Denise Smith

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International Facilities-Based Service Providers – List of Foreign Direct Termination Arrangement Routes Due to the FCC by November 14, 2018

International service providers likely celebrated when the Federal Communications Commission (“Commission”) eliminated the annual International Traffic and Revenue reporting requirement last year but may have forgotten about the Commission’s plan to issue targeted data requests, when necessary, to obtain information previously available from the annual report. Well the time has come and the Commission now … Continue Reading

Flurry of USF Audit Reports Expected by End of Year, Random Audits to Return in FY 2019

We attended the Audit Committee meeting at USAC’s quarterly business meeting this morning.  While much of the discussion concerned internal controls USAC has in place to oversee its functions, the business update portion of the meeting gave us a snapshot into contributor and beneficiary audit activity at USAC.  The presentation gave us some insight into … Continue Reading

Federal Communications Commission International Reporting Rule Changes Take Effect

Almost six months after releasing its October 2017 Order streamlining, eliminating, and revising certain international reporting requirements, on April 25, 2018, the Federal Communications Commission (“Commission”) published a public notice in the Federal Register announcing that the international reporting rule changes were effective on April 25, 2018.  While, in practice, a Commission rule waiver had … Continue Reading

FCC Commissioner O’Rielly Statement Hints at Possible Long-Awaited Movement on Team Telecom Review Process Reform

In 2016, the Federal Communications Commission (“FCC” or “Commission”) initiated a rulemaking proceeding proposing changes to the process of reviewing certain Section 214 and submarine cable landing license applications, conducted by the group of Executive Branch agencies commonly referred to as “Team Telecom.”  That proceeding largely stalled after the comment cycle ended later that year.  … Continue Reading

Federal Communications Commission Draft Order Proposes Possible Elimination and Further Streamlining of Section 43.62 Annual International Reports

In advance of its October 24, 2017 Open Meeting, the Federal Communications Commission (Commission) has released a Draft Report and Order (Draft Order) for Commission consideration that, if adopted, would eliminate the Section 43.62 annual International Traffic and Revenue Report  (International Traffic Report) and streamline the Section 43.62 annual Circuit Capacity Report (Circuit Capacity Report).  … Continue Reading

Proposed Fourth Quarter 2017 Universal Service Fund Contribution Factor Jumps – Poised to Hit New High

On September 12, 2017, the Federal Communications Commission’s (Commission) Office of the Managing Director (OMD) released a Public Notice proposing a universal service fund (USF) contribution factor of 18.8% for fourth quarter 2017.  This proposed contribution factor would be the highest rate since the USF program’s inception and likely reflects the impact of the declining … Continue Reading

UPDATE: August 2017 FCC Meeting Recap: FCC Announces Comment Deadlines for Proposed Changes to Broadband Data Collection

On August 24, 2017, the Federal Communications Commission (“FCC” or “Commission”) published in the Federal Register its Further Notice of Proposed Rulemaking (“FNPRM”) that explores ways to improve the value of data, collected on FCC Form 477, regarding the availability of mobile and fixed broadband and other communications services, and to identify and eliminate unnecessary … Continue Reading

August 2017 FCC Meeting Recap: FCC Proposes Changes to Broadband Data Collection

At its August Open Meeting, the Federal Communications Commission (“FCC” or “Commission”) voted unanimously in favor of a Further Notice of Proposed Rulemaking (“FNPRM”) that explores ways to improve the value of data, collected on FCC Form 477, regarding the availability of mobile and fixed broadband and other communications services, and to identify and eliminate … Continue Reading

ITSPs and CMRS Providers Can Now Review and Revise FCC Annual Regulatory Fee Information; September Payment Deadline Not Yet Set

By Public Notice released Friday, the Federal Communications Commission (FCC or Commission) announced that Interstate Telecommunications Service Providers (ITSP) and Commercial Mobile Radio Service (CMRS) providers can now log in to preview the provider’s FY2017 regulatory fee data in the FCC’s Fee Filer system.  ITSPs and CMRS providers have limited time to request any revisions … Continue Reading

International Bureau Reminds Filers – Section 43.62 International Traffic and Revenue Reporting Requirement Temporarily Waived

As we reported in an earlier blog post, on May 1, 2017, the Federal Communications Commission’s (Commission) International Bureau (Bureau) issued an Order temporarily waiving the annual Section 43.62 International Traffic and Revenue Reporting (the Traffic and Revenue Report) requirement.  The Traffic and Revenue Report filing, normally due by July 31 each year, is temporarily … Continue Reading

What to Expect at the FCC’s July 2017 Open Meeting

Below is Kelley Drye’s preview of the items under consideration at the Federal Communication Commission’s (FCC’s) upcoming monthly Open Meeting, to be held on July 13, 2017.  Consistent with the trend since he took over the Commission, Chairman Ajit Pai continues to schedule a large number of items.  Indeed, for the sixth month in a … Continue Reading

Commission Resolves Long-Pending Stratos and Morris USF Contribution-Related Petitions

In orders issued last week, the Federal Communications Commission (Commission) continues what appears to be a trend of resolving long-pending universal service fund (USF) contribution issues.  The Orders, released May 23, 2017 and May 24, 2017 by the Commission’s Wireline Competition Bureau (Bureau), ruled on petitions filed by, respectively, Morris Communications, Inc. (Morris) and Stratos … Continue Reading

