone number of the persons responsible for
       handling its payphone compensation and for resolving disputes with
       PSPs; any change must be updated within sixty days of the change. The
       call tracking system must be audited, and corresponding reports must
       be filed, at annual intervals thereafter. Completing carriers must
       permit PSPs to inspect documents, including workpapers, underlying a
       System Audit Report.

    9. Central to implementing the core and express requirement of section
       276(b), the rules require each Competing Carrier, on a quarterly
       basis, to compensate all PSPs for each completed coinless access code
       or subscriber toll-free payphone call. To ensure that the payment
       tendered is accurate and complete, Completing Carriers must, on a
       quarterly basis, submit to each PSP a call data report that contains
       certain information about the calls the Completing Carrier completed
       from that PSP's payphone(s) during the quarter. Each Completing
       Carrier also must, on a quarterly basis, provide a sworn statement of
       its Chief Financial Officer certifying that the compensation paid for
       a quarter is accurate and complete.

   10. As an additional measure to ensure that all payphone call activity is
       traced and accounted for, the Commission's rules also impose
       requirements on carriers that carry payphone traffic but do not
       themselves complete those calls. An "Intermediate Carrier" is defined
       as a "facilities-based long distance carrier that switches payphone
       calls to other facilities-based long distance carriers." An
       Intermediate Carrier also must, on a quarterly basis, submit a call
       data report to each PSP that contains certain information about the
       calls that the Intermediate Carrier switched to other long distance
       carriers. The quarterly reports provided by Intermediate Carriers, if
       accurate and complete, help PSPs ensure that they are getting
       appropriate compensation from Completing Carriers.

   11. The current payphone compensation regime thus is an interdependent one
       that relies on the cooperation of Completing and Intermediate Carriers
       with PSPs to ensure that the goals of section 276 are realized. In
       adopting its current rules, the Commission expressly warned that
       noncompliance could result in "substantial forfeitures," and that
       egregious cases could lead to "an Order to Show Cause why we should
       not revoke a[n] SBR's section 214 authority, and possibly bar the
       company's principals from participation in interstate
       telecommunications business activities without first obtaining
       explicit permission from the Commission." In a recent Public Notice,
       we again warned carriers about the consequences of noncompliance,
       stating that we "reiterate that the Commission will not hesitate to
       take enforcement action, including forfeitures, should Completing
       Carriers and Intermediate Carriers fail to comply with their
       compensation and reporting obligations under the payphone rules."
       Today's action against Compass Global is the first enforcement action
       the Commission will take to address noncompliance with the payphone
       compensation rules. We intend it to serve as an example of the
       Commission's resolve to fully enforce compliance with its payphone
       compensation rules.

    B.  Compass Global and the FCC Investigation

   12. Compass Global is a privately held New Jersey-based telecommunications
       provider that describes itself as "predominantly a switch based
       international wholesale reseller." It began completing "long distance
       subscriber toll free calls" in August 2003.

   13. In 2005, after the current payphone rules had been in effect for a
       number of months, Commission staff became concerned about potential
       noncompliance of certain carriers with the payphone rules. The
       Commission's Enforcement Bureau ("Bureau") initiated investigations of
       a number of carriers.

   14. On March 6, 2006 the Bureau sent Compass Global a Letter of Inquiry
       ("LOI") seeking certain documents and information related to the
       company's compliance with the payphone rules. The LOI directed Compass
       Global, within 30 days, to submit (among other things) a sworn written
       response to a series of questions relating to its apparent failure to
       comply with the payphone rules. Compass Global did not respond in any
       way within the applicable time period. On April 19, 2006, Bureau staff
       contacted Compass Global by telephone, and its principal stated that
       the company had never received the LOI. Later that same day, the
       Bureau reissued the LOI to Compass Global. After receipt, Compass
       Global's principal contacted Bureau staff by telephone and reported
       that the company had, in fact, received the March 6 LOI, but had set
       it aside to address other priorities. Bureau staff then sent Compass
       Global a letter on April 20, 2006 noting this course of events,
       reminding the company that "failure to respond to an LOI in and of
       itself constitutes a violation of the Act and the Commission's rules,"
       and stating that "failure to respond to the March 6, 2006 LOI has
       already exposed [Compass Global] to potential enforcement action,
       including a forfeiture." On May 6, 2006, Compass Global responded
       fully to the LOI.

   15. As explained below, Compass Global's LOI Response indicates that the
       company is a Completing Carrier for payphone calls; that it has, after
       nearly three years of service, only recently established a call
       tracking system that reliably tracks calls to completion; that it has
       not engaged any third party auditor or filed initial or annual audit
       reports or otherwise complied with any of the Commission's audit
       requirements; that it has made only partial compensation to the PSPs
       for which it has completed the highest volume of calls, and has made
       no compensation whatsoever to other PSPs; that it has failed to submit
       to each PSP the quarterly call data reports required by the
       Commission's rules; and that it has never provided a sworn statement
       of an officer certifying to payment accuracy and completeness.

    C. Forfeiture Authority

   16. Under section 503(b)(1)(B) of the Act, any person who is determined by
       the Commission to have willfully or repeatedly failed to comply with
       any provision of the Act or any rule, regulation, or order issued by
       the Commission shall be liable to the United States for a forfeiture
       penalty. To impose such a forfeiture penalty, the Commission must
       issue a notice of apparent liability, the notice must be received, and
       the person against whom the notice has been issued must have an
       opportunity to show, in writing, why no such forfeiture penalty should
       be imposed. The Commission will then issue a forfeiture order if it
       finds by a preponderance of the evidence that the person has violated
       the Act or a Commission rule.

