Advisories

FCC Announces Proposed USF Contribution Factor of 23.8% for Q2 2022

The Federal Communications Commission announced the proposed universal service contribution factor for the second quarter of 2022 will be 23.8%.   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 minimize the economic impact of federal USF contribution […]

M&D Associate Attorney Michal Nowicki to Speak About CVAA Compliance in Entertainment at ACCESS, a Virtual Conference on Media Accessibility

We at Marashlian & Donahue are pleased to announce that Associate Attorney Michal Nowicki will be speaking at ACCESS, a virtual conference from 3Play Media that focuses on inclusivity and accessibility in media. Specifically, Mr. Nowicki will host a panel alongside Tom Wlodkowski, Vice President, Accessibility and Multicultural Technology and Product at Comcast, titled “Understanding […]

Public Knowledge Asks the FCC to Reclassify I-VoIP as a Title II Common Carrier Service, Implicating a Potential Onslaught of Onerous Federal and State Regulatory Obligations

On Wednesday, March 2, 2022, Public Knowledge, a nonprofit organization that seeks to promote open access to the Internet and other communications tools, filed a Petition for Declaratory Ruling with the Federal Communications Commission (FCC) asking the Commission to classify interconnected Voice Over Internet Protocol (I-VoIP) services as Title II common carrier services. If the […]

Incremental Action Foreshadows Greater Future Broadband Competition Scrutiny in Multiple Tenant Environments

On February 15, 2022, the Federal Communications Commission (FCC) released a Report and Order and Declaratory Ruling (Order) intended to promote broadband competition and benefit people living and working in apartments, condos, office buildings, and other multiple tenant environment (MTE) buildings. Specifically, the Order: Adopts new rules prohibiting providers from entering into certain revenue-sharing agreements […]

FCC Withdraws STIR/SHAKEN Exemptions From Vonage and Bandwidth for Failure to Update Networks

On Thursday, February 17, 2022, the Federal Communications Commission released an Order that withdrew STIR/SHAKEN exemptions from two voice service providers, Vonage and Bandwidth. The FCC found that these providers failed to fully implement STIR/SHAKEN following the period of leniency granted to them by the exemption. The FCC has referred Vonage and Bandwidth to the […]

FCC Slams IK Communications with a $100,000 Fine for Failure to Respond to LOI and Failure to File 499-A Forms Over 6 Years

On Thursday, February 17, 2022, the Federal Communications Commission (FCC) released a Notice of Apparent Liability for Forfeiture (NAL) that detailed the proposed penalty assigned to IK Communications, a New Jersey-based prepaid calling card provider, for failure to file annual Telecommunications Reporting Worksheets (Worksheets) with the Universal Service Administrative Company (USAC) to support the FCC’s […]

FCC Steps Up Enforcement of Illegal Robocalls: Demands Carriers Immediate Cease Transmissions and Collaborates with State AGs to Broaden Dragnet

In its continuing efforts to combat unlawful robocalls and malicious caller ID spoofing, the Federal Communications Commission (“FCC”) is sending out a flurry of cease-and-desist letters to entities that are transmitting illegal robocalls, and is working with State Attorneys General to “build robocalling partnerships” to enhance enforcement efforts. Robocall Suspects are Being Investigated and Threatened […]

FCC Cuts STIR/SHAKEN Compliance Extensions for Small Voice Providers, Database Updates Required; FCC Emails Spark Confusion Over Compliance Duties of Non-Facilities-Based Resellers

The FCC’s Fourth STIR/SHAKEN Report and Order (“R&O”) will go 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 […]

New Frontier for Robocall Enforcement Emerges: In a Carrier vs Carrier Lawsuit, Frontier Communications Alleges VoIP Provider, Mobi Telecom, Purposefully Fails to Implement Illegal Robocalling Mitigation Efforts Resulting in Damages Inflicted Upon Frontier

Frontier Communications recently filed suit against voice provider Mobi Telecom for violating Connecticut unfair trade practices law by “intentionally and recklessly” facilitating illegal robocalls. This suit highlights the emerging threat of private litigation that seeks to stave off relentless scam calls and adds yet another dimension to the complex, expansive, and evolving “Robocall Mitigation Enforcement […]

ALERT: NEW FCC COMPLIANCE FILING MAY APPLY TO YOUR COMPANY – Supply Chain Report Due May 5, 2022, Applies to All Providers of Advanced Communications Services

IF YOUR COMPANY PROVIDES ANY “ADVANCED COMMUNICATIONS SERVICE” (WHICH INCLUDES, BUT IS NOT LIMITED TO, BROADBAND SERVICES), A NEW FCC COMPLIANCE REPORTING OBLIGATION WITH A MAY 5, 2022 FILING DEADLINE APPLIES TO YOUR COMPANY!   IF YOU NEED HELP WITH ANY OF THE FOLLOWING ISSUES, CONTACT US AS SOON AS POSSIBLE! Is the reporting obligation applicable […]

FCC Proposes New Point-of-Sale Labeling Requirements for Broadband Service Providers

On January 27, 2022, the Federal Communications Commission proposed new rules that would require broadband providers to display labels that convey critical broadband service information to better enable consumers to comparison shop for broadband services. The FCC released a Notice of Proposed Rulemaking that details these proposed changes and is currently seeking comments from the […]

FCC Commissioners to Vote on Proposed Limitations to Internet Service Providers’ Ability to Contract with Multiple Tenant Environment Buildings

On Friday, January 21, the Federal Communications Commission (FCC) shared a press release that included proposed changes to existing regulations to promote competition between Internet service providers. Chairwoman Jessica Rosenworcel circulated a Report and Order and Declaratory Ruling to her fellow Commissioners that would place limitations on agreements between providers and multiple tenant environment (MTEs) […]

Comments Sought by FCC for Accessibility Requirements for Closed Captioning Settings for Video Apparatus: Now is the Time for Your Company to Weigh In

On January 10, 2022, the Federal Communications Commission (“FCC” or “Commission”) Media Bureau released a Public Notice reviving a stalled rulemaking proceeding to clarify disability access requirements for closed captioning display settings for digital apparatus, to ensure consumers with hearing loss can fully enjoy video programming. The proposed rules, if adopted, would clarify how manufacturers […]

Proposed Changes to CPNI Breach Notification Requirements of Telecom Carriers Announced by FCC Chair

On Wednesday, January 12, the Federal Communications Commission (FCC) published a press release proposing changes to existing regulations concerning the notification responsibilities of telecommunications carriers following a breach of customer proprietary network information (CPNI). Chairwoman Jessica Rosenworcel has circulated a Notice of Proposed Rulemaking (NPRM) to her fellow Commissioners and will seek comments from the […]

FCC Seeks Comments on Proposed Rules Mandating Consumer Disclosures by Broadband ISPs (aka, “Nutrition Labels”)

The Federal Communication Commission (FCC) plans to take up a proposal to require “Nutrition Labels” for broadband service at the commission’s public meeting set for January 27, 2022. The requirement for broadband service labeling stems from provisions in the $1.2 trillion Infrastructure Investment and Jobs Act. The funding bill established the FCC’s Affordable Connectivity Program […]