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 Federal Communications Commission DA 16-1193 
 
Before the 
Federal Communications Commission 
Washington, DC 20554 
 
In the Matter of 
 
Roman LD, Inc. 
 
 
 
) 
) 
) 
) 
) 
 
 
File No.:  EB-TCD-14-00017114 
NAL/Account No.:  201532170012 
FRN:  0020640579 
ORDER 
 
Adopted:  October 21, 2016 Released:  October 21, 2016 
 
By the Chief, Enforcement Bureau: 
 
1. The Enforcement Bureau (Bureau) of the Federal Communications Commission 
(Commission) has entered into a Consent Decree to resolve its Notice of Apparent Liability for Forfeiture 
(NAL) which found that Roman LD, Inc. (Roman or Company) apparently submitted requests to switch 
consumers’ preferred long distance telephone carrier without authorization, commonly known as 
“slamming.”  The NAL also found that Roman, acting through its telemarketers, apparently engaged in 
deceptive marketing, by impersonating customers’ existing carrier, to obtain information that the 
Company then used to fabricate audio recordings as evidence of consumer authorization.  The Consent 
Decree also resolves the Commission’s investigation into whether Roman failed to seek and obtain 
Commission approval before transferring control of the Company to Ms. Monotaz Begum (Owner).  
Companies that engage in slamming and deceptive marketing prey on consumers not only by billing them 
for unauthorized service but also by violating their right to select the telecommunications providers of 
their choice.  The Commission is committed to ensuring that carriers do not perpetrate such unjust and 
unreasonable acts.   
2. To settle this matter, Roman admits making misrepresentations to consumers, fabricating 
verification recordings, engaging in “slamming,” and unlawfully transferring control of the Company.  
Roman will implement a compliance plan, and will pay a $240,000 civil penalty.  In the event of default, 
the Consent Decree also requires Roman to pay an additional civil penalty in the amount of $5,900,000, 
less any amounts previously paid.  Upon default, Roman and Owner shall be jointly and severally liable 
for the civil penalty and additional civil penalty. 
3. After reviewing the terms of the Consent Decree and evaluating the facts before us, we 
find that the public interest would be served by adopting the Consent Decree resolving the NAL1 
regarding Roman’s compliance with the law and the Commission’s rules regarding misrepresentations, 
slamming, and transfers of control, including Sections 201(b), 214, and 258 of the Communications Act 
of 1934, as amended (Act),2 and Sections 63.03, 63.04, 63.18, 63.24, and 64.1120 of the Commission’s 
rules (Rules).3 
4. In the absence of material new evidence relating to this matter, we do not set for hearing 
the question of Roman’s basic qualifications to hold or obtain any Commission license or authorization.4 
                                                     
1 Roman LD, Inc., Notice of Apparent Liability for Forfeiture, 30 FCC Rcd 3433 (2015) (Roman NAL). 
2 47 U.S.C. §§ 201(b), 214, 258.  
3 47 CFR §§ 63.03, 63.04, 63.18, 63.24, 64.1120. 
4 See 47 CFR § 1.93(b). 
 Federal Communications Commission DA 16-1193   
 2
5. Accordingly, IT IS ORDERED that, pursuant to Sections 4(i) and 503(b) of the Act5 and 
the authority delegated by Sections 0.111 and 0.311 of the Rules,6 the attached Consent Decree IS 
ADOPTED and its terms incorporated by reference. 
6. IT IS FURTHER ORDERED that the above-captioned matter IS TERMINATED and 
the NAL IS RESOLVED in accordance with the terms of the attached Consent Decree. 
7. IT IS FURTHER ORDERED that a copy of this Order and Consent Decree shall be 
sent by first class mail and certified mail, return receipt requested, to Monotaz Begum, Roman LD, Inc., 
2300 Valley View Lane, Suite 730, Irving, TX 75062 and to Roman LD, Inc.’s attorney, Cheng-Yi Liu, 
Fletcher, Heald & Hildreth, 1300 North 17th Street, 11th Floor, Arlington, VA 22209. 
 
FEDERAL COMMUNICATIONS COMMISSION 
 
 
 
       
Travis LeBlanc 
      Chief 
      Enforcement Bureau 
                                                     
5 47 U.S.C. §§ 154(i), 503(b). 
6 47 CFR §§ 0.111, 0.311. 
 Federal Communications Commission DA 16-1193 
 
Before the 
Federal Communications Commission 
Washington, DC 20554 
 
In the Matter of 
 
Roman LD, Inc. 
) 
) 
) 
) 
) 
 
 
File No.:  EB-TCD-14-00017114 
NAL/Account No.:  201532170012 
FRN:  0020640579 
 
CONSENT DECREE 
 
1. The Enforcement Bureau (Bureau) of the Federal Communications Commission 
(Commission), and Roman LD, Inc. (Roman), by their authorized representatives, hereby enter into this 
Consent Decree for the purpose of terminating the Bureau’s investigation into violations by Roman of 
Sections 201(b) and 258 of the Communications Act of 1934, as amended (Act or Communications Act),1 
and Section 64.1120 of the Commission’s rules (Rules),2 as well as Section 214 of the Act3 and Sections 
63.03, 63.04, 63.18, and 63.24 of the Rules.4     
 