    1. For the apparent violations in this case, section 503(b)(2)(B) of the
       Act authorizes the Commission to assess a forfeiture of up to $130,000
       for each violation or each day of a continuing violation, up to a
       statutory maximum of $1.325 million for a single act or failure to
       act. In determining the appropriate forfeiture amount, we consider the
       factors enumerated in section 503(b)(2)(D) of the Act, including "the
       nature, circumstances, extent and gravity of the violation, and, with
       respect to the violator, the degree of culpability, any history of
       prior offenses, ability to pay, and such other matters as justice may
       require."

   17. Under section 503(b)(6) of the Act, we may propose forfeitures only
       for apparent violations that accrued within one year of the date of
       the NAL. Nevertheless, section 503 does not bar us from assessing
       whether conduct occurring prior to that time period apparently
       violated the Act or our rules in determining the appropriate
       forfeiture amount for those violations within the statute of
       limitations.

   III.  DISCUSSION

   18. As explained below, we find that Compass Global has apparently failed
       to comply with our payphone compensation rules. Based on its conduct,
       we find that Compass Global is apparently liable for a total
       forfeiture of $466,000.

    A. Compass Global's Payphone Rule and Other Violations

    2. As a preliminary matter, we conclude that Compass Global is a
       Completing Carrier under the Commission's rules - indeed, Compass
       Global acknowledges as much. In its LOI Response, Compass Global
       states that it is "predominantly a switch based international
       wholesale reseller," and that it completes "long distance subscriber
       toll free calls." Compass Global further states that it began
       completing such calls in August 2003, and that it has continuously
       completed these types of call since that time. As a result, Compass
       Global, as a Completing Carrier, is required to establish a call
       tracking system; to have that system audited in compliance with the
       Commission's rules; to compensate PSPs, on a quarterly basis, for each
       payphone call it completes; to file with PSPs, on a quarterly basis,
       call data reports for the payphone calls it completes; and to provide
       PSPs, on a quarterly basis, with a statement of its Chief Financial
       Officer certifying payment accuracy and completeness. As set forth in
       detail below, Compass Global has failed to satisfy any of these
       requirements.

   1. Failure to Establish Call Tracking System

    3. We first conclude that Compass Global has apparently violated sections
       64.1310(a)(1) and 64.1320(c)(1) of the Commission's rules by failing
       to establish, on a timely basis, a call tracking system that
       accurately tracks calls to completion. Compass Global has created a
       call tracking system, but admits that the system was not reliable
       until very recently. In its LOI Response, Compass Global explained
       that it "began creating the Toll Free Call Tracking System in October
       of 2004," and that the software evolved through different phases
       "until it reached the final version completed just last month" (April
       2006). Compass Global further stated that the software "has only
       recently been completed to the point where the company is confident
       with the software's accuracy," and that previously "Compass Global did
       not have a Call Tracking Software in place that was sufficiently
       reliable or accurate enough to provide firm data to payphone service
       providers in the form of a report."

    4. Compass Global's conduct falls far short of the Commission's
       requirement to establish an accurate call tracking system by July 1,
       2004. Indeed, Compass Global did not even begin to create a call
       tracking system until October 2004, and in the absence of filing the
       Commission-required audit of the call tracking system (discussed
       separately below) it is still not clear that Compass Global has
       fulfilled its obligation. As a result, we find that Compass Global
       apparently violated sections 64.1310(a)(1) and 64.1320(c)(1) of the
       Commission's rules by failing to establish by July 1, 2004 a call
       tracking system that accurately tracks coinless access code or
       subscriber toll-free payphone calls to completion, and that it has
       presented no reliable evidence that its violation does not continue to
       the present.

   2. Failure to Satisfy Audit-Related Requirements

    5. We next conclude that Compass Global has apparently violated each
       provision of section 64.1320 of our rules by failing to satisfy any of
       the audit-related requirements for its call tracking system. Section
       64.1320 sets forth a comprehensive, detailed scheme for auditing the
       call tracking system. As a Completing Carrier, Compass Global had an
       obligation to comply with all of these audit-related requirements. To
       date, it has complied with none. In its LOI Response, Compass Global
       stated that due to the difficulties with its call tracking system,
       "the company has not yet finalized an agreement with an independent,
       third-party auditor to verify the accuracy and reliability of its call
       tracking system." Nearly two years after Compass Global was required
       to have its call tracking system audited and to have filed the System
       Audit Report that addressed specific requirements, Compass Global
       explains that "the company is researching such entities, and has
       [been] engaging in conversations with several entities to perform this
       audit." To date, Compass Global has not filed its System Audit Report
       with the Commission - or presumably with the PSPs for which it
       completes calls, or the long distance carriers from which it receives
       payphone calls. As a result, we conclude that Compass Global has
       apparently violated section 64.1320 by failing to satisfy any
       audit-related requirements for its call tracking system, and that its
       violation continues to this day.

   3. Failure to Compensate PSPs for Each Completed Call

    6. We further conclude that Compass Global has apparently violated
       sections 64.1300 and section 64.1310(a)(2) of our rules by willfully
       and repeatedly failing to compensate PSPs for each toll-free payphone
       call that it has completed. Compass Global acknowledges as much. Due
       to problems with the accuracy of its call tracking system, Compass
       Global stated as of the date of its LOI Response that it had only made
       "good faith estimated payments" of approximately $125,000 to PSPs that
       Compass Global says are associated with 90% of the toll-free payphone
       calls it completed. Compass Global has also stated, however, that
       these PSPs have submitted claims for additional compensation, that
       "[t]he company is currently behind by approximately one or two
       quarters in those payments," and that it is "in the process of making
       payments . . . to these largest providers for the remaining balances
       just as soon as it possibly can." With respect to the PSPs associated
       with smaller call volume, Compass Global plainly admits that "the
       company has not yet made payments to these service providers." These
       admissions establish that Compass Global has not compensated each PSP
       for each completed call. Indeed, it appears that the degree of Compass
       Global's misconduct may be greater than it has described. Call data
       provided with Compass Global's LOI Response suggests the traffic
       carried by the two carriers to which it has made occasional and
       partial payment does not appear to comprise 90% of traffic for which
       Compass Global owes compensation, and payment to these and the other
       carriers appears to be much more than "a quarter or two" overdue. In
       light of Compass Global's LOI Response, we find that Compass Global
       has apparently violated sections 64.1300 and 64.1310(a)(2) of the
       Commission's rules by failing to compensate each PSP for each
       toll-free payphone call it completed, since the July 1, 2004 effective
       date of the current rules.

