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Advancing The Cause of Competition in the Telecommunications Industry
FCC REGULATORY FEES DUE NO LATER THAN SEPTEMBER 7th
The Federal Communications Commission has published a notice in the
Federal Register announcing the Fiscal Year 2005 Regulatory Payment
window is now available to accept annual regulatory fee payments.
Regulatory fee payments will be accepted from August 23, 2005 through
September 7, 2005. Any payments received after 11:59 p.m. September
7, 2005 will be assessed a 25% late fee.
If your company is registered with the FCC as an interstate carrier
(i.e., Form 499 registration) you should have already received an
invoice for Regulatory Fees.
FCC EXTENDS VoIP E-911 REPORTING AND COMPLIANCE DEADLINES
On July 26, 2005, the FCC's Enforcement Bureau released a "guidance"
notice to Interconnected VoIP providers regarding the July 29, 2005
E-911 customer notification deadlines. In the notice, the Bureau
provided additional information concerning its planned enforcement of
the VoIP E-911 subscriber notification provisions of the FCC's Rules.
The FCC also extended the deadline for compliance by 30 days, to
approximately August 29, 2005, provided the VoIP provider has met
certain reporting requirements by August 10, 2005.
FCC ENFORCEMENT BUREAU PROPOSES OVER $2.5 MILLION IN FORFEITURES
AGAINST 5 CARRIERS FOR ALLEGEDLY VIOLATING USF AND OTHER REGULATORY
PROGRAM RULES
In the past month, the FCC has issued Notices of Apparent Liability
("NALs") totaling over $2.5 million against five telecommunications
carriers for apparently violating Universal Service Fund ("USF") and
other regulatory program laws, including those for the Telecommuni-
cations Relay Service ("TRS"), the North American Numbering Plan
Administration ("NANPA"), and regulatory fees.
The programs at issue in the NALs further important statutory and
regulatory goals. The USF ensures that consumers in all regions of
the nation have access to affordable, quality telecommunications
services. The TRS fund enables persons with hearing or speech
disabilities to communicate by telephone with the help of a relay
operator. The NANPA ensures the equitable availability of telephone
numbers. Regulatory fees distribute the cost of certain regulatory
activities. Under the Communications Act and the Commission's rules,
every telecommunications carrier that provides interstate service must
contribute to these programs on an equitable basis. The Commission
requires carriers to register with the Commission in order to monitor
activities in the telecommunications marketplace.
The five corporations that are the subject of the NALs are: Carerra
Communications, LP, InPhonic, Inc., Teletronics, Inc., Telecom
Management, Inc., and OCMC, Inc.
According to FCC News Releases, the NALs help level the playing field
for all telecommunications carriers by demonstrating a "no tolerance
policy" for any carrier that fails to pay its required USF and other
regulatory obligations. The apparent violations distort the
marketplace by causing carriers in compliance with the requirements to
carry a disproportionate share of the costs of funding these programs
and frustrate the purposes for which Congress and the Commission
established the programs.
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The Front Lines is a free publication of The Helein Law Group, P.C.,
providing clients and interested parties with valuable information,
news, and updates regarding regulatory and legal developments
primarily impacting companies engaged in the competitive
telecommunications industry.
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The Helein Law Group, P.C.
8180 Greensboro Drive, Suite 700
McLean, Virginia 22102
Jonathan Marashlian (jsm@thlglaw.com)