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"Jonathan is well-versed in a broad range of telecom regulatory matters. He uses his expertise to arrive at innovative, real-world business solutions while maintaining a high degree of professionalism."
"Jonathan is extremely knowledgeable in his field. He has provided invaluable telecom expertise to us and our subsidiary company on countless occasions. We would be lost without him. I highly recommend Jonathan!"
"Jonathan['s firm] was able to provide our ISP association with fresh responses to the RBOC FCC petitions as opposed to the boilerplate comments most law firms offered. Jonathan has a good understanding of the industry and how things work at the FCC."
—COO of a leading virtual
system company
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unit of foreign PTT
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nationwide Hosted
VoIP provider
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of US operating unit
of international multi-media
conglomerate
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regional CLEC
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international communications carrier
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provider of long distance,
wireless, point-of-sale and
carrier services
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regional CLEC
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leading provider of
long distance, wireless,
point-of-sale and carrier
services
—CFO of enhanced
conferencing solutions
provider
—Member, Federation of
Internet Solutions Providers
of the Americas
Contact Information

Marashlian & Donahue, LLC

The CommLaw Group
1420 Spring Hill Road
Suite 401
McLean, Virginia 22102

Telephone: (703) 714-1300
Facsimile: (703) 714-1330

E-mail: mail@commlawgroup.com

FCC Announces Proposed NANP Contribution Factor of 0.0000181

The FCC recently announced a proposed contribution factor of  0.0000181 (0.00181%) for the North American Numbering Plan ("NANP") for the fiscal year beginning July 1st.  The proposed NANP contribution factor reflects an increase from last year's contribution factor of 0.0000165.

If the FCC takes no action by June 7, 2010, the NANP contribution factor shall be deemed approved by the Commission.  Once approved, the NANP contribution factor will remain in effect until June 30th of next year.

Annual NANP Fund support payments must be paid by all wireline telecommunications carriers and interconnected VoIP service providers.  Welch LLP, the NANP Fund administrator, will apply the NANP contribution factor against all contributors' telecommunications revenue, as reported in the recently filed FCC Form 499-A.  There is no de minimis exemption for NANP contribution.

Details and Important Reminders

  • Duty to Pay

A regulated carrier's obligation to pay NANP support contributions exists by virtue of having provided interstate or international telecommunications services or interconnected VoIP services during the past year, regardless of whether a carrier received an invoice from NECA.

  • Minimum Payment

The minimum annual contribution to the NANP Fund continues at $25.  The minimum contribution is owed by all carriers holding Filer IDs during the past year, even if a carrier reported no revenue in its annual Form 499-A.  In addition, filers with no end-user revenue, e.g. resellers, must pay $25.

  • Late Filing Penalty

NECA will assess a late filing penalty of $100 to any carrier filing FCC Form 499-A after the April 1st deadline.

Consequences of Non-Payment/Delinquency

Late payment charges will be applied to delinquent accounts not paid by the invoice due dates.  In addition, a carrier who owes money to the NANP Fund will be considered delinquent and in "red light status" if payment is not made by the due date reflected on the NANP invoice.  

Furthermore, clients are reminded that if an annual contributor has not made its payment, including any late payment assessments, within ninety (90) days of the NANP invoice due date, the delinquent amount will be transferred to the FCC pursuant to the Debt Collection Improvement Act of 1996.