   4. Failure to Provide Quarterly Reports

    7. Compass Global has also apparently violated section 64.1320(a)(4) of
       our rules by willfully and repeatedly failing to submit call data
       reports to PSPs that satisfy the Commission's requirements. By its own
       admission, Compass Global has not complied with the quarterly
       reporting requirement: in its LOI response, the company stated that
       "Compass Global has not made available or provided to payphone service
       providers the reports of completed calls required by section
       64.1310(a)(4) of the Commission's rules." The company explained that
       it has not provided these reports due to the problems associated with
       the accuracy and reliability of its call tracking system, but that now
       it "is in the process of providing these payphone service providers
       with these reports, as well as CDRs (call detail records) for all
       completed calls originated from the ANI's they identified as belonging
       to them." Thus, we find that Compass Global has apparently violated
       section 64.1320(a)(4) of our rules by failing to submit to each PSP
       call data reports that satisfy the Commission's requirements since the
       effective date of the rules, and that its violation continues to this
       day.

   5. Failure to Provide CFO Sworn Statement

    8. Compass Global has also apparently violated section 64.1310(a)(3) of
       the Commission's rules by willfully and repeatedly failing to provide
       to PSPs a sworn statement by its Chief Financial Officer (CFO)
       certifying payment accuracy and completeness. As with Compass Global's
       other apparent violations, there can be no dispute, and Compass Global
       itself acknowledges, that the company failed to comply with the
       requirement to provide a sworn statement certifying payment accuracy
       and completeness. In its LOI Response, Compass Global admits that
       "[t]he company has not provided to all payphone service provider [sic]
       a sworn statement from the company's Chief Financial Officer that the
       amount for that quarter is accurate and is based on 100% of all
       completed calls that originated from that payphone service provider's
       payphones." As with its other violations, Compass Global explains that
       its failure to comply with this requirement is a result of its
       inadequate call tracking system. We find that Compass Global has
       apparently violated section 64.1310(a)(3) by failing to submit to any
       PSP a sworn statement certifying that the payment is accurate and
       based on 100% of calls that Compass Global completed from that PSP's
       payphones.

   6. Failure to Provide Timely Response

    9. Finally, we also conclude that Compass Global has apparently violated
       a Commission order by willfully failing to respond on a timely basis
       to a directive of the Enforcement Bureau to provide certain documents
       and information. As indicated above, Compass Global failed to respond
       in any way to the Bureau's March 6 LOI within the time frame allotted.
       When the Bureau had not received a response several days after that
       time frame closed, staff contacted Compass Global. The company denied
       having received the LOI, and staff directed another LOI to it again on
       April 19, 2006. After receiving the LOI again, Compass Global
       acknowledged that it had actually received the March 6 LOI, but had
       decided to prioritize other matters over responding to the LOI. It was
       only on May 6, 2006, nearly one month after the original due date,
       that Compass Global responded to the LOI. As a result, we find that
       Compass Global has apparently violated a Commission order by willfully
       failing to respond on a timely basis to the Bureau's March 6 LOI,
       which directed it to provide certain documents and information within
       thirty days.

    B. Proposed Forfeiture

   10. Although the Commission has acted on numerous formal complaints in the
       payphone compensation arena, we have not issued an NAL against a
       carrier for a violation of our current payphone compensation rules,
       which became effective July 1, 2004. As such, in calculating the
       appropriate penalty for Compass Global's violations of these rules, we
       consider the factors set forth in section 503(b)(2)(D), and our
       forfeiture guidelines.

   11. The misconduct for which the forfeiture guidelines establish a base
       forfeiture that most closely approximates Compass Global's is failure
       to file required forms or information. The base forfeiture is $3,000
       for this conduct. The guidelines explicitly state, however, that
       "[t]he Commission and its staff retain the discretion to issue a
       higher or lower forfeiture than provided in the guidelines." The
       guidelines explicitly identify several factors to adjust a base
       forfeiture upward, and among these are "egregious misconduct,"
       "substantial harm," "substantial economic gain," and "repeated or
       continuous violation." When it adopted its current payphone rules, the
       Commission explicitly warned that it would consider aggravating
       factors and fully utilize its enforcement power in penalizing
       violations: "We note that the current base penalty for failure to file
       required forms or information with the Commission is $3,000; however,
       we have the discretion to impose substantially higher forfeitures
       based on the factors listed in our rules." The Commission explained
       that "late payment or non-payment to PSPs could result in substantial
       forfeitures: up to $120,000 for a single non-payment and up to $1.2
       million for a continuing violation." (These figures were then the
       statutory maximums.) The Commission further warned that "[i]n
       egregious cases, we may issue an Order to Show Cause why we should not
       revoke a SBR's section 214 authority, and possibly bar the company's
       principals from participating in interstate telecommunications
       business activities without first obtaining explicit permission from
       the Commission." In short, the Commission clearly indicated that it
       would not tolerate noncompliance with its rules, and would use the
       full range of its enforcement powers to penalize violators.