I. DEFINITIONS 
2. For the purposes of this Consent Decree, the following definitions shall apply: 
(a) “Act” or “Communications Act” means the Communications Act of 1934, as 
amended.5   
(b) “Adopting Order” means an order of the Bureau adopting the terms of this Consent 
Decree without change, addition, deletion, or modification. 
(c) “Affiliate” shall have the meaning defined in 47 U.S.C. § 153(2).  
(d) “Bureau” means the Enforcement Bureau of the Federal Communications 
Commission. 
(e) “Commission” and “FCC” mean the Federal Communications Commission and all of 
its bureaus and offices. 
(f) “Communications Laws” means, collectively, the Act, the Rules, and the published 
and promulgated orders and decisions of the Commission to which Roman is subject 
by virtue of its business activities, including but not limited to Sections 201, 214, and 
258 of the Act and Sections 63.03, 63.04, 63.18, 63.24, and 64.1100-64.1195 of the 
Rules.  
(g) “Compliance Plan” means the compliance obligations, programs, and procedures 
described in this Consent Decree at paragraph 13.    
(h) “Consumer” means any Person to which Roman provides service or otherwise 
engages to sell or attempt to sell its services. 
                                                     
1 47 U.S.C. §§ 201(b), 258. 
2 47 CFR § 64.1120. 
3 47 U.S.C. § 214. 
4 47 CFR §§ 63.03, 64.04, 63.18, 63.24. 
5 47 U.S.C. § 151 et seq. 
 Federal Communications Commission DA 16-1193   
 2
(i) “Consumer Complaint” means any complaint or inquiry Roman receives from a 
Consumer, a billing aggregator, a local exchange carrier, the Better Business Bureau, 
or a federal or state regulatory agency alleging that Roman has:  (1) submitted or 
executed an Unauthorized Change, a practice commonly known as “slamming,” (2) 
charged the Consumer for services that the consumer never authorized, a practice 
known as “cramming,” or (3) misled the Consumer about the nature of Roman’s 
services or identity during the marketing of any Roman services. 
(j) “Covered Personnel” means all employees and agents of Roman who perform, or 
supervise, oversee, or manage the performance of, duties that relate to Roman’s 
responsibilities under the Communications Laws, including the Slamming Rules, 
Section 201(b) of the Act, and this Consent Decree, and includes customer service 
representatives, Sales Representatives, and Verifiers.  
(k) “Effective Date” means the date by which both the Bureau and Roman have signed 
this Consent Decree.  
(l) “Investigation” means the investigation commenced by the Bureau’s letter of inquiry, 
dated September 11, 2014,6 regarding Roman’s noncompliance with Sections 201, 
214, and 258 of the Act and Sections 63.03, 63.04, 63.18, 63.24, and 64.1120 of the 
Rules, which culminated in the issuance of a Notice of Apparent Liability.  
(m) “NAL” means the Notice of Apparent Liability for Forfeiture issued to Roman on 
March 31, 2015, proposing a forfeiture for apparent violations of Sections 201, 214, 
and 258 of the Act and Sections 63.03, 63.04, 63.18, 63.24 and 64.1120 of the Rules.   
(n) “Operating Procedures” means the standard, internal operating procedures and 
compliance policies established by Roman to implement the Compliance Plan. 
(o) “Owner” means Ms. Monotaz Begum. 
(p) “Parties” means Roman, Ms. Monotaz Begum, and the Bureau, each of which is a 
“Party.”   
(q) “Person” shall have the meaning defined in 47 U.S.C. § 153(39). 
(r) “Roman” or “Company” means Roman LD, Inc., its Affiliates, and its predecessors-
in-interest and successors-in-interest. 
(s) “Rules” means the Commission’s regulations found in Title 47 of the Code of 
Federal Regulations.  
(t) “Sales Representative” means any Person Roman engages as an employee, 
independent contractor, or otherwise, to market, sell, or attempt to sell, its services.   
(u) “Slamming Rules” means the Rules set forth at 47 CFR § 64.1120 et seq.  
(v) “Unauthorized Change” shall have the meaning defined in 47 CFR § 64.1100(e). 
(w) “Verifier” means each Person Roman engages, as an employee, independent 
contractor, or otherwise, to verify, or attempt to verify, that any buyer or potential 
buyer of a Roman service has authorized the purchase of such service.  
II. BACKGROUND 
3.  Section 258 of the Act makes it unlawful for any telecommunications carrier to engage 
in the practice of “slamming” by “submit[ing] or execut[ing] a change in a subscriber’s selection of a 
                                                     
