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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
Quarterly Carrier PIU Reports (for Third Quarter) are due November 15th
11/01/2010

The next-scheduled PIU Report to underlying transport providers is due no later than November 15th. This report will cover the Second Quarter of this year (July 1st - September 30th).

Pursuant to Federal Communications Commission ("FCC") requirements, all prepaid calling card providers must report Percentage of Interstate Usage ("PIU") factors, and the call volumes on which these factors were calculated, to those carriers from which they purchase transport services.

According to the FCC's regulations, filing Transport Provider PIU Reports is a prerequisite to filing the PIU Officer Certification with the FCC (due on December 31th). Therefore, we cannot file the PIU Officer Certification with the FCC unless or until our client has submitted Transport Provider PIU Report(s).

BACKGROUND INFORMATION:

Prepaid calling card providers must report PIU factors to all carriers from which they purchase transport services. Specifically, a prepaid calling card provider must report:

  1. Prepaid calling card PIU factors, and
  2. Call volumes on which these factors were calculated (based on not less than a one-day representative sample).

These factors must be computed separately for originating and terminating traffic on a state-specific basis. If the prepaid calling card provider fails to report the appropriate PIU information to an underlying transport provider in a timely manner, the transport provider may treat the prepaid calling card provider's traffic as subject to a 50 percent (50%) default PIU.

Underlying transport providers will use the reported PIU in calculating PIU factors it reports to LECs. Transport providers may disclose the reported PIU to LECs upon request.  A transport provider also may audit the PIU reports it receives if it has a reasonable basis to believe that such reports contain inaccurate or misleading data.

Due Dates

Due dates for filing quarterly Transport Provider PIU Reports and FCC Certifications are as follows:

Reporting Period

PIU Report Due

FCC Certification Due

4th Quarter (Oct 1-Dec31)

February 15

March 31

1st Quarter (Jan 1-Mar 31)

May 15

June 30

2nd Quarter (Apr 1-Jun 30)

August 15

September 30

3rd Quarter (Jul 1-Sept 30)

November 15

December 31

FCC Enforcement

Filing a PIU Report serves as the basis for the PIU Officer Certification. Therefore, in order to comply with the FCC's upcoming  reporting requirement, all clients must submit PIU Reports to their underlying carriers in a timely manner.

The FCC imposes steep fines against entities that fail to comply with its "reporting" regulations, which includes USF filings, CPNI Certifications, and prepaid calling card provider reports. These FCC fines frequently exceed one hundred thousand dollars ($100,000.00) for a single offence. Examples of recent enforcement actions are available on the FCC's website: http://www.fcc.gov/eb/usfc/.

If you have any further questions or concerns about the FCC's PIU filing obligations, please contact Chris Canter at:cac@commlawgroup.com or 703-714-1308.