   12. Although we acknowledge and encourage Compass Global's reported
       efforts to implement its tracking system and settle past-due accounts
       with its PSPs,  we find that each of Compass Global's violations of
       our payphone rules discussed above - failure to establish a call
       tracking system, failure to comply with audit-related requirements,
       failure to compensate PSPs for each and every completed call, failure
       to submit call data reports to PSPs, and failure to submit a sworn
       statement attesting to the compeleteness of payment - warrants upward
       adjustment from the base forfeiture of $3,000. Our conclusion is based
       on the determination that each of the violations involves egregious
       misconduct, has been continuous or repeated since our current payphone
       rules became effective, and involves substantial harm to each of the
       PSPs who have been deprived of compensation from Compass Global. The
       rules required Compass Global to have established a call tracking
       system, to have that system audited and to have filed a System Audit
       Report in accordance with certain defined standards, all by no later
       than July 1, 2004. As discussed above, Compass Global only recently
       established a call tracking system that appears to be reliable, and
       has not yet subjected that system to audit. In addition, although
       Compass Global states that it has paid the PSPs that deliver the
       highest call volume to the company, it acknowledges that it is behind
       in its payments to those PSPs, and has never paid the PSPs that
       deliver smaller call volume. Compass Global further admits that it has
       failed to submit to each PSP the quarterly call data reports required
       by the Commission's rules, and has never made available a sworn
       statement attesting to the accuracy of the payments it has tendered.
       As a result, Compass Global's violations of the payphone rules are
       egregious, have been continuous or repeated, and have caused
       substantial harm to PSPs. A substantial upward adjustment of the
       forfeiture amounts is therefore warranted.

   13. As explained below, the rules Compass Global apparently violated are
       fundamental and necessary to the Commission's payphone compensation
       regime, which rests on intercarrier cooperation. Failures to comply
       with these requirements thwart realization of the statutory command of
       section 276 of the Act that PSPs be compensated "for each and every
       completed intrastate and interstate call using their payphone." Thus,
       we propose base forfeiture amounts consistent with the overarching
       import of the rule violations. We also find that the forfeitures
       proposed are reasonable when compared to similar forfeitures in our
       Universal Service Fund ("USF") enforcement actions. Finally, we warn
       carriers that we may impose harsher fines in future enforcement
       actions if we determine that those proposed here are insufficient to
       deter others from engaging in the same misconduct.

   1. Failure to Establish Call Tracking System

   14. We find that an appropriate penalty for the failure to establish, on a
       timely basis, a call tracking system that accurately tracks calls to
       completion is $50,000. This requirement is a fundamental and necessary
       precursor to compliance with the Commission's compensation and other
       payphone requirements; indeed the entire payphone compensation regime
       rests on inter-carrier compliance and cooperation. The Commission's
       rules do not require carriers to report to, or even file with, the
       Commission; instead, they provide to each other the information and
       compensation required by our rules. Failure to establish an accurate
       call tracking system on a timely basis is , thus, a serious
       dereliction of a Completing Carrier's responsibilities because it
       prevents the carrier from fulfilling any of the other payphone
       requirements, including the core statutory requirement of compensating
       PSPs for each and every payphone call the carrier completes. Indeed,
       as Compass Global itself explains, it is the failure to establish an
       accurate and reliable call tracking system that has rendered it
       difficult if not impossible for the company to comply with any of the
       other payphone requirements. As a result, this failure should be
       associated with a significant penalty.

   2. Failure to Satisfy Audit-Related Requirements

   15. We also find that $50,000 is an appropriate penalty for Compass
       Global's failure to have its call tracking system audited in
       compliance with the requirements of section 64.1320. Failure to
       complete an audit in conformity with section 64.1320 is another
       element of the fundamental requirements in the payphone rules that are
       designed to ensure the accuracy and reliability of a Completing
       Carrier's call tracking system (and, consequently, the amount of
       compensation paid to each PSP). Although this $50,000 fine relates to
       Compass Global's failure to comply with any provision of section
       64.1320 in the Commission's rules, we warn carriers that compliance
       with some but not all of the provisions of that section will still
       result in forfeitures. For example, a Completing Carrier that has had
       its call tracking system audited and filed a System Audit Report but
       fails to file a statement identifying the person responsible for
       handling its payphone compensation - or fails to update the statement
       if any change occurs - violates section 64.1320(e) and is potentially
       subject to forfeiture. Likewise, a Completing Carrier that fails to
       engage an auditor to evaluate its call tracking system annually
       violates section 64.1320(f) and is also subject to forfeiture. All
       components of the audit requirements are critical and must be
       satisfied. We also find that a $50,000 proposed forfeiture for Compass
       Global's failure to establish a call tracking system in a timely
       fashion and a $50,000 proposed forfeiture for its failure to have the
       call tracking system audited in compliance with Commission
       requirements are appropriate penalties, particularly when compared to
       the Commission's treatment of a carrier's failure to register in our
       USF enforcement cases, given that these specific payphone rules, like
       a carrier's failure to register, impose such fundamental requirements.

   3. Failure to Compensate PSPs for Each Completed Call

   16. With respect to the failure of a Completing Carrier to compensate PSPs
       for each and every toll-free payphone call it completes, we find an
       appropriate penalty to be $50,000 per quarter. A Completing Carrier's
       failure to pay PSPs violates the fundamental goal of section 276 of
       the Act that all PSPs be "fairly compensated for each and every
       completed intrastate and interstate call using their payphone," just
       as a carrier's failure to contribute to the USF violates the
       requirement in section 254(d) that "[e]very telecommunications carrier
       that provides interstate services shall contribute, on an equitable
       and nondiscriminatory basis, to the specific, predictable, and
       sufficient mechanisms established by the Commission." We also note
       that this violation is similar to the failure to contribute to the
       USF. We therefore propose a forfeiture of $50,000 for each of the four
       quarters within the past twelve months that Compass Global failed to
       compensate PSPs for each and every toll-free payphone call it
       completed, for a total forfeiture of $200,000.