6 Letter from Richard A. Hindman, Chief, Telecommunications Consumers Division, FCC Enforcement Bureau, to 
Roman LD, Inc. (Sept. 11, 2014) (on file in EB-TCD-14-00017114) (LOI). 
 Federal Communications Commission DA 16-1193   
 3
provider of telephone exchange service or telephone toll service except in accordance with such 
verification procedures as the Commission shall prescribe.”7  Section 64.1120 of the Rules prohibits 
carriers from submitting a request to change a consumer’s preferred provider of telecommunications 
services before verifying authorization from the consumer.8 
4. Section 201(b) of the Act states that “[a]ll charges, practices, classifications, and 
regulations for and in connection with [interstate or foreign] communication service [by wire or radio], 
shall be just and reasonable, and any such charge, practice, classification, or regulation that is unjust or 
unreasonable is declared unlawful.”9  The Commission has held that unfair and deceptive marketing 
practices by interstate common carriers, and misrepresentations about a carrier’s identity or the nature of 
its service to obtain a consumer’s authorization to change his or her preferred long distance carrier, 
constitute unjust and unreasonable practices under Section 201(b) of the Act.10  
5. Section 214 of the Act,11 and Sections 63.03 and 63.24 of the Rules,12 require carriers to 
obtain Commission approval before consummating substantial transfers of control of domestic and 
international Section 214 authority.  Sections 63.04 and 63.18 of the Rules require certain information to 
be included in domestic and international transfer of control applications.13  Roman violated Section 214 
and related Rules14 by consummating substantial transfers of control of:  (1) a domestic Section 214 
authority; and (2) an international Section 214 authority, without prior Commission approval.  This 
transaction transferred ultimate control of domestic and international Section 214 authority from the 
initial owner of Roman to Ms. Monotaz Begum.   
6. On April 2, 2015, the Commission released a Notice of Apparent Liability for Forfeiture 
against Roman, finding that the Company apparently violated Sections 201(b) and 258 of the Act and 
Section 64.1120 of the Rules, as well as Section 214 of the Act and Sections 63.03, 63.04, 63.18, and 
63.24 of the Rules.15  The Commission found that “Roman apparently . . . violat[ed] Section 201(b) of the 
Act for misrepresenting its identity to consumers in order to deceive them into believing its telemarketing 
call was from the consumer’s own carrier and for fabricating audio ‘verification’ recordings.”16  The 
Commission also found that Roman apparently violated “Section 258 of the Act and Section 64.1120 of 
the Rules by submitting requests to change or switch consumers’ preferred long distance carriers without 
authorization verified in compliance with the Commission’s verification procedures.”17  Finally, the 
                                                     
7 47 U.S.C. § 258(a).  
8 47 CFR § 64.1120(c)(1)-(3). 
9 47 U.S.C. § 201(b). 
10 See Preferred Long Distance, Inc., Notice of Apparent Liability for Forfeiture, 27 FCC Rcd 16489 (2012) 
(Preferred NAL), Forfeiture Order, 30 FCC Rcd 13711 (2015).  
11 47 U.S.C. § 214. 
12 47 CFR §§ 63.03, 63.04, 63.18, 63.24.  See Stanacard, LLC, Notice of Apparent Liability for Forfeiture, 28 FCC 
Rcd 82, 85-86, paras. 9-11 (EB 2013).  A transfer of control of domestic lines or of a domestic Section 214 authority 
is considered “substantial” if it results in a change in ultimate ownership or control of those lines or that authority.  
47 CFR § 63.03(d).  A transfer of control of international lines or of an international Section 214 authority is 
considered “substantial” if it results in a change in the actual controlling party of those lines or that authority.  See 
47 CFR § 63.24(a). 
13 See 47 CFR §§ 63.04, 63.18. 
14 47 U.S.C. § 214; 47 CFR §§ 63.03, 63.04, 63.18, 63.24. 
15 Roman LD, Inc., Notice of Apparent Liability for Forfeiture, 30 FCC Rcd 3433 (2015) (Roman NAL). 
16 Roman NAL, 30 FCC Rcd at 3435, para. 6. 
17 Id. 
 Federal Communications Commission DA 16-1193   
 4
Commission found that Roman apparently violated Section 214 of the Act and Sections 63.03, 63.04, 
63.18, and 63.24 of the Rules by failing to seek and obtain Commission approval before transferring 
control of the Company to Ms. Monotaz Begum on January 2, 2013.”18 
III. TERMS OF AGREEMENT 
7. Adopting Order.  The provisions of this Consent Decree shall be incorporated by the 
Bureau in an Adopting Order. 
8. Jurisdiction.  Roman and Owner agree that the Bureau has jurisdiction over them and 
the matters contained in this Consent Decree and has the authority to enter into and adopt this Consent 
Decree.   
9. Effective Date; Violations.  The Parties agree that this Consent Decree shall become 
effective on the Effective Date as defined herein.  As of the Effective Date, the Parties agree that this 
Consent Decree shall have the same force and effect as any other order of the Commission.  Any violation 
of the Adopting Order or of the terms of this Consent Decree shall constitute a violation of a Commission 
order, entitling the Commission to exercise any rights and remedies attendant to the enforcement of a 
Commission order. 
10. Termination of Investigation.  In express reliance on the covenants and representations 
in this Consent Decree and to avoid further expenditure of public resources, the Bureau agrees to 
terminate the Investigation.  In consideration for the termination of the Investigation, Roman and Owner 
agree to the terms, conditions, and procedures contained herein.  The Bureau further agrees that, in the 
absence of new material evidence, it will not use the facts developed in the Investigation through the 
Effective Date, or the existence of this Consent Decree, to institute, on its own motion, any new 
proceeding, formal or informal, or to take any action on its own motion against Roman or Owner 
concerning the matters that were the subject of the Investigation. The Bureau also agrees that, in the 
absence of new material evidence, it will not use the facts developed in the Investigation through the 
Effective Date, or the existence of this Consent Decree, to institute on its own motion any proceeding, 
formal or informal, or to set for hearing the question of Roman’s basic qualifications to be a Commission 
licensee or hold Commission licenses or authorizations.19  
11. Admission of Liability.  Roman admits, for the purpose of this Consent Decree and for 
Commission civil enforcement purposes, and in express reliance on the provisions of paragraph 10 herein, 
that its actions referenced in paragraph 6 herein and the NAL violated the Act and Rules. 
12. Compliance Officer.  Within thirty (30) calendar days after the Effective Date, Roman 
shall designate a senior corporate manager with the requisite corporate and organizational authority to 
serve as a Compliance Officer and to discharge the duties set forth below.  The person designated as the 
Compliance Officer shall be responsible for developing, implementing, and administering the Compliance 
Plan and ensuring that Roman complies with the terms and conditions of the Compliance Plan and this 
Consent Decree, including verifying that new subscriptions are in fact authorized and implementing 
quality control improvements in the subscription and customer service process.  In addition to the general 
knowledge of the Communications Laws necessary to discharge his or her duties under this Consent 
Decree, the Compliance Officer shall have specific knowledge of the Slamming Rules and the 
Commission’s decisions related to carrier marketing practices, misrepresentations about a carrier’s 
identity or the nature of its service, and inclusion of unauthorized charges on consumers’ telephone bills.  
13. Compliance Plan.  For purposes of settling the matters set forth herein, Roman agrees 
that it shall, within sixty (60) calendar days after the Effective Date, develop and implement a 
Compliance Plan designed to ensure future compliance with the Communications Laws, including 
Sections 201(b), 214, and 258 of the Act and Sections 63.03, 63.04, 63.18, 63.24, and 64.1100 et seq. of 
                                                     
