Advisories

FCC Establishes Registration Grace Period for VRS and IP CTS; Proposes Further Changes to VRS Regulations

On June 30, 2022, the Federal Communications Commission (“FCC” or the “Commission”) released an order and notice of proposed rulemaking (“NPRM”) collectively, the “Order” — updating the Commission’s regulations governing Video Relay Service (“VRS”) and Internet Protocol Captioned Telephone Service (“IP CTS”), and proposing additional regulatory changes under these telecommunications relay service (“TRS”) programs. The […]

California Public Utilities Commission Muddies the Waters on State Regulation of Nomadic I-VoIP

As a result of the California Public Utilities Commission’s (“CPUC”) elimination of the simplified interconnected Voice over Internet Protocol (“I-VoIP”) registration form, nomadic I-VoIP providers entering the California market are left without a means to register and remit applicable California Public Purpose Program (“Program”) surcharges. The Commission has recognized its oversight and plans to initiate […]

FCC Rules Voicemail Must be Accessible to Persons with Disabilities and Continues Cracking Down on Violators of Accessibility Laws 

In its latest disability access enforcement action, the Federal Communications Commission (“FCC” or the “Commission”) granted a consumer complaint (the “Complaint”) alleging that Verizon’s Premium Visual Voicemail service is inaccessible to persons with disabilities, in violation of Commission rules implementing Section 255 of the Communications Act. The FCC determined that Verizon failed to show that […]

FCC Announces Proposed USF Contribution Factor of 33% for Q3 2022

The Federal Communications Commission announced the proposed universal service contribution factor for the third quarter of 2022 will be 33%, a whopping ~10% increase from the prior quarter!   If your company has any questions or would like to engage in a Communications Taxes & Fees “Optimization” or learn about other Operational Best Practices to potentially […]

FCC & Canadian Counterpart Sign MOU to Combat Illegal Robocalls

On June 6, 2022, the Federal Communications Commission (“FCC” or “Commission”) issued a News Release, announcing that the FCC had signed Memorandum of Understanding (“MOU”) with the Canadian Radio-television and Telecommunications Commission (“CRTC”). to combat illegal robocalls. Referring to robocall scams as “an international problem,” FCC Chairwoman Jessica Rosenworcel pledged to “work closely with partners […]

FCC Imposes New Regulations on Gateway Providers

On May 20, 2022, the Federal Communications Commission (“FCC” or “Commission”) released a Sixth Report & Order and Seventh Further Notice of Proposed Rulemaking (“R&O” and “FNPRM”), imposing additional regulatory requirements on the gateway providers that are the point of entry for foreign-originated illegal robocalls into the United States, and soliciting comments on, among other […]

Accessible Canada Act – June 1 Filing Deadline for All TSPs, Ensure CRTC Compliance

All telecommunications service providers (TSPs) and broadcasters registered with the Canadian Radio-Television and Telecommunications Commission (CRTC) must comply with the CRTC’s first June 1, 2022, deadline pursuant to the Accessible Canada Act (ACA). TSPs and Broadcasters with at least 10 employees must act by June 1, 2022 deadline TSPs and broadcasters with at least 10 […]

First CRTC STIR/SHAKEN Status Reports Due May 31, 2022, from All Canadian TSPs

All Telecommunications Service Providers (TSPs) in Canada must fully implement STIR/SHAKEN as a condition of providing or offering service. On May 31, 2022, impacted TSPs must submit their first post-implementation STIR/SHAKEN status report. CRTC STIR/SHAKEN Requirements Cover All TSPs CRTC Decision 2021-123, which requires Canadian TSPs to implement STIR/SHAKEN to authenticate and verify caller ID […]

First Accessible Canada Act Deadline Approaching – Ensure Compliance Before the June 1 Deadline

Canadian telecommunications service providers (TSPs) and broadcasters with at least ten employees will soon need to take their first steps to begin compliance with the Accessible Canada Act (Act) and Telecom and Broadcasting Regulatory Policy CRTC 2021-215, which provides the Canadian Radio-television and Telecommunications Commission’s (CRTC) regulations implementing the Act. June 1, 2022 marks the […]

FCC Seeks Comments on “Interoperability” of Video Conferencing Service under the CVAA; Expansion of TRS Rules on the Horizon?

On April 27, 2022, the Federal Communications Commission (“FCC” or “Commission”) released a Public Notice inviting public comments to refresh the record on the scope of FCC regulations, implementing the Twenty-First Century Communications and Video Accessibility Act (“CVAA”), that require interoperable video conferencing services to be accessible to and usable by people with disabilities. Although […]

FCC Upholds USAC’s Interpretation of the Affiliate Filer Rule: Could Your Company Lose the Exemption?

On April 5, 2022, the Federal Communications Commission’s (“FCC” or “Commission”) Wireline Competition Bureau (“WCB” or “Bureau”) unexpectedly issued an Order denying BA Telecom’s appeal challenging the Limited International Revenue Exception (“LIRE”) Affiliate Rule’s application to BA Telecom’s Universal Service Fund (“USF”) contributor affiliates. The Order impacts investment decisions of all telecom carriers and interconnected […]

The Opportunities and Risks of 10 Digit-Long Codes and Bulk Business Text Messaging

Earlier this year, Linda McReynolds, Of Counsel to Marashlian & Donahue, participated in a webinar hosted by the Cloud Communications Alliance (CCA). Ms. McReynolds spoke about the potential opportunities and risks of ten-digit long codes (10DLC), which allow companies to directly text their customers through local numbers. Ahead of the webinar, Ms. McReynolds also recorded […]

New STIR/SHAKEN Deadline for “Non-Facilities-Based” Voice Service Resellers is Rapidly Approaching: Compliance Action Required

The FCC’s Fourth STIR/SHAKEN Report and Order (“R&O”) went into effect on February 24, 2022. As explained in an earlier Advisory the R&O shortens the current two-year extension for some categories of small voice service providers (“SVSPs,” those with 100,000 or fewer voice service subscriber lines) to fully implement the STIR/SHAKEN caller ID authentication standards. […]