   4. Failure to Provide Call Data Reports

   17. We find that an appropriate penalty for Compass Global's failure to
       provide call data reports that satisfy the Commission's requirements
       is $20,000 per quarter. A Completing Carrier's provision of call data
       reports is an important obligation, the failure of which is
       correspondingly important. This violation is similar to the failure to
       file Telecommunications Reporting Worksheets in the USF context, which
       results in a proposed forfeiture of $50,000 for each missed filing
       with the Commission. The impact of the failure to file the call data
       reports upon which payphone compensation is based, however, is less
       than the failure to file Worksheets, on which a carrier's contribution
       to multiple regulatory programs is based. In addition, other
       requirements in the payphone context, such as the audit, serve as
       additional safeguards to ensure the accuracy of reports. We therefore
       propose a forfeiture of $20,000 for each quarter within the past
       twelve months that Compass Global failed to submit call data reports
       to PSPs. The total proposed forfeiture is therefore $80,000.

   5. Failure to Provide CFO Sworn Statement

   18. We likewise find that an appropriate penalty for Compass Global's
       failure to provide a sworn statement of an officer attesting to the
       accuracy of the compensation it tenders to PSPs is $20,000 per
       violation. This failure is similar to the failure to file a
       Telecommunications Reporting Worksheet that is accurate and complete
       in all material respects. The Commission has assessed a $50,000
       penalty for the misreporting by a carrier of its revenues on a
       Worksheet, which as noted above is the same penalty as the Commission
       has assessed for failure to file a Worksheet at all. The penalty for
       failure to file the sworn statement pursuant to the payphone rules,
       however, should be less than the failure to file an accurate
       Worksheet, given that failure to file the sworn statement impacts only
       PSPs rather than an industry-wide fund like the USF. In addition,
       there are other requirements in the payphone context, such as the call
       data reports, that serve to reinforce the accuracy of the payment. We
       therefore propose a penalty of $20,000 for each of the four quarters
       within the past twelve months that Compass Global failed to provide
       the sworn statement of an officer attesting to the accuracy of the
       compensation it tendered to PSPs. The total proposed forfeiture is
       therefore $80,000.

   6. Failure to Provide Timely Response

   19. Finally, we find that Compass Global's failure to respond to the
       Bureau's March 6, 2006 LOI warrants a penalty of $6,000. The base
       forfeiture for failure to respond to Commission communications is
       $4,000. We have imposed higher penalties, however, for failure to
       respond to LOIs at all ($20,000), and for incomplete and untimely
       responses to LOIs (e.g., $8,000). Since Compass Global ultimately
       responded in full to the LOI when the Bureau reissued it, we find its
       conduct less egregious than the failure to respond at all or both
       incompletely and untimely, and therefore propose a smaller upward
       adjustment of $2,000 to the base forfeiture of $4,000 for failure to
       respond to Commission communications.

   IV. CONCLUSION

   20. In light of the seriousness, duration and scope of the apparent
       violations, we find that a proposed forfeiture in the amount of
       $466,000 is warranted. This proposed forfeiture amount includes: (1)
       $50,000 for failure, in apparent violation of sections 64.1310(a)(1)
       and 64.1320(c)(1) of the Commission's rules, to establish, on a timely
       basis, a call tracking system that accurately tracks calls to
       completion; (2) $50,000 for failure, in apparent violation of section
       64.1320 of the rules, to undergo a system audit and comply with other
       audit-related requirements; (3) $200,000 for failure, in apparent
       violation of section 64.1310(a)(2) of the rules, to compensate PSPs
       for each and every payphone call completed for the four quarters
       within the last year; (4) $80,000 for failure, in apparent violation
       of section 64.1310(a)(4) of the rules, to submit to each PSP the
       required call data reports for the four quarters within the last year;
       (5) $80,000 for failure, in apparent violation of section
       64.1310(a)(3), to make available sworn statements from an officer
       attesting to accuracy of payments tendered to PSPs for the four
       quarters within the last year, and (6) $6,000 for failure to respond
       to the Bureau's March 6 LOI.

   19. We caution that additional violations of the Act or the Commission's
       rules could subject Compass Global to further enforcement action. Such
       action could take the form of higher monetary forfeitures and/or
       possible revocation of Compass Global's operating authority, including
       disqualification of Compass Global's principals from the provision of
       any interstate common carrier services without the prior consent of
       the Commission. In addition, we note that, to the extent Compass
       Global is found to be delinquent on any debt owed to the Commission,
       the Commission will not act on, and may dismiss, any application or
       request for authorization filed by Compass Global, in accordance with
       the agency's "red light" rules. We order Compass Global to submit
       within thirty (30) days, either as part of its response to this NAL or
       separately, a report, supported by a sworn statement or declaration
       under penalty of perjury of a corporate officer, stating its plan to
       come into compliance promptly with the relevant payment and reporting
       rules discussed herein. We also order Compass Global to correct its
       past failures by having its call tracking system audited in compliance
       with Commission rules, by compensating each PSP for each payphone call
       it has completed and for which payment was already due, by filing with
       each PSP any overdue call data reports for payphone calls it has
       completed, and for providing each PSP any overdue statements of an
       officer certifying payment accuracy and completeness.

