A declaratory ruling the FCC announced last week clarifying its customer proprietary network information (CPNI) policies could impact the practices of some carriers and/or their “designees” operating or controlling mobile payments platforms that use CPNI. The FCC ruling [PDF] affects the practice of mobile carriers who use customers’ devices to collect information about customers’ use of the network, including through the use of preinstalled apps. Some carriers involved in mobile payments may not have previously considered information gathered by applications—as opposed to the network itself—to be covered by FCC rules. This ruling may merit a review of information gathering and usage practices by carriers involved in the mobile payments process, whether directly or indirectly with third parties which might qualify as “designees.” Please let us know if you have questions or may need assistance with these issues.
LNGS contact: Brooks Harlow (firstname.lastname@example.org)