Initial commit — Performance West telecom compliance platform

Includes: API (Express/TypeScript), Astro site, Python workers,
document generators, FCC compliance tools, Canada CRTC formation,
Ansible infrastructure, and deployment scripts.

Co-Authored-By: Claude Opus 4.6 (1M context) <noreply@anthropic.com>

scripts/document_gen/templates/guides/material_change_procedures.md

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+# Material Change Update Procedures Guide
+
+## Implementation Handbook for Voice Service Providers
+
+**Prepared by Performance West Inc.**
+**Effective Date: 2026**
+
+---
+
+## 1. What Is the Material Change Requirement?
+
+Under the FCC's 2025 RMD Report & Order (effective February 5, 2026), all providers with an RMD filing must update their certification within **10 business days** of any material change to their operations, ownership, or filing information.
+
+Failure to update within 10 business days can result in a **$1,000 per day forfeiture**.
+
+**Regulatory basis:** 47 CFR § 64.6305, 2025 RMD Report & Order (FCC 25-6)
+
+---
+
+## 2. What Counts as a Material Change?
+
+| Category | Examples |
+|---|---|
+| **Ownership** | Change in controlling interest, merger, acquisition, new parent company |
+| **Corporate identity** | Legal name change, DBA change, new EIN |
+| **Contact information** | New robocall mitigation contact person, email, phone, address |
+| **STIR/SHAKEN status** | Change from partial to full implementation, switch to a different STI-CA, loss of SPC token |
+| **Provider classification** | Adding gateway operations, ceasing to be a VSP, becoming an intermediate provider |
+| **Upstream provider** | Changing the upstream carrier that provides STIR/SHAKEN signing |
+| **Robocall mitigation program** | Significant changes to KYC procedures, analytics vendors, blocking policies |
+| **Trade names / DBAs** | Adding or removing names under which you operate |
+
+---
+
+## 3. Implementation Steps
+
+### Step 1: Designate a Compliance Officer
+
+Assign one person (and a backup) as the **RMD Compliance Officer** responsible for:
+- Monitoring for material changes
+- Initiating the update process within 10 business days
+- Maintaining an audit trail of updates
+
+**Recommended:** The same person who is listed as the RMD contact on your filing.
+
+### Step 2: Create a Material Change Checklist
+
+Post this checklist where operations, legal, and management teams can see it:
+
+**When ANY of the following occur, notify the RMD Compliance Officer immediately:**
+
+- [ ] Company name or DBA changed
+- [ ] Ownership or controlling interest changed
+- [ ] New parent company, merger, or acquisition
+- [ ] RMD contact person changed (name, email, phone)
+- [ ] Principal office address changed
+- [ ] STIR/SHAKEN certificate authority changed
+- [ ] SPC token renewed, revoked, or transferred
+- [ ] Upstream provider changed
+- [ ] Provider type changed (added/removed VSP/gateway/intermediate)
+- [ ] Robocall mitigation program materially revised
+- [ ] New analytics vendor deployed or existing vendor discontinued
+- [ ] Trade names added or removed
+
+### Step 3: Establish an Internal Notification Process
+
+Create a simple workflow:
+
+```
+Change occurs (e.g., new upstream provider signed)
+    ↓
+Department head notifies RMD Compliance Officer (email/ticket)
+    <20><><EFBFBD>
+Compliance Officer logs the change in the tracking spreadsheet
+    ↓
+Within 5 business days: prepare updated RMD filing content
+    ↓
+Within 10 business days: submit update to FCC RMD portal
+    ↓
+Confirm update accepted, save confirmation screenshot
+```
+
+### Step 4: Update the RMD Portal
+
+To submit an update:
+
+1. Log in to the FCC RMD portal at https://apps.fcc.gov/rmd/ (MFA required since Feb 5, 2026)
+2. Navigate to your existing certification
+3. Click "Update" or "Edit"
+4. Modify the relevant fields
+5. Re-upload your certification letter/Exhibit A if the mitigation plan changed
+6. Submit and save the confirmation page
+
+**Or:** Contact Performance West — we can submit the update on your behalf as your authorized filing agent.
+
+### Step 5: Maintain an Audit Trail
+
+Keep a log of all material changes and RMD updates:
+
+| Date | Change Description | Notified By | Updated in RMD | Confirmation # |
+|---|---|---|---|---|
+| 2026-03-15 | New upstream provider (ABC Telecom) | VP Engineering | 2026-03-18 | RMD-UPD-12345 |
+| 2026-04-01 | Contact email changed to new@company.com | HR | 2026-04-03 | RMD-UPD-12346 |
+
+---
+
+## 4. Documenting Material Change Procedures in Your RMD Filing
+
+Your RMD certification should include:
+
+> "[Company Name] updates its RMD certification and CORES registration within 10 business days of any material change, including but not limited to changes in ownership, contacts, STIR/SHAKEN posture, upstream provider, or trade names, per 47 CFR § 64.6305. A designated compliance officer monitors for material changes and maintains an audit trail of all updates."
+
+---
+
+## 5. Penalties for Non-Compliance
+
+| Violation | Penalty |
+|---|---|
+| Failure to update within 10 business days | $1,000/day forfeiture |
+| False or inaccurate information in filing | $10,000 base forfeiture |
+| Failure to maintain compliant certification | Removal from RMD (downstream carriers must block your traffic within 30 days) |
+
+---
+
+## 6. Common Mistakes to Avoid
+
+| Mistake | Consequence |
+|---|---|
+| No material change language in RMD filing | Filing flagged as deficient |
+| Updating only annually during recertification | Misses the 10-day requirement for mid-year changes |
+| No internal notification process | Changes happen without anyone updating the RMD |
+| Updating the filing but not the Exhibit A | Inconsistency between certification and plan |
+| No audit trail | Cannot demonstrate timely compliance if audited |
+
+---
+
+*This guide is provided for informational purposes as part of your RMD filing service. It is not legal advice.*
+
+*Performance West Inc. — performancewest.net — 1-888-411-0383*