   V. ORDERING CLAUSES

   21. ACCORDINGLY, IT IS ORDERED THAT, pursuant to section 503(b) of the
       Communications Act of 1934, as amended, and section 1.80 of the
       Commission's rules, that Compass Global, Inc. is hereby NOTIFIED of
       its APPARENT LIABILITY FOR A FORFEITURE in the amount of $466,000 for
       willfully and repeatedly violating the Act and the Commission's rules.

   22. IT IS FURTHER ORDERED THAT, pursuant to section 1.80 of the
       Commission's Rules, within thirty days of the release date of this
       NOTICE OF APPARENT LIABILITY, Compass Global, Inc. SHALL PAY the full
       amount of the proposed forfeiture or SHALL FILE a written statement
       seeking reduction or cancellation of the proposed forfeiture.

   20. IT IS FURTHER ORDERED THAT, pursuant to section 4(i) of the Act, 47
       U.S.C. S 4(i), within thirty days of the release of this NOTICE OF
       APPARENT LIABILITY AND ORDER, Compass Global, Inc. SHALL SUBMIT a
       report, supported by a sworn statement or declaration under penalty of
       perjury by a corporate officer, stating its plan to come into
       compliance promptly with the payment and reporting rules discussed
       herein. Compass Global, Inc. also SHALL HAVE its call tracking system
       audited in compliance with Commission rules, SHALL PAY overdue
       compensation to PSPs, SHALL FILE overdue call reports to PSPs, and
       SHALL PROVIDE to PSPs overdue statements of an officer certifying
       payment accuracy and completeness.

   23. Payment of the forfeiture must be made by check or similar instrument,
       payable to the order of the Federal Communications Commission.  The
       payment must include the NAL/Acct. No. and FRN No. referenced above.
       Payment by check or money order may be mailed to Federal
       Communications Commission, P.O. Box 358340, Pittsburgh, PA
       15251-8340.  Payment by overnight mail may be sent to Mellon
       Bank /LB 358340, 500 Ross Street, Room 1540670, Pittsburgh, PA
       15251.  Payment by wire transfer may be made to ABA Number 043000261,
       receiving bank Mellon Bank, and account number 911-6229.

   24. The response, if any, to this NOTICE OF APPARENT LIABILITY must be
       mailed to William H. Davenport, Chief, Investigations and Hearings
       Division, Enforcement Bureau, Federal Communications Commission, 445
       12^th Street, S.W., Washington, D.C. 20554 and must include the
       NAL/Acct. No. referenced above.

   25. The Commission will not consider reducing or canceling a forfeiture in
       response to a claim of inability to pay unless the petitioner submits:
       (1) federal tax returns for the most recent three-year period; (2)
       financial statements prepared according to generally accepted
       accounting practices (GAAP); or (3) some other reliable and objective
       documentation that accurately reflects the petitioner's current
       financial status. Any claim of inability to pay must specifically
       identify the basis for the claim by reference to the financial
       documentation submitted.

   26. Requests for payment of the full amount of this NAL under an
       installment plan should be sent to: Federal Communications Commission,
       Deputy Chief Financial Officer, Room 1-A637, 445 12^th Street, S.W.,
       Washington, D.C. 20554.

   27. IT IS FURTHER ORDERED that a copy of this NOTICE OF APPARENT LIABILITY
       AND ORDER shall be sent by certified mail, return receipt requested,
       to Dean Cary, President/CEO, Compass Global, Inc., 50 Tice Blvd.,
       Woodcliff Lake, NJ 07677.

   FEDERAL COMMUNICATIONS COMMISSION

   Marlene H. Dortch

   Secretary

   47 C.F.R. SS 64.1310(a)(1), 64.1320(c)(1).

   47 C.F.R. S 64.1320.

   47 C.F.R. SS 64.1300, 64.1310(a)(2).

   47 C.F.R. 64.1310(a)(4).

   47 C.F.R. S 64.1310(a)(3).

   Telecommunications Act of 1996, Pub. L. No. 104-104, 110 Stat. 56 (1996).

   47 U.S.C. S 276.

   47 U.S.C. S 276. See Conf. Rep. No. 104-458 at 158. The Conference Report
   explains: "In place of the existing regulatory structure, the Commission
   is directed to establish a new system whereby all payphone service
   providers are fairly compensated for every interstate and intrastate call
   made using their payphones, including, for example, "toll-free" calls to
   subscribers to 800 and new 888 services and calls dialed by means of
   carrier access codes. In crafting implementing rules, the commission is
   not bound to adhere to existing mechanisms or procedures established for
   general regulatory purposes in other provisions of the Communications
   Act." The quoted language comes from the House amendment to the Senate
   bill. The Conference agreement indicates that Congress adopted the House
   provision with some changes.

   See Implementation of the Pay Telephone Reclassification and Compensation
   Provisions of the Telecommunications Act of 1996, Second Report and Order,
   18 FCC Rcd 19975 (2003), (subsequent history omitted) (Second Payphone
   Order). The Commission had earlier adopted different rules,
   Implementation of the Pay Telephone Reclassification and Compensation
   Provisions of the Telecommunications Act of 1996, Report and Order, 11 FCC
   Rcd 20541 (1996) (subsequent history omitted).

   See Implementation of the Pay Telephone Reclassification and Compensation
   Provisions of the Telecommunications Act of 1996, Order on
   Reconsideration, 19 FCC Rcd 21457 (2004) (subsequent history omitted).

   60 Fed. Reg. 26825 (May 14, 2004); 69 Fed. Reg. 71383 (Dec. 9, 2004).

   47 C.F.R. S 64.1300(b).

   47 C.F.R. S 64.1300(c).

   47 C.F.R. S 64.1300(a).

   Second Payphone Order, 18 FCC Rcd at 19988, P 26.

