Reminder: FCC Filings Due on or Before February 1, 2019

Kelley Drye Client Advisory

Please be reminded of the upcoming due dates for the Reports listed below:
Important – As of the date of this alert, the Federal Communications Commission is closed due to the federal government shutdown.  However, the FCC has stated that filings submitted to fund administrators, such as the Universal Service Administrative Company (USAC) and the North American Numbering Plan Administrator (NANPA) must be submitted by the regular filing due date. 
Consequently, the filing due date for the FCC Form 499-Q and Form 502 filings, discussed below, has not been extended and must be submitted by February 1, 2019.

Form 499-Q Quarterly Telecommunications Reporting Worksheet

Carriers and providers of interstate and international telecommunications, including, but not limited to, interconnected Voice over Internet Protocol providers, providers offering interstate telecommunications for a fee on a non-common carrier basis, and payphone providers that are aggregators, are required to file the FCC Form 499-Q on a quarterly basis unless the carrier or provider qualifies for one of the filing exemptions.  Carriers and providers must report their actual and projected end user and carrier’s carrier revenues for each calendar quarter by filing the Form 499-Q.  The Form 499-Q filing reporting historical revenues for October 1 through December 31 of 2018 and projected revenues for April 1 through June 30 of 2019 is due to the Universal Service Administrative Company on or before February 1, 2019.
Note: Revisions to this Form 499-Q filing must be filed within 45 days of February 1, 2019.

Form 502: North American Numbering Plan Numbering Resource Utilization/Forecast Report

Section 52.15(f) of the Commission’s rules requires carriers that receive numbers from the North American Numbering Plan Administrator (“NANPA”), pooling administrator, or another telecommunications carrier, to file the Form 502 to report numbering usage and forecast future numbering resource needs.  Carriers must report on utilization of their current inventory of numbering resources and submit to the NANPA a forecast of the carrier’s yearly numbering resource requirements. Reports reflecting information for the preceding 6-month period ending December 31, 2018 are due to the NANPA on or before February 1, 2019.  The Form 502 can be found here:  http://​www​.nan​pa​.com/​n​r​u​f​/​i​n​d​e​x​.html.


Please be advised that attorneys in Kelley Drye & Warren’s Communications Practice Group are experienced in addressing universal service filing and carrier contribution issues and are available to assist clients with determining how to report their revenues for universal service purposes, as well as with the filing of FCC Form 499-Q.  The group’s attorneys also are experienced in completing and filing the FCC Form 502.
For more information regarding this client advisory, please contact your usual Kelley Drye attorney or any member of the Communications Practice Group.