Introducing the Series

Most MVNO compliance failures aren't failures of knowing. The obligations are documented. The forms are public. The deadlines are on a calendar somewhere. Form 499-A is famous. The CPNI annual certification under Section 64.2009(e) is well-understood. State PUC registration requirements are a Google search away.

The failures are failures of running. They are operational failures.

A small MVNO grows past the threshold where reactive compliance works. Filings get missed. Evidence isn't kept. The first sign of trouble shows up in a diligence process, a carrier audit, or a USAC red letter — and by then there are usually two years of gaps to remediate. The cost is rarely the fine itself. The cost is the delayed transaction, the breached MVNO agreement, the enforcement inquiry that consumes six months of executive time.

This is the gap most MVNO compliance writing doesn't address. Strategy and regulatory-obligation content is abundant. What you owe and which forms exist are covered well in trade publications, legal briefings, and the FCC's own materials. How a compliance function actually runs — who owns it, what they own, how they execute, and how they prove they did — is covered almost nowhere.

This series goes operational.

What the Series Covers

Article 1: Who Owns MVNO Compliance Operations. The ownership question is the first one most MVNOs get wrong. Compliance gets assigned by default to the CFO (because USF is a remittance), to external counsel (because regulation feels legal), or to the founder (because everything starts with the founder). All three are anti-patterns. The case for COO ownership rests on a simple observation: compliance is operational work. The dependencies live in operations. The evidence lives in operational systems. The authority to compel that evidence belongs to the COO. The first article makes that case, names the failure modes the alternatives produce, and lays out what falls under the compliance operations owner.

Article 2: Running MVNO Compliance Operations. Once ownership is settled, the function still has to run. That means a maintained compliance calendar, an evidence repository that survives an audit, a pre-filing review workflow, and a measurement framework that tells the executive team and board whether compliance is actually performing. The second article covers the operational mechanics — including the KPIs most compliance functions never define — and closes with a remediation playbook for organizations inheriting compliance debt.

Who This Is For

The series is written for COOs, CFOs, General Counsel, and founders at MVNOs, MVNAs, and MVNEs operating in the U.S. wireless market. It assumes familiarity with the general regulatory landscape — what USF is, what CPNI means, what a state PUC does. It does not attempt to teach those obligations. It addresses how to run against them.

Operators with established compliance functions will find the framing useful for stress-testing what they have. Operators building from scratch will find the structural recommendations directly applicable. Operators discovering compliance debt mid-flight will find the remediation guidance in Article 2 worth the read.