Advisories

FCC Clarifies Video Conferencing Services Must Be Accessible to People with Disabilities and Proposes Additional Enhancements for Deaf Users

At its June 8 open meeting, the FCC voted to adopt a Report and Order clarifying that interoperable video conferencing services must be accessible to, and usable by, people with disabilities as advanced communications services, under the Twenty-First Century Communications and Video Accessibility Act (CVAA). The new rules will apply to video conferencing services widely […]

FCC Imposes Record Fine on PayG, LLC for Failure to Pay Universal Service Fund Contributions

The Federal Communications Commission (FCC) today released Notice of Apparent liability for Forfeiture (NAL), which would fine PayG, LLC almost $1.5 million for underpaying and failing to timely pay Universal Service Fund (USF) contributions between 2018 and 2021. During this time, the FCC charged that PayG not only failed to fully pay its required contributions […]

FCC Reminds Small Facilities-Based & Gateway Voice Service Providers of Rapidly Approaching June 30, 2023 STIR/SHAKEN Compliance Deadline 

The Federal Communications Commission (“FCC” or “Commission”) Tuesday issued a Public Notice reminding small facilities-based voice service providers (“VSPs”) and gateway carriers that they must fully implement the STIR/SHAKEN caller ID authentication framework in their Internet Protocol (IP) networks no later than June 30, 2023.  As stated in the Fourth STIR/SHAKEN Report & Order, the […]

Enforcement Bureau Proposes $100,000 Fine Against RevTel for Non-Responsiveness, Failing to Provide Documentation, and Lack of Cooperation with both USAC and FCC  

Last week, the Federal Communications Commission’s (FCC) Enforcement Bureau issued a Notice of Apparent Liability for Forfeiture and Order (NAL) against RevTel Communications, for failing to respond to directives from USAC to provide documentation supporting information reported in its annual telecommunications reporting worksheets for the 2020 through 2022 period.  The Enforcement Bureau (EB) proposed a […]

Comment Deadlines Established for Proposed New STIR/SHAKEN Rules

As stated in our previous client advisory, the Federal Communication Commission (“FCC” or “Commission”) in March 2023 released a Notice of Proposed Rulemaking (“NPRM”) seeking comment on two important proposed STIR/SHAKEN rules. When the NPRM was released, the comment and reply comment deadlines were not established. On May 5, 2023, the NPRM was published in […]

FCC Releases Text of Rulemaking Proposing Sweeping Changes to Regulation of International Telecom Providers Operating in the US

As discussed in our firm’s April 21st Client Advisory, the Federal Communications Commission (“FCC” or “Commission”) announced a Notice of Proposed Rulemaking (NPRM) that proposed rules requiring all companies providing international telecommunications services pursuant to Section 214 authorization (214 License) to file renewal applications every ten (10) years; also ordering all 214 license holders to […]

FCC Proposes to Require All Holders of Section 214 International Authorizations to File Renewal Applications; Also Orders One-Time Collection of Information 

On April 20, 2023, the Federal Communications Commission (FCC) adopted a Notice of Proposed Rulemaking (NPRM) proposing rules requiring all companies providing international telecommunications services pursuant to Section 214 authorization (214 License) to file renewal applications every ten (10) years.  In an Enforcement Advisory released the same day, the FCC reminded current holders of international […]

FTC Implements Extensive Program to Prevent Illegal Robocalls Originating Overseas: Gateway VoIP Providers Are Targeted for Enforcement Actions

The Federal Trade Commission (“FTC”) Tuesday issued a Press Release announcing its Project Point of No Entry (“PoNE”) program, aimed at preventing foreign-originated illegal robocalls from reaching U.S. consumers. PoNE is targeted at gateway voice over internet protocol (“VoIP”) providers. A gateway provider is a U.S.-based intermediate carrier that has facilities in the U.S. and […]

Form 499 Filers Beware! Risks and Consequences are High for Carriers Reporting Wholesale Revenue in Reliance on USF Exemption Certification Forms

This year’s FCC Form 499 deadline, April 3rd, is fast approaching. For wholesale telecommunications providers, common pitfalls in reporting practices could leave you at risk of greater exposure to USF liability. In particular, all revenues reported in Block 300 as “wholesale” and exempt from USAC’s USF assessment must be properly supported by documentation in order […]

CJEU Issues Judgment on Legal Framework for Lawful Interception Obligations and Costs Incurred by Electronic Communications Providers

First of all, were you aware that in some European countries, service providers are compensated/ reimbursed by the regulatory authority and/or government, itself, when law enforcement engages in lawful intercept activities that impose burdens on the service provider? This is, in fact, true! But the rules of the road governing “whether” and “how much” reimbursement […]

FCC IMPOSES ROBOTEXT PREVENTION REQUIRMENTS ON MOBILE WIRELES PROVIDERS; SEEKS COMMENTS ON ADDITIONAL PROPOSED ROBOTEXT RULES

The Federal Communications Commission (“FCC” or “Commission”) Friday issued a Report & Order and Further Notice of Proposed Rulemaking that requires mobile wireless carriers to implement new robotext mitigation measures and seeks comments on additional proposed robotext rules. The compliance deadline for the new regulations is six months after the document is published in the […]

Advanced Communications Providers Must File Supply Chain Annual Reports by March 31, 2023

In a recent Public Notice, the Federal Communications Commission (“FCC” or “Commission”) reminded providers of advanced communications services (“ACS”) of their obligation to file Supply Chain Annual Reports by no later than March 31, 2023. The FCC defines ACS carriers as those that “provide high-speed, switched, broadband telecommunications capability that enables users to originate and […]

FCC USF Fee Factor Decreases to 29% from 32.6% for Q2 2023

The FCC Managing Director issued a Public Notice on March 14, 2023, announcing the proposed Universal Service Fund (“USF”) contribution factor for the second quarter of 2023 will be 29% down from the previous quarter’s 32.6%. Any reforms of the USF contribution system will likely take months — and potentially longer — to materialize in […]