   47 C.F.R. SS 64.1310(a)(1), 64.1320(c)(1). Section 64.1320(c) sets forth
   nine specific requirements with which the call tracking system must
   comply, and for which an independent third-party auditor must verify
   compliance.

   The Commission's current rules became effective July 1, 2004. See supra at
   P 5. Because, as discussed below, the rules explicitly required a
   Completing Carrier to file an audit report regarding its compliance with
   section 64.1310(a)(1) by the effective date of the rules, a Completing
   Carrier needed to establish a call tracking system that satisfies the
   Commission's requirements by the effective date.

   47 C.F.R. SS 64.1320(a), 64.1320(c).

   47 C.F.R. SS 64.1320(b), 64.1320(d).

   47 C.F.R. S 64.1320(e).

   47 C.F.R. S 64.1320(f).

   47 C.F.R. S 64.1320(g).

   47 C.F.R. S 64.1310(a)(2).

   47 C.F.R. S 64.1320(a)(4). Each quarterly report must be in computer
   readable format and include: (1) a list of the coinless access code and
   subscriber toll-free calls dialed and completed by the Completing Carrier
   from the PSP's payphone, and the Automatic Number Identification (ANI) for
   each payphone; (2) the total volume of calls completed for each of these
   numbers; (3) the name, address, and phone number of the individuals
   responsible for handling the Completing Carrier's payphone compensation;
   and (4) the carrier identification code ("CIC") of all facilities-based
   long distance carriers that routed calls to the Completing Carrier,
   organized by access code and toll-free number.

   47 C.F.R. S 64.1320(a)(3). In lieu of providing such a statement to each
   PSP, a Completing Carrier may instead provide a single statement addressed
   to all PSPs to which compensation is tendered, and may electronically
   notify PSPs of the existence of the statement by either sending the report
   or posting it on the website of the Completing Carrier or a clearinghouse.
   Id.

   47 C.F.R. S 64.1310(b).

   47 C.F.R. S 64.1310(c). Each quarterly report must be in computer readable
   format and include: (1) a list of all facilities-based long distance
   carriers to which the Intermediate Carrier switched access code and
   toll-free calls dialed from the PSP's payphone; (2) a list of all access
   code and toll-free numbers dialed from each PSP's payphones that local
   exchange carriers delivered to the Intermediate Carrier and the
   Intermediate Carrier switched to the identified long distance carrier; (3)
   the total volume of calls switched to each of these numbers; and (4) the
   name, address, and phone number of the individuals for each identified
   long distance carrier who serves as the Intermediate Carrier's contact at
   the identified carrier. Id.

   Second Payphone Order, 18 FCC Rcd at 19998, P 44.

   Wireline Competition Bureau Reminds Carriers of Their Obligations Under
   the Payphone Compensation Rules, Public Notice, DA 06-1862, rel'd Sept.
   13, 2006.

   Letter from Dean Cary, President/CEO Compass Global, to Raelyn Tibayan
   Remy, Attorney, Investigations and Hearings Division, Enforcement Bureau,
   FCC, dated May 6, 2006, at 1 ("LOI Response").

   Id.

   Letter from Hilary S. DeNigro, Deputy Chief, Investigations and Hearings
   Division, Enforcement Bureau, FCC, to Dean Cary, President, Compass
   Global, Inc., dated March 6, 2006 ("LOI" or "March 6 LOI").

   Letter from Hillary S. DeNigro, Deputy Chief, Investigations & Hearings
   Division, Enforcement Bureau, FCC, to Dean Cary, President, Compass
   Global, Inc., dated April 19, 2006 ("April 19 LOI").

   Letter from Hillary S. DeNigro, Deputy Chief, Investigations and Hearings
   Division, Enforcement Bureau, FCC, to Dean Cary, President/CEO Compass
   Global, dated April 20, 2006.

   See LOI Response, supra note 30. This response was filed within the new
   time frame established in the April 19 LOI.

   Compass Global LOI Response at Inquiry 5.

   Id. at Inquiries 7, 8.

   Id. at Inquiry 8 b.

   Id. at Inquiry 13.

   Id. at Inquiry 9.

   Id. at Inquiry 13 b.

   47 U.S.C. S 503(b)(1)(B); 47 C.F.R. S 1.80(a)(1). Section 312(f)(1) of the
   Act defines willful as "the conscious and deliberate commission or
   omission of [any] act, irrespective of any intent to violate" the law. 47
   U.S.C. S 312(f)(1). The legislative history to section 312(f)(1) of the
   Act clarifies that this definition of willful applies to both sections 312
   and 503(b) of the Act, H.R. Rep. No. 97-765, 97^th Cong. 2d Sess. 51
   (1982), and the Commission has so interpreted the term in the section
   503(b) context. See, e.g., Application for Review of Southern California
   Broadcasting Co., Memorandum Opinion and Order, 6 FCC Rcd 4387, 4388
   (1991) ("Southern California Broadcasting Co."). The Commission may also
   assess a forfeiture for violations that are merely repeated, and not
   willful. See, e.g., Callais Cablevision, Inc., Grand Isle, Louisiana,
   Notice of Apparent Liability for Monetary Forfeiture, 16 FCC Rcd 1359
   (2001) (issuing a Notice of Apparent Liability for, inter alia, a cable
   television operator's repeated signal leakage).  "Repeated" means that the
   act was committed or omitted more than once, or lasts more than one day.
   Callais Cablevision, Inc., 16 FCC Rcd at 1362, P 9; Southern California
   Broadcasting Co., 6 FCC Rcd at 4388, P 5.