18 Id. 
19 See 47 CFR § 1.93(b). 
 Federal Communications Commission DA 16-1193   
 5
the Rules, and with the terms and conditions of this Consent Decree.  The Compliance Plan shall include, 
at a minimum, the following components:  
(a) Operating Procedures.  Within sixty (60) calendar days after the Effective Date, 
Roman shall establish Operating Procedures that the Compliance Officer and all 
Covered Personnel must follow to help ensure Roman’s compliance with this 
Consent Decree, the Slamming Rules, and Section 201(b) of the Act with respect to 
its marketing practices and charges for telecommunications services.  
(b) Compliance Manual.  Within sixty (60) calendar days after the Effective Date, 
Roman shall develop, use, and maintain a Compliance Manual, and distribute the 
same to all Covered Personnel.  For any Person who becomes Covered Personnel 
more than sixty (60) calendar days after the Effective Date, Roman shall distribute 
the Compliance Manual to that Person within thirty (30) calendar days after the date 
such Person becomes Covered Personnel, and prior to such Person engaging with 
consumers with respect to Roman’s services.  The Compliance Manual shall explain 
the requirements of this Consent Decree, the Slamming Rules, and Section 201(b) of 
the Act and shall instruct Covered Personnel to consult and follow the Operating 
Procedures to ensure Roman’s compliance with the Communications Laws and this 
Consent Decree.  Roman shall periodically review and revise the Compliance Manual 
to ensure that the information set forth therein remains current and complete.  Roman 
shall distribute any revisions of the Compliance Manual to all Covered Personnel 
within thirty (30) calendar days.  
(c) Compliance Training Program.  Roman shall establish, and implement a 
compliance training program in compliance with this Consent Decree, the Slamming 
Rules, Section 201(b) of the Act, and the Operating Procedures.  As part of the 
compliance training program, Covered Personnel shall be advised of Roman’s 
obligation to report any noncompliance with this Consent Decree, the Slamming 
Rules, and Section 201(b) of the Act under paragraph 14 of this Consent Decree and 
shall be instructed on how to disclose noncompliance to the Compliance Officer.  All 
Covered Personnel shall be trained pursuant to the compliance training program 
within sixty (60) calendar days after the Effective Date, except that any person who 
becomes Covered Personnel at any time after the initial compliance training program 
shall be trained within thirty (30) calendar days after the date such person becomes 
Covered Personnel.  Roman shall repeat compliance training on an annual basis, and 
shall periodically review and revise the compliance training program as necessary to 
ensure that it remains current and complete and to enhance its effectiveness. 
(d) Additional Requirements for Consumer Complaints.  Within sixty (60) calendar 
days after the Effective Date, Roman shall also handle Consumer Complaints as 
follows:   
i. Complaint Response.  Within twenty-four (24) hours of receiving any Consumer 
Complaint asserting an Unauthorized Change by Roman or its agent, or any 
Covered Personnel, Roman shall contact the complainant and assist the 
complainant in re-establishing service with his or her preferred carrier, by, at a 
minimum, contacting the complainant’s preferred carrier and reporting the 
change to the preferred carrier as an Unauthorized Change.  Within thirty (30) 
calendar days of receipt of any such Consumer Complaint, Roman shall also 
refund all charges (both recurring and non-recurring) the complainant incurred in 
connection with any Unauthorized Change.  Within twenty-four (24) hours of 
Roman receiving any Consumer Complaint asserting that Roman or its agent 
charged the complainant for any service without the complainant’s authorization, 
Roman shall contact the complainant and assist the complainant with remedial 
 Federal Communications Commission DA 16-1193   
 6
action by, at a minimum, canceling the service and (A) removing any charges for 
the service from the complainant’s bill where Roman bills the complainant 
directly, or (B) taking all steps necessary to cause the charges to be removed 
from the complainant’s bill where a third party, such as the complainant’s local 
exchange carrier, directly or indirectly bills the complainant for the service.  
Where Roman bills through a third party and has taken all steps for removal of 
charges from complainant’s bill, Roman shall follow up with the third party to 
verify that the charges have been removed and that no further charges will be 
placed on the complainant’s bill.  If the charges are not removed and future 
charges are not blocked, Roman shall be responsible for all future charges until 
such time as they are removed and blocked. 
ii. Complaint Retention.  Roman shall retain for the term of this Consent Decree, in 
an accurate, clear, and comprehensible format, all documents evidencing or 
relating to all Consumer Complaints, including Roman’s responses thereto.  
Copies of such documents evidencing or relating to Consumer Complaints must 
be forwarded electronically to the Bureau within twenty (20) calendar days from 
the date of the Consumer Complaint and updated monthly until resolved.  These 
documents evidencing or relating to Consumer Complaints must be submitted 
electronically to Michael.Epshteyn@fcc.gov, Erica.McMahon@fcc.gov, and 
Mika.Savir@fcc.gov.  These documents shall include, at a minimum, the 
following:  all computer records, electronic or e-mail communications, and all 
written notes regarding such writings, verbal discussions, and electronic mail 
communications, as well as any relevant recordings, including all third party 
verification recordings made during telephone conversations relating to the 
