Reminder: Federal Communications Commission - February Filings

Kelley Drye Client Advisory

Please be reminded of the upcoming due dates for the Reports listed below:

FCC Form 499-Q: Quarterly Telecommunications Reporting Worksheet

Carriers providing interstate and international telecommunications that are required to contribute to federal universal service support mechanisms must report their revenues for each calendar quarter by filing FCC Form 499-Q with the Universal Service Administrative Company (USAC) on a quarterly basis.

The next FCC Form 499-Q is due February 3, 2020 and must be submitted electronically using USAC’s E-File system. A contributor must file a revised FCC Form 499-Q within 45 calendar days of the February 3 deadline (or the next business day thereafter) if the contributor discovers an error in the data it reported.

The February FCC Form 499-Q filing covers historical end user revenue data for October 1 through December 31 of the prior year and projected end user data for April 1 through June 30, 2020.  Providers of interconnected Voice over Internet Protocol service and commercial mobile radio service that rely upon traffic studies to report their revenues on the FCC Form 499-Q must submit the traffic studies with the FCC Form 499-Q filing.

Note that the Federal Communications Commission (FCC) actively enforces the FCC 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 FCC Forms 499-A and 499-Q in the prior two years.

The prepaid calling card percentage of interstate usage certification must cover the prior quarter ending December 31, 2019.  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.