International Bureau Temporarily Waives Section 43.62 International Traffic and Revenue Reporting Requirement

By an International Bureau (Bureau) Order (Order) released yesterday that temporarily waives the International Traffic and Revenue Reporting (the Traffic and Revenue Report) requirement, the Federal Communications Commission (FCC) appears to be moving steadily toward its overhaul of the Section 43.62 international reporting requirements.  As Kelley Drye reported in recent posts (here and here), in late … Continue Reading

Comment Deadlines Set for FCC’s Latest International Reporting Streamlining Rulemaking

As Kelley Drye reported in a post late last month, the Federal Communications Commission (FCC) is considering eliminating the FCC Rule 43.62(b) annual International Traffic and Revenue reporting obligation and streamlining the Rule 43.62(a) annual Circuit Capacity reporting requirements.  The FCC last overhauled these international reporting requirements a mere four years ago.  The FCC’s Notice … Continue Reading

Wireline Competition Bureau Explains No Presumption of Intrastate or Interstate Jurisdiction for Private Lines; Carriers Must Conduct Good Faith Inquiry Into Nature of Traffic Carried

By an Order issued late last week, the Wireline Competition Bureau (Bureau) provided important insight regarding determining the jurisdictional classification of private line revenues.  In ruling on long-pending petitions for reconsideration of Universal Service Administrative Company (USAC) audit findings regarding the classification of private line revenues, the Bureau explained that the longstanding Ten Percent Rule … Continue Reading

FCC Proposes Eliminating Annual International Traffic and Revenue Report and Streamlining Annual Circuit Capacity Report

At its March 23, 2017 Open Meeting, the Federal Communications Commission (FCC or Commission) voted unanimously to adopt a notice of proposed rulemaking (NPRM) seeking comment on a proposal to reduce certain reporting requirements for international telecommunications service providers (International Service Providers). In particular, the FCC proposes to eliminate, in its entirety, the annual International … Continue Reading

Don’t Miss Kelley Drye’s 8th Annual USF Update Webinar on February 23, 2017 at 12 PM ET

Kelley Drye is proud to present our 8th Annual Update on federal Universal Service Fund (USF) activities.  This one-of-a-kind webinar provides an in-depth discussion of trends and legal implications involving the Universal Service Fund, from contributions, to the four support funds, as well as audits and enforcement.  This educational event is intended to help attorneys … Continue Reading

FCC Regulatory Fees Order for FY 2016 Released; September 27 Payment Deadline Set

On September 6, 2016, the Federal Communications Commission released a Public Notice announcing a payment deadline for annual regulatory fees of no later than 11:59 PM Eastern Daylight Time on September 27, 2016.  Although the regulatory fees will not officially become effective until published in the Federal Register, entities that are required to pay fees … Continue Reading

FCC Annual Regulatory Fee Information for ITSP and CMRS’ Now Available for Review; No Fee Payment Date Set

The Federal Communications Commission (FCC or Commission) has just announced in a Public Notice that Interstate Telecommunications Service Providers (ITSP) and Commercial Mobile Radio Service (CMRS) providers can now log into the FCC’s Fee Filer system to preview the provider’s FY2016 regulatory fee data.  ITSPs and CMRS providers are encouraged to review their proposed fee … Continue Reading

Comment Deadlines Set for FCC Rulemaking Seeking to Expedite the Team Telecom Application Review Process

As Kelley Drye reported in an earlier post, the Federal Communications Commission (FCC) is moving quickly on efforts to expedite review of certain FCC applications, including, but not limited to, Section 214 and submarine cable-related applications, by the Executive Branch agencies known as Team Telecom.  In a May 2016 request to the FCC, the National Telecommunications and … Continue Reading

Details of Mandatory Network Outage Obligations for Submarine Cable Operators Released

As we noted in a prior post,  on June 24, 2016, the Federal Communications Commission (Commission) adopted new mandatory network outage reporting requirements for submarine cable licensees.  The Commission’s Submarine Cable Network Outage Reporting Order (Order), released Tuesday, identifies Commission expectations and provides exact rule language for the reporting requirements which had been described at only … Continue Reading

FCC Proposes Rules to Expedite Initial Stages of the Team Telecom Application Review Process

The Federal Communications Commission (“Commission” or “FCC”) is looking to jump start the initial steps of the Executive Branch process of reviewing certain applications, including Section 214 and submarine cable-related applications.  In a May 2016 request from the National Telecommunications and Information Administration (“NTIA”), NTIA proposed rule changes designed to facilitate more rapid opening stage … Continue Reading

FCC Imposes Mandatory Network Outage Reporting Requirements on Submarine Cable Licenses

The Federal Communications Commission (Commission) today adopted  mandatory network outage reporting requirements for submarine cable licensees less than a year after proposing to do so.  This mandatory reporting reflects a significant change from the voluntary submarine cable outage reporting system currently in place.  The new rules will apply to all submarine cable licensees, regardless of … Continue Reading

FCC Updates Some Network Outage Reporting Rules; Seeks Comment on Other Issues Including Broadband and Possible Expansion of VoIP Reporting

More than a year after seeking comment on proposed revisions to its communications network outage reporting (NOR) requirements, the Federal Communications Commission (FCC or Commission) has released an Order.  (The proposed NOR requirements for submarine cable systems was released in November 2015 and that proceeding remains pending.)  Recognizing that communications technology has evolved since the … Continue Reading
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