On December 22nd, our firm circulated an advisory reminding clients of various regulatory filing requirements for “Billing Telephone Corporations” providing service in California. The advisory included an outdated definition of “Billing Telephone Corporation.” Under current CPUC rules, a “Billing Telephone Corporation” is any “telephone corporation that bills a Subscriber for products and services provided by a third-party, including corporate affiliates.”
Accordingly, only telephone corporations that bill customers for third-party services or products must file the required reports.
A firm advisory sent on December 27th, discusses special considerations for VoIP given the lack of clarity as to whether nomadic I-VoIP providers qualify as “telephone corporations.”
If you have any questions, please contact your assigned attorney.