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On April 25, 2023, the Federal Communications Commission “(FCC” or Commission”) released a Notice of Proposed Rulemaking (“NPRM”) that foreshadows a potentially radical revision to the regulatory framework governing the provision of international telecommunications services.  Such services are regulated under Section 214 of the Communications Act of 1934 (“Section 214”), and the FCC’s rulemaking is considering changes to almost every aspect of the authorization lifecycle.  If the proposed rules are largely adopted, following public comment and follow-on lobbying in the coming months, the result will be a substantially increased compliance burden for international telecommunications carriers which may complicate their investment and transactional strategies.  Right now, this is a situation of a few “knowns” and a lot of open questions.  (Note that the NPRM generally does not propose rule changes with regard to domestic (i.e., interstate) Section 214 authority obligations.)

Accompanying the NPRM was an Order that mandates a one-time data request for ownership information to all holders of international Section 214 authority.  See our FAQs document describing the Order.  The response deadline is not yet known as the Office of Management and Budget must first complete a review of the Order’s information collection obligations.  The response deadline will be at least thirty days after the OMB review is completed as announced in the Federal Register.

Continue Reading FCC Considering Major Changes to Section 214 Application and Authorization Rules

On this episode of Full Spectrum, Senior Associate Winafred Brantl discusses the Commission’s proposed significant changes to the International Section 214 regime. Responding to growing concerns regarding undisclosed foreign ownership of international Section 214 carriers, the FCC will conduct a one-time data collection from all international Section 214 authorization holders and has proposed a requirement

The Federal Communications Commission (“FCC”) adopted an Order on April 20, 2023 imposing a one-time ownership-related data request to which all holders of international Section 214 authority must respond.  The due date for affected carriers to respond is not yet known and will be established after review and approval of the FCC’s Order by the

A May 2013 California Public Utilities Commission decision requires most companies holding a California CPCN or wireless registration (“WIR”) to submit a $25,000 continuous performance bond. The decision also revises application/registration requirements, increases filing fees and sets a minimum annual User Fee.   In addition, the CPUC will convene a workshop to consider whether to require VoIP providers to register with the Commission.

The primary impact of this decision for most providers in California will be the new performance bond requirement.  The CPUC’s bond requirement takes effect on August 21, 2013.  Thereafter, entities failing to obtain a performance bond may be subject to revocation proceedings.

Continue Reading California Requires Most Carriers to Post a Performance Bond

On July 17th, the FCC adopted a consent decree entered into between the Enforcement Bureau and AccessLine Communications Corporation, a facilities-based and resold long distance carrier holding domestic and international Section 214 authority. The consent decree, which resolved an investigation into alleged unauthorized transfers of control by AccessLine and its parent, Telanetix, is but the