Consumer Complaint.   
(e) Additional Requirements for the Marketing and Selling of Service. Within sixty 
(60) calendar days after the Effective Date:  
i. Scripts.  Roman shall cause each Sales Representative and Verifier to use scripts 
when carrying out his or her duties as a Sales Representative or Verifier for 
Roman.  The Sales Representative script shall require each Sales Representative 
at the outset of the call to clearly and promptly state to each buyer or potential 
buyer of Roman’s services that (A) the Sales Representative is not affiliated with 
the buyer or potential buyer’s current long distance, international, or other toll 
carrier, and (B) the purpose of the call is to inquire whether the buyer or potential 
buyer is authorized to make a change to and wishes to change his or her long 
distance, international, or other toll service from his or her current preferred 
carrier to Roman.  The Sales Representative script shall also prohibit the Sales 
Representative from (A) making any false or misleading statements to the 
Consumer regarding the Verifier or the role of the Verifier, and (B) instructing 
the Consumer in how he or she should respond to the Verifier’s questions.  The 
Verifier script shall require each Verifier to clearly and promptly state at the 
beginning of the verification process that the purpose of the call is to confirm the 
call recipient’s intent to change preferred carriers for his or her long distance, 
international, or other toll service, and to obtain the call recipient’s approval to 
effectuate such change.   
ii. Monitoring.  Roman shall monitor, on a monthly basis, from both on-site and 
remote locations, no less than seventy (70) percent of real-time sales and 
verification calls to ensure that Sales Representatives and Verifiers are carrying 
out their responsibilities in compliance with the Communications Laws and this 
Consent Decree. 
 Federal Communications Commission DA 16-1193   
 7
(f) Changes of Subscribers’ Preferred Carriers.  Beginning on the Effective Date, 
Roman shall, after submitting a request to change a subscriber’s telecommunications 
service provider to Roman, confirm that the carrier change has been effected prior to 
charging and/or billing the subscriber (directly or indirectly through an affiliate or 
third party) for any service.  Roman shall implement, maintain, and use procedures to 
ensure that it does not continue charging any subscriber who contacts Roman directly 
to cancel service with Roman or contacts their local exchange carrier to switch 
service from Roman to another carrier.  Roman shall ensure that such procedures are 
incorporated in and made a part of its Operating Procedures.  In addition, Roman 
shall submit any requests to change a Consumer’s telecommunications service 
provider to Roman no later than fourteen (14) days after verifying the subscriber’s 
authorization to switch providers to Roman.  Roman shall not use any third-party 
verification recording it relied on to submit a request to change a subscriber’s carrier 
for any subsequent carrier change requests. 
14.  Reporting Noncompliance.  Roman shall report any noncompliance with Section 
201(b) of the Act, the Slamming Rules, changes in ownership, and with the terms and conditions of this 
Consent Decree within fifteen (15) calendar days after discovery of such noncompliance.  Such reports 
shall include a detailed explanation of:  (a) each instance of noncompliance; (b) the steps that Roman has 
taken or will take to remedy such noncompliance; (c) the schedule on which such remedial actions will be 
taken; and (d) the steps that Roman has taken or will take to prevent the recurrence of any such 
noncompliance.  All reports of noncompliance shall be submitted to the Chief, Telecommunications 
Consumers Division, Enforcement Bureau, Federal Communications Commission, 445 12th Street, SW, 
Rm. 4C-224, Washington, DC 20554, with a copy submitted electronically to 
Michael.Epshteyn@fcc.gov, Erica.McMahon@fcc.gov, and Mika.Savir@fcc.gov. 
15. Compliance Reports.  Roman shall file compliance reports with the Commission six (6), 
twelve (12), eighteen (18), twenty-four (24), thirty (30), and thirty-six (36) months after the Effective 
Date.   
(a) Each Compliance Report shall include a detailed description of Roman’s efforts 
during the relevant period to comply with the terms of this Consent Decree, Section 
201(b) of the Act, and the Slamming Rules. 
(b) Each Compliance Report shall also include a detailed description of any new or 
additional telecommunications companies owned, in whole or in part, by any of the 
present or past owners, shareholders, officers, or directors of Roman and all changes 
in ownership of Roman.    
(c) Each Compliance Report shall include a certification by the Compliance Officer, as 
an agent of and on behalf of Roman, stating that the Compliance Officer has personal 
knowledge that Roman:  (i) has established and implemented the Compliance Plan; 
(ii) has utilized the Operating Procedures since the implementation of the 
Compliance Plan; and (iii) is not aware of any instances of noncompliance with the 
terms and conditions of this Consent Decree, including the reporting obligations set 
forth in paragraph 14 of this Consent Decree.   
(d) The Compliance Officer’s certification shall be accompanied by a statement 
explaining the basis for such certification and shall comply with Section 1.16 of the 
Rules,20 and be subscribed to as true under penalty of perjury in substantially the 
form set forth therein.   
(e) If the Compliance Officer cannot provide the requisite certification, the Compliance 
Officer, as an agent of and on behalf of Roman, shall provide the Commission with a 
                                                     
