Reminder: Federal Communications Commission - November Filings
Kelley Drye Client Advisory
October 20, 2020
Please be reminded of the upcoming due dates for the Reports listed below:

Form 499-Q: Quarterly Telecommunications Reporting Worksheet

Providers of interstate and international telecommunications, including, but not limited to, VoIP providers, that are required to contribute to federal universal service support mechanisms must report their revenues for each calendar quarter by filing Form 499-Q with the Universal Service Administrative Company (USAC) on a quarterly basis.
The next Form 499-Q is due November 1, 2020 and must be submitted electronically using USAC’s E-File system.  (Because November 1, 2020 falls on a weekend, filers will have until November 2, 2020, the next business day, to submit the filing.) A contributor must file a revised Form 499-Q within 45 calendar days of the November 1 deadline (or the next business day thereafter) if it discovers an error in the data it reported.

The November Form 499-Q filing covers historical end user revenue data for July 1 through September 30 of the current year and projected end user and wholesale data for January 1 through March 1 of the next year.  Providers of interconnected Voice over Internet Protocol service and commercial mobile radio service that rely upon traffic studies to report their revenues on the Form 499-Q must submit the traffic studies with the Form 499-Q filing.

Note that the Federal Communications Commission (FCC) actively enforces the Form 499-Q filing and accompanying Universal Service Fund (USF) contribution requirement, and may impose monetary penalties for failure to file or make timely USF contributions.

Quarterly Prepaid Calling Card Provider USF Contribution Certification – 47 CFR 64.5001

Section 64.5001 of the FCC’s rules requires prepaid calling card providers to submit a certification, on a quarterly basis, confirming that the provider is contributing to the Universal Service Fund. The certification requirement does not apply to a prepaid calling provider that timely filed annual and quarterly Forms 499-A and 499-Q in the prior two years.

The fourth quarter PIU certification must cover the prior quarter ending September 30, 2020.  Certifications can be filed in the FCC’s electronic comment filing system (ECFS) and must reference WC Docket No. 05-68.
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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.  For more information, please contact your current Kelley Drye attorney or any member of the Communications Practice Group.