Tag: Regulatory Compliance

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Current News Technology What Customers Want

Do the Cloud Guys Get It?

English: Cloud Computing Image (Photo credit: Wikipedia)

I just read an article this week that cites five reasons why cloud computing isn’t taking off as fast as the companies selling the solution were hoping for. The reasons unfortunately make me feel like the cloud industry folks are out of touch with the real world. This is not an uncommon phenomenon in that high-tech industries are run by innovators. Innovators often don’t understand why the rest of the world doesn’t see things with the same clarity as they do.

Following are the five reasons cited in the article about why cloud computing is not selling as fast as hoped, with my observations after each point.

The Organization. Organizations often are structured in a way that does not make the kind of shift to cloud easy. For instance, IT shops are often organized into separate groups for compute, network and storage.

Changes that affect people are never easy for companies. Going to the cloud is supposed to save a lot of labor costs for larger companies, but that is not necessarily the case for smaller companies.  But even larger companies are going to take a while to make sure they are not walking off a cliff. Every old-timer like me remembers a few examples of where major technology conversions went poorly, and nobody wants to be the one blamed if a big conversion goes wrong.

Security. Companies are afraid that the cloud is not going to be as safe as keeping all of their data in-house.

Everything I have read says that if done right that the cloud can be very secure. However, the fear is that not every conversion is going to be done right. You can place your bets with me now, but sometime in the next year or two there is going to be a major ugly headline about a company that converted to the cloud poorly which led to a major breach of customer records. The problem is that everybody is human and not every cloud company is going to do every conversion perfectly.

Legacy Applications. Cloud companies want you to get rid of legacy systems and upgrade to applications made for the cloud.

This is where cloud companies just don’t get it. First, almost every company uses a few legacy systems that are not upgradable and for which there is no cloud equivalent. Every industry has some quirky homegrown programs and applications that are important for their core business. When you tell a company to kill every legacy application most of them are going to rightfully be scared this is going to create more problems than it solves.

Second, nobody wants to be automatically upgraded with the latest and greatest software. It’s a company nightmare to come in on a Monday and find out that the cloud provider has upgraded everybody to some new Microsoft version of Office that is full of bugs and that everybody hates and that brings productivity to a halt. Companies keep legacy systems because they work. I recently wrote about the huge number of computers still running on Windows XP. That is how the real world works.

Legacy Processes. In addition to legacy software, companies have many legacy processes that they don’t want to change.

Honestly this is arrogant. Companies buy software to make what they do easier. To think that you need to change all of your processes to match the software is really amazingly out of touch with what most companies are looking for. Where a cloud salesman sees ‘legacy system’ most companies see something that works well and that they took years to get the way they want it.

Regulatory Compliance. Companies are worried that the cloud is going to violate regulatory requirements. This is especially true for industries such as financial, health and the power industries.  

This is obviously a case-by-case issue, but if you are in one of the heavily regulated industries then this has to be a significant concern.

I hope this doesn’t make me sound anti-cloud, because I am not. But I completely understand why many companies are going to take their time considering this kind of huge change. There is no product ever made that should not be taking their customers into consideration. When I see articles like this I feel annoyed, because the gist of the article is, “Why won’t these dumb customers see that what I have is good for them”. That is never a good way to get people to buy what you are selling.

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Improving Your Business Regulation - What is it Good For? The Industry

It’s Still a Regulated World

It seems like every few weeks I have a conversation with a carrier and in the course of conversation I find out that they are not in compliance with some regulation or another. It seems like a lot of companies that sell VoIP services, in particular, think that somehow that makes them immune from regulation.

But regulation has not gone away. If you bill an end-user customer for a voice, data or video product then there are regulations that you have to comply with. If you are an ISP for other entities, even if those entities are large, you are subject to some regulation. The only category of carrier that might not be subject to regulation is what I call a carrier’s carrier, and who only serves other carriers as customers. And in some states even they are subject to regulation.

It matters that you follow the rules. It seems like regulators at both the state and the federal level are getting surly about offenders and there some big fines being handed down to carriers who ignore regulation. I think the cost of compliance is cheaper than the cost of getting caught.

