As our firm recently advised, on April 30, 2012, a unanimous Federal Communications Commission (“FCC”) released its anticipated Further Notice of Proposed Rulemaking (“FNPRM”) seeking comment on reforming the Universal Service Fund (“USF”) contribution system in an effort to reduce disputes, simplify compliance, and promote competition. The FNPRM includes a number of proposals and issues that stand to have a significant impact on a variety of industry segments. On June 7, 2012, the FCC published the FNPRM in the Federal Register, setting the comment deadline on July 9th. A summary of the FNPRM as it appears in the Federal Register is available here: FNPRM Summary
The FCC proposes to expand the base of contributors to the Fund, modify the existing revenue-based system or adopt a numbers/connections-based approach, and identifies a number of other potential reforms to improve the contribution system. For example, the FCC proposes to reform the carrier’s carrier rule by replacing the existing wholesale verification process with a European-style “Value-Added Tax,” eliminate or modify the LIRE and de minimis exemptions, modify the manner in which revenues are allocated between inter and intrastate jurisdictions, and adopt new rules for reporting prepaid calling card revenues.
Comments are due by July 9th, with replies due by August 6th. Clients interested in filing comments in this matter should contact Jonathan Marashlian at firstname.lastname@example.org or (703) 714-1313. Due to the brief comment period, with the deadline over a holiday week, it is imperative that we begin preparation of comments in the matter right away on behalf of any client wishing to participate in the proceeding.