20 47 CFR § 1.16. 
 Federal Communications Commission DA 16-1193   
 8
detailed explanation of the reason(s) why and describe fully:  (i) each instance of 
noncompliance; (ii) the steps Roman has taken or will take to remedy such 
noncompliance, including the schedule on which proposed remedial actions will be 
taken; and (iii) the steps that Roman has taken or will take to prevent the recurrence 
of any such noncompliance, including the schedule on which such preventive action 
will be taken. 
(f) All Compliance Reports shall be submitted to the Chief, Telecommunications 
Consumers Division, Enforcement Bureau, Federal Communications Commission, 
445 12th Street, SW, Rm. 4-C224, Washington, DC 20554, with copies submitted 
electronically to Michael.Epshteyn@fcc.gov, Erica.McMahon@fcc.gov, and 
Mika.Savir@fcc.gov. 
16. Termination Date.  The obligations set forth in paragraphs 12 through 15 of this 
Consent Decree shall expire thirty-six (36) months after the Effective Date or on the date that Roman 
ceases providing telecommunications services, whichever occurs first. 
17. Section 208 Complaints; Subsequent Investigations.  Nothing in this Consent Decree 
shall prevent the Commission or its delegated authority from adjudicating complaints filed pursuant to 
Section 208 of the Act21 against Roman or its affiliates or Owner for alleged violations of the Act, or for 
any other type of alleged misconduct, regardless of when such misconduct took place.  The Commission’s 
adjudication of any such complaint will be based solely on the record developed in that proceeding.  
Except as expressly provided in this Consent Decree, this Consent Decree shall not prevent the 
Commission from investigating new evidence of noncompliance by Roman or Owner with the 
Communications Laws. 
18. Civil Penalty.  In light of Roman’s demonstrated financial hardship and subject to the 
provisions of paragraph 19 below, Roman shall pay a Civil Penalty to the United States Treasury in the 
amount of two hundred forty thousand dollars ($240,000.00).  Such payment shall be made in 6 
installments (each, an Installment Payment).  The first Installment Payment in the amount of forty 
thousand dollars ($40,000) is due within thirty (30) calendar days after the Effective Date.  Thereafter, 
Installment Payments in the amount of forty thousand dollars ($40,000) are due and payable monthly on 
the 15th of the month starting December 15, 2016 with the final Installment Payment on April 15, 2017.  
Roman and Owner acknowledge and agree that upon execution of this Consent Decree, the Civil Penalty 
and each Installment Payment shall become a “Claim” or “Debt” as defined in Section 3701(b)(1) of the 
Debt Collection Improvement Act of 1996 (DCIA).22  Roman further agrees that, upon an Event of 
Default (as described below in paragraph 19), Roman will pay an Additional Civil Penalty to the United 
States Treasury in the amount of five million nine hundred thousand dollars ($5,900,000) less any 
amounts previously paid as Installment Payments.  Roman and Owner acknowledge and agree that upon 
an Event of Default, the Additional Civil Penalty shall also become a “Claim” or “Debt” as defined in 
Section 3701(b)(1) of the DCIA,23 and all procedures for collection of the Additional Civil Penalty may, 
at the Commission’s discretion, be initiated against Roman and/or Owner.  Roman and Owner agree that 
if the Event of Default occurs while Owner is still an owner of Roman, or while Owner owns, operates, or 
controls another toll reseller, that she and Roman will be jointly and severally liable for the Civil Penalty 
and Additional Civil Penalty of five million nine hundred thousand dollars ($5,900,000) less any amounts 
previously paid as Installment Payments.   
Roman or Owner, as applicable, shall send electronic notification of payment on the date such payment is 
made to Lisa Williford, Telecommunications Consumers Division, Enforcement Bureau, Federal 
                                                     
