Wireless and Interconnected Voip Service Providers Required to Submit Traffic Studies to USAC And FCC

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All firm clients providing wireless or interconnected VoIP services are advised that the Instructions to the 2008 Telecommunications Reporting Worksheet (“2008 Form 499-A Instructions”) requires providers of wireless or interconnected VoIP services relying on “traffic studies,” to determine USF contribution eligible revenues, to submit their traffic studies to USAC and the FCC. Though established by USAC in the absence of a formal FCC rulemaking proceeding, such Form 499-A “instructions” have, in the past, been given the force and effect of law by the FCC. Therefore, failure to comply with the traffic study submission requirement is considered a violation of FCC Rules and could subject non-compliant providers to the FCC’s enforcement mechanisms.

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