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USAC, Universal Service Fund and FCC Enforcement: Implementing Effective Compliance Risk Management

When the FCC implemented its Net Neutrality Rules and extended certain Title II regulations to Broadband services, the agency confirmed that it would not require Broadband Internet Access Service Providers (i.e. ISPs) to contribute to USF (at this time). Nonetheless, the anticipated expansion of USF funding recipients and the exclusion of Broadband revenue from the contribution base are certain to ratchet up the pressure on USAC and the FCC’s Enforcement Bureau to squeeze as much revenue from current USF contribution-eligible services as possible. This dynamic will set the stage for increased contributor audits and FCC enforcement, putting the FCC’s USF Strike Force to the test.