21 47 U.S.C. § 208. 
22 Debt Collection Improvement Act of 1996, Pub. L. No. 104-134, 110 Stat. 1321, 1358 (Apr. 26, 1996) (DCIA). 
23 Id. 
 Federal Communications Commission DA 16-1193   
 9
Communications Commission at Lisa.Williford@fcc.gov.  The payment must be made by check or 
similar instrument, wire transfer, or credit card, and must include the NAL Account Number and FRN 
referenced in the caption of the Adopting Order.  Regardless of the form of payment, a completed FCC 
Form 159 (Remittance Advice) must be submitted.24  When completing the FCC Form 159, Roman or 
Owner, as applicable, shall enter the Account Number in block number 23A (call sign/other ID) and enter 
the letters “FORF” in block number 24A (payment type code).  Below are additional instructions Roman 
or Owner, as applicable, must follow based on the form of payment selected:   
? Payment by check or money order must be made payable to the order of the Federal 
Communications Commission.  Such payments (along with the completed Form 159) must be 
mailed to Federal Communications Commission, P.O. Box 979088, St. Louis, MO 63197-
9000, or sent via overnight mail to U.S. Bank—Government Lockbox #979088, 
SL-MO-C2-GL, 1005 Convention Plaza, St. Louis, MO 63101. 
? Payment by wire transfer must be made to ABA Number 021030004, receiving bank 
TREAS/NYC, and account number 27000001.  To complete the wire transfer and ensure 
appropriate crediting of the wired funds, a completed Form 159 must be faxed to U.S. Bank 
at (314) 418-4232 on the same business day the wire transfer is initiated. 
? Payment by credit card must be made by providing the required credit card information on 
FCC Form 159 and signing and dating the Form 159 to authorize the credit card payment.  
The completed Form 159 must then be mailed to Federal Communications Commission, P.O. 
Box 979088, St. Louis, MO 63197-9000, or sent via overnight mail to U.S. Bank—
Government Lockbox #979088, SL-MO-C2-GL, 1005 Convention Plaza, St. Louis, MO 
63101.   
Questions regarding payment procedures should be addressed to the Financial Operations Group Help 
Desk by phone at (877) 480-3201, or by e-mail to ARINQUIRIES@fcc.gov. 
19. Event of Default.  Roman and Owner agree that an Event of Default shall occur upon:  
(a) the failure to pay the Civil Penalty or any Installment Payment to the U.S. Treasury on or before the 
dates specified in Paragraph 18 unless reasonable cause is given and the failure to pay is cured within five 
(5) business days; (b) the release of an order within three (3) years of the Effective Date by the 
Commission, such as a Notice of Apparent Liability for Forfeiture that is uncontested or a Forfeiture 
Order, finding that Roman, any Roman Affiliate, or entity owned, operated, or controlled by Owner, 
violated Section 201(b) of the Act or the Slamming Rules; or (c) the release of an order by the 
Commission finding that Roman materially misstated its financial condition in the documents it produced 
to support its claim of inability to pay.   
20. Interest, Charges for Collection, and Acceleration of Maturity Date.  After an Event 
of Default has occurred, all procedures for collection permitted by the DCIA and other provisions of law25 
may, at the Commission’s discretion, be initiated and the following shall become immediately due and 
payable, without notice, presentment, demand, protest, or notice of protest of any kind, all of which are 
waived by Roman and Owner.  After an Event of Default referred to in (a) of Paragraph 19 has occurred, 
Roman and Owner shall be jointly and severally liable for:  (i) any unpaid portion of the Civil Penalty or 
Installment Payments referenced in Paragraph 18, which shall accrue interest at a rate of the U.S. Prime 
Rate in effect on the date of the Event of Default plus 4.75 percent per annum from the date of the Event 
of Default until payment in full; (ii) any penalties permitted and/or required by the law, including but not 
limited to 31 U.S.C. § 3717; and (iii) any administrative charge(s), including the costs of collection, 
litigation, and attorneys’ fees.  After an Event of Default referred to in (b) or (c) of Paragraph 19 has 
occurred, Roman shall be liable for: (i) the Additional Civil Penalty defined in Paragraph 18, which shall 
                                                     