Here is a sample of the kinds of federal regulations that we see carriers ignoring. There are other state requirements that are also being ignored:

  • CALEA. There are significant obligations to be read to immediately give access of your customer’s voice and data records to law enforcement. You must have a manual filed that describes the processes.
  • CPNI / Privacy. You must have a manual and processes describing how you will protect your customers’ privacy.
  • Red Flag. You must have a manual and processes in place to demonstrate how you will protect your customers from identity theft.
  • Net Neutrality. There is very specific information about your company, your products, your network and your technology that you must inform customers about.
  • 21st Century Communications Video Accessibility Act. You must file a plan on how you will help disabled customers get access to voice, video and data products.
  • Universal Service Contributions. We find carriers that should be contributing to the USF fund who are not. The fines for getting caught for this can be huge.

I told my readers that I wasn’t going to write too many blog entries that are direct sales pitches for CCG services. I will admit that many of my blogs hint at the services we offer, but the main intentions of these blogs is to discuss issues for carriers that I think they will find to be useful. But in many cases CCG is able to help clients with a lot of the topics discussed in my blog.

CCG has three regulatory products that make it easy for anybody to stay in compliance with the rules. We have many clients who use CCG as their regulatory arm and many have said that it’s far cheaper to use us than to do it themselves. Here are the three products you ought to consider if you want to hand make sure that you are in compliance with the regulatory side of the business.

Regulatory Assessment. We will do a one-time assessment of your business and tell you every regulation that we think applies to you. Why guess if you are in compliance. For a modest fee we will make a list.

Regulatory Compliance Monitoring Service. In this service we develop a calendar for your company and we remind you of every regulatory deadline you must meet during the year.

Regulatory Compliance Filing Service. If you want it, we can create all of the needed paperwork and manuals, fill out the quarterly and annual forms and file everything for you. We think we have some of the best prices in the market for this kind of work.

If you want help to get into regulatory compliance or stay incompliance, give Terri Firestein of CCG a call at (301) 788-6889. We can help you take regulatory worries off your plate.

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Regulation - What is it Good For? Regulatory Alerts

Regulatory Alert: Annual Access Charge Reform Tariff Filings Coming Due

Seal of the United States Federal Communications Commission. (Photo credit: Wikipedia)

The second year of access reform is here again and most LECs and CLECs will need to file revised access rates by July 1. However, you should be aware that many State Commissions have their own requirements and time frames that need to be addressed in advance of the FCC’s date. As an example, the Public Utilities Commission of Ohio is directing that all affected ILECs and CLECs file the appropriate intrastate tariff amendment application or letter of compliance on or before May 1, 2013. This alert is to warn that in many states you are not going to have the luxury of waiting until July 1 to file your rates.

These filings are due to FCC Report and Order (WC Docket No. 07-135) which adopted a transitional intercarrier compensation restructuring framework for both intrastate and interstate interexchange and reciprocal compensation telecommunications traffic. In its recent March 26, 2013 release (WC Docket No.13-76) the FCC established procedures for the 2013 filing of annual access charge tariffs and Tariff Review Plans (“TRP”) for price cap ILECs, rate-of-return ILECs and CLECs that benchmark rates to price cap or rate-of-return ILECs. The Order sets an effective date of July 2, 2013 for the July 2013 annual access charge tariff filing. The Order establishes May 17, 2013 as the date that price cap ILECs must file their short form TRP. Affected ILECs and CLECs may make their tariff filings on either a 15 or 7 day notice (prior to the effective date) therefore affected ILECs and CLECs filing on a 15 day notice must file on June 17, 2013 and those filing on a 7 day notice must file on June 25, 2013. All filings must be made using the FCC’s Electronic Tariff Filing System (“ETFS”).

You also need to be aware that as part of the annual access charge tariff filing carriers will need to include the universal service charge contribution factor for the third quarter which begins on July 1, 2013. Note that in accordance with 47 C.F.R. § 54.712 of the FCC’s rules “…if a contributor chooses to recover its federal universal service contribution costs through a line item on a customer’s bill the amount of the charge may not exceed the interstate telecommunications portion of that customer’s bill times the relevant contribution factor.”

If you need help with these filings let us know. CCG also offers a service we call Regulatory Compliance where we notify our clients each year of every regulatory filing they need to make. It’s affordable and a great way to make sure that you meet all of your regulatory filing requirements.  Call Terri Firestein at CCG if you need help or want more information. She is at (301) 788-6889.

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