FCC Releases Reminder on NLAD Transfer and Dispute Resolution Procedures

On Thursday, the FCC’s Wireline Competition Bureau released a public notice reminding ETCs about the NLAD processes for transferring subscriber benefits and for disputing an applicant’s failure to pass the NLAD’s automated identity verification check.

For benefits transfer, the Bureau reminds ETCs that the carrier to which the subscriber is transferring must obtain consent from the subscriber to transfer the service, keep a record of all communications relating to the transfer, and initiate the transfer in NLAD.

For identity dispute resolution, the Bureau reminds ETCs that if the NLAD is unable to verify the applicant’s identity through its automated processes, USAC will provide the ETC with  a reason for the rejection (e.g., address cannot be verified), and ETCs will have an opportunity to override the rejection by reviewing documentation (such as a driver’s license) then submitting an override code, or by working with USAC through a manual process.

These processes are not new, and USAC has been processing benefits transfer disputes under them for at least a month, and identity verification overrides for longer.  The fact that this public notice is just now being released  seems to confirm anecdotal evidence that the NLAD benefits transfer and dispute resolution processes have not had a smooth start.