Under the rules governing the Federal Universal Service Fund (“FUSF”), all telecommunications service providers must determine what revenue is subject to direct FUSF contribution, and what revenue can be considered wholesale and exempt from contribution requirements.

Under the Federal Communications Commission’s (“FCC”) Carrier’s Carrier rule, FUSF contribution should only be made on retail, end-user services.

Wholesale carriers, or “Carrier’s Carriers,” that provide services to other carriers who contribute directly to the FUSF (or have customers which contribute directly to the FUSF) may exempt this revenue from contribution.

The Carrier’s Carrier Rule exempts revenue from FUSF contribution obligations on the basis of “wholesale” sales if the carrier can reasonably certify that their reseller-customers, or the reseller’s own carrier-customers, are directly contributing to FUSF.

Revenue not verified in accordance with the Carrier’s Carrier Rule must be classified as retail, end-user revenue and will be subject to direct FUSF contribution.

Specifically, wholesale carriers that do not maintain necessary documentation of direct contributor status from reseller-customers (e.g., an exemption certificate) will be responsible for contributing to the FUSF on all un-verified revenue.

This at-a-glance document covers FUSF exemption certificate overview for wholesalers (Carrier’s Carrier).