   47 U.S.C. S 503(b); 47 C.F.R. S 1.80(f).

   See, e.g., SBC Communications, Inc., Forfeiture Order, 17 FCC Rcd 7589,
   7591, P 4 (2002) (forfeiture paid).

   47 U.S.C. S 503(b)(2)(B); see also 47 C.F.R. S 1.80(b)(2).

   47 U.S.C. S 503(b)(2)(D); see also Forfeiture Policy Statement, 12 FCC Rcd
   at 17100, P 27; 47 C.F.R. S 1.80(b).

   47 U.S.C. S 503(b)(6)(B); see also 47 C.F.R. S 1.80(c)(3).

   See 47 C.F.R. S 1.80(b)(4).

   LOI Response to Inquiries 3, 4.

   LOI Response to Inquiry 6.

   47 C.F.R. SS 64.1310(a)(1), 64.1320(c)(1).

   47 C.F.R. S 64.1320(c).

   47 C.F.R. S 64.1310(a)(2).

   47 C.F.R. S 64.1310(a)(4).

   47 C.F.R. S 64.1310(a)(3).

   LOI Response to Inquiry 8.

   LOI Reponse to Inquiry 9.

   47 C.F.R. S 64.1320.

   See supra n.14.

   LOI Response to Inquiry 8.

   Id.

   See LOI Response to Inquiries 9 and 13.

   Id.

   LOI Response to Inquiry 13.

   LOI Response to Inquiry 13.

   As part of its LOI Response, Compass Global attached a chart that appears
   to show amounts due and payments made for the last two quarters of 2004
   and all four quarters of 2005 (no data for 2006). The chart suggests that
   Compass Global made at least partial payments to APCC in March and July
   2005, and to Verizon in September 2005. These two entities, of seven named
   by Compass Global, comprise some $376,000 due (before any payment), while
   the other five named, and some unnamed (set forth as "No ANI Ownership
   Information"), total some $181,000 due. See Compass Global LOI Response at
   Attachment. Thus it appears that the two entities to which some payment
   has been made account for about two thirds of the traffic for which
   Compass Global owes payphone compensation, and that the last time Compass
   Global made any payment was about a year ago.

   Since it filed its LOI Response, Compass Global has not provided any
   information indicating that it has made any additional payments to PSPs.
   Given the company's continuing obligation to produce additional
   information responsive to the LOI as it becomes available, see LOI at 3,
   the absence of any such additional information suggests that Compass
   Global's only payments to PSPs are those partial payments noted above, in
   March, July, and September 2005. In addition, in recent conversations
   between Bureau staff and Compass Global, the principal confirmed that the
   company had not made any payments other than those described in the LOI
   Response.

   LOI Response to Inquiry 9.

   Id. Since it filed its LOI Response, Compass Global has not provided any
   information indicating that it has submitted reports. Given the company's
   continuing obligation to produce additional information responsive to the
   LOI as it becomes available, see LOI at 3, the absence of any such
   additional information suggests that Compass Global still has not
   submitted any reports to PSPs. In a recent telephone conversation with
   staff, Compass Global's principal stated that the company has recently
   provided certain call data to some of its major PSPs, but did not
   characterize this data as the quarterly report required by our rules.

   LOI Response to Inquiry 13.

   See supra P 14.

   47 C.F.R. S 1.80 (b)(4), Note, Guidelines for Assessing Forfeitures.

   Id., Section II., Adjustment Criteria for Section 503 Forfeitures
   (criteria (1), (4), (6) and (7)).

   Second Payphone Order, 18 FCC Rcd at 19998, P 44.

   Id.

   Id.

   As explained below, we impose a forfeiture of $6,000 for Compass Global's
   failure to respond to the March 6 LOI on a timely basis.

   See, e.g., Global Teldata II, Inc., Notice of Apparent Liability for
   Forfeiture & Order, 20 FCC Rcd 17264 (2005) ("Global Teldata NAL");
   InPhonic, Inc., Notice of Apparent Liability for Forfeiture & Order, 20
   FCC Rcd 13277 (2005); Telecom House, Inc., Notice of Apparent Liability
   for Forfeiture & Order, 20 FCC Rcd 15131 (2005); Teletronics, Inc., Notice
   of Apparent Liability for Forfeiture & Order, 20 FCC Rcd 13291 (2005).

   See para. 11, supra.

   47 C.F.R. S 64.1195(a).

   See, e.g., id. at 17275, PP 26-27.

   See, e.g., id. at 17274-75, P 25.

   See Globcom Inc. d/b/a Globcom Global Communications, Notice of Apparent
   Liability for Forfeiture and Order, 18 FCC Rcd 19893 (2003), Globcom Inc.,
   Order of Forfeiture, FCC 06-49.

   47 C.F.R. S 1.80(b).

   See, e.g., BigZoo.com Corp., Order of Forfeiture, 20 FCC Rcd 3954 (2005);
   QuickLink Telecom, Inc., Order of Forfeiture, 20 FCC Rcd 14464 (2005).

   Carrera Communications, LP, Notice of Apparent Liability for Forfeiture &
   Order, 20 FCC Rcd 13307 (2005).

   See Business Options, Inc., Consent Decree, 19 FCC Rcd 2916 (2003); NOS
   Communications, Inc., Affinity Network Incorporated and NOSVA Limited
   Partnership, Consent Decree, 2003 WL 22439710 (2003).

   47 C.F.R. S 1.1910.

   47 U.S.C. S 503(b).

   47 C.F.R. S 1.80,

   See 47 C.F.R. S 1.80(f)(3).

   See 47 C.F.R. S 1.1914.

   Federal Communications Commission FCC 06-186

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                                 Federal Communications Commission FCC 06-186