24 An FCC Form 159 and detailed instructions for completing the form may be obtained at 
http://www.fcc.gov/Forms/Form159/159.pdf. 
25 See 31 CFR Part 900, et seq. 
 Federal Communications Commission DA 16-1193   
 10
accrue interest at a rate of the U.S. Prime Rate in effect on the date of the Event of Default plus 4.75 
percent per annum from the date of the Event of Default until payment in full; (ii) any penalties permitted 
and/or required by the law, including but not limited to 31 U.S.C. § 3717; and (iii) any administrative 
charge(s), including the costs of collection, litigation, and attorneys’ fees.  Roman and Owner shall be 
jointly and severally liable for the aforementioned Additional Civil Penalty, penalties, and charges if the 
Event of Default referred to in paragraph 19 (b) or (c) occurs while Owner is still an owner of Roman or 
while Owner owns, operates, or controls another toll reseller. 
21. Waivers.  As of the Effective Date, Roman and Owner waive any and all rights they may 
have to seek administrative or judicial reconsideration, review, appeal, or stay, or to otherwise challenge 
or contest the validity of this Consent Decree and the Adopting Order.  Roman and Owner shall retain the 
right to challenge Commission interpretation of the Consent Decree or any terms contained herein.  If 
either party (or the United States on behalf of the Commission) brings a judicial action to enforce the 
terms of the Consent Decree or Adopting Order, the Parties shall not contest the validity of the Consent 
Decree or the Adopting Order, and Roman and Owner shall waive any statutory right to a trial de novo.  
Roman and Owner hereby agree to waive any claims they may otherwise have under the Equal Access to 
Justice Act,26 relating to the matters addressed in this Consent Decree. 
22. Severability.  The Parties agree that if any of the provisions of the Consent Decree shall 
be held unenforceable by any court of competent jurisdiction, such unenforceability shall not render 
unenforceable the entire Consent Decree, but rather the entire Consent Decree shall be construed as if not 
containing the particular unenforceable provision or provisions, and the rights and obligations of the 
Parties shall be construed and enforced accordingly.  
23. Invalidity.  In the event that this Consent Decree in its entirety is rendered invalid by any 
court of competent jurisdiction, it shall become null and void and may not be used in any manner in any 
legal proceeding. 
24. Subsequent Rule or Order.  The Parties agree that if any provision of this Consent 
Decree conflicts with any subsequent Rule or Order adopted by the Commission (except an Order 
specifically intended to revise the terms of this Consent Decree to which Roman does not expressly 
consent) that provision will be superseded by such Rule or Order.   
25. Acts or Omissions of Contractors and Agents.  Roman and Owner acknowledge that 
the act, failure to act, or omission by any contractor, subcontractor, or agent of Roman, Roman Affiliate, 
or Owner that results in a violation of the Act, Rules, or this Consent Decree constitutes an act, failure to 
act, or omission by Roman. 
26. Successors and Assigns.  Roman and Owner agree that the provisions of this Consent 
Decree shall be binding on Roman’s successors, assigns, and transferees and any assignee or transferee of 
Owner’s interest (in whole or part) in Roman and any Roman successor, assign, and transferee. 
27. Final Settlement.  The Parties agree and acknowledge that this Consent Decree shall 
constitute a final settlement between the Parties with respect to the Investigation. 
28. Modifications.  This Consent Decree cannot be modified without the advance written 
consent of all Parties. 
29. Paragraph Headings.  The headings of the paragraphs in this Consent Decree are 
inserted for convenience only and are not intended to affect the meaning or interpretation of this Consent 
Decree. 
30. Authorized Representative.  Each Party represents and warrants to the other that it has 
full power and authority to enter into this Consent Decree.  Each person signing this Consent Decree on 
                                                     
26 See 5 U.S.C. § 504; 47 CFR §§ 1.1501-1.1530. 
 Federal Communications Commission DA 16-1193   
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behalf of a Party hereby represents that he or she is fully authorized by the Party to execute this Consent 
Decree and to bind the Party to its terms and conditions. 
31. Counterparts.  This Consent Decree may be signed in counterpart (including 
electronically or by facsimile).  Each counterpart, when executed and delivered, shall be an original, and 
all of the counterparts together shall constitute one and the same fully executed instrument. 
 
 
 
__________________________________________ 
Travis LeBlanc 
Chief 
Enforcement Bureau 
 
 
__________________________________________ 
Date 
 
 
 
__________________________________________ 
Ms. Monotaz Begum 
On behalf of Roman LD, Inc. and its Affiliates 
 
 
__________________________________________ 
Date 
 
 
 
__________________________________________ 
Ms. Monotaz Begum 
Owner 
On behalf of herself in her personal capacity 
 
 
__________________________________________ 
Date