CommLaw Monitor

Comment Deadlines Set for FCC's Latest International Reporting Streamlining Rulemaking

Mon, 17 Apr 2017 14:29:06 -0400

As Kelley Drye reported in a post late last month, the Federal Communications Commission (FCC) is considering eliminating the FCC Rule 43.62(b) annual International Traffic and Revenue reporting obligation and streamlining the Rule 43.62(a) annual Circuit Capacity reporting requirements. The FCC last overhauled these international reporting requirements a mere four years ago. The FCC’s Notice of Proposed Rulemaking (NPRM) now solicits comments on a number of issues including, but not limited to, the effect on U.S. consumers and carriers of eliminating the annual International Traffic and Revenue report, the costs of complying with the two annual reporting requirements, and options for streamlining the annual Circuit Capacity reporting obligations. Kelley Drye will be preparing an advisory delving deeper into the issues for which the FCC is seeking comment so be sure to check the Kelley Drye Communications practice group page for more details.

The NPRM was published this morning in the Federal Register, establishing the comment deadline at May 17, 2017 with reply comments due by June 1, 2017. International telecommunications providers subject to the reporting requirements should review the NPRM and consider whether to participate in the comment cycle to ensure their views are heard.

Should you have any questions about this proceeding and what the proposed rules may mean for your business, feel free to contact a member of Kelley Drye’s Communications practice group.

FCC Delays Filing Deadline for International Traffic And Revenue Reports – New Filing Window to be Announced

Chip Yorkgitis — Mon, 20 Jul 2015 16:57:39 -0400

As we discussed in a previous blog post, the Federal Communications Commission’s (FCC) streamlined international telecommunications reporting requirements took effect February 2015. New rule Section 43.62 requires common carriers engaged in international telecommunications service, as well as persons or entities engaged in providing international Voice over Internet Protocol (VoIP) service connected to the public switched telephone network, to file international traffic and revenue reports annually. Due to complications with the FCC’s new filing system, the annual Section 43.62 international traffic and revenue report filing deadline is being postponed from July 31 to a not-yet-announced date.

The FCC requires international traffic and revenue reports be filed using the FCC’s new online filing system. However, the filing system is not ready to accept the report in time for the usual July 31 filing deadline. As a result, and similar to its action with the annual Section 43.62 circuit capacity report filed in April of this year, the FCC is postponing the annual international traffic and revenue report filing deadline. The FCC reports that a special filing window for this year will be announced in the future, and we will provide those dates, in a subsequent blog post, when they become available. The circuit capacity report filing deadline for this year was postponed by a month after its usual date of March 31 (to which it will return next year) and we anticipate a similar multi-week extension for the international traffic and revenue report to be filed this year. Please be aware that traffic and revenue data submitted before the official filing window opens will be deleted, and the filer will need to resubmit its data.

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Leah Rabkin, a summer associate, contributed to this post.

FCC Announces Effectiveness of New International Reporting Requirements, Deadline for Filing Uncertain

Chip Yorkgitis — Wed, 18 Feb 2015 11:39:26 -0500

In January 2013, the Federal Communications Commission (“FCC”) comprehensively revised its reporting rules applicable to providers of international telecommunications, making numerous substantive revisions to the categories of providers subject to the reporting requirements, the information to be reported and the format of the reports. See our advisory on the January 2013 Order. But the effectiveness of the Order had been delayed, in large part, pending approval by the Office of Management and Budget (“OMB”). In a Public Notice issued Friday, February 13, the Commission announced that the new Section 43.62 annual International Traffic and Revenue report and Circuit Capacity report (the “Annual International Reports”) requirements, and the associated revised filing manual, are effective as of February 11, 2015.

Filers, thus, are now required to submit the Annual International Reports in accordance with the processes and specifications of rule 43.62 and the 43.62 filing manual. The reporting changes include creation of an online filing portal. However, it is not certain that the online filing system will be ready in time for the March 31, 2015 annual circuit capacity report filing. Indeed, the Public Notice suggests that the filing date has been suspended for now. The FCC will issue another Public Notice announcing the implementation of the online filing system and the due date for the annual circuit capacity report.

International providers of telecommunications, including interconnected VoIP providers, should review the new filing manual and take time to become familiar with the new reporting obligations in advance of the announcement of the Circuit Capacity report filing deadline for 2015. We have every reason to believe that the annual Traffic and Revenue Report deadline will remain the same, July 31. But the January 2013 Order modified the requirements for this second report as well. So, again, we recommend that providers ascertain whether, under the revised 43.62 and the new filing manual, they must file. If so, then the new requirements concerning Traffic and Revenue Report should be reviewed as well.