There are some PBX's with DS1 (T1) cards that are not FCC registered, and the manufacturers won't bother doing that because of the homologation nightmares it creates.
They would rather let the CSU manufacturers get all the local registry approvals, and just certify their equipment to work with the CSU's.
However, Avaya has registered not only the 120A CSU, but also the DS1 card.
From the Definity pocket reference book FCC references section:
Manufacturer’s Port SOC/REN/
Identifier FIC Code A.S. Code Network Jacks
Off/On premises station OL13C 9.0F RJ2GX,RJ21X,RJ11C
DID trunk 02RV2-T 0.0B RJ2GX,RJ21X
CO trunk 02GS2 0.3A RJ21X
CO trunk 02LS2 3.0A RJ21X
Tie trunk TL31M 9.0F RJ2GX
1.544 digital interface 04DU9-B,C 6.0F RJ48C,RJ48M
1.544 digital interface 04DU9-BN,KN 6.0F RJ48C,RJ48M
120A2 channel service unit 04DU9-DN 6.0F RJ48C
It, of course, mentions all the same "you must accept interference, you must disconnect if you cause damage" statements, but it's not illegal (in the US anyway)to connect directly.
The CSU is just that, a channel service unit. If you need to break off a few channels to a separate piece of equipment, or your signal degrades over distance, a CSU is what you need. If you're just connecting a whole T1 to a PBX, and the copper portion of your T1 is only 30-50 feet long, you can easily do without them.
Carpe dialem! (Seize the line!)