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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
On February 15, 2012, the Federal Communications Commission (“FCC”) adopted an order requiring Interconnected VoIP service providers to report significant network outages that meet specific criteria and thresholds.
In response to the high volume of complaints over unwanted robocalls, the Federal Communications Commission (“FCC”) on February 15, 2011 issued changes to its rules for autodialed or prerecorded telemarketing calls made to wireline and wireless phones.
Under the new rules, consumers must give their express written consent before receiving a robocall. The “established business relationship” exemption to the new consent requirement was further eliminated. Telemarketers will also have to provide an automated interactive opt-out mechanism during robocalls so that consumers can immediately tell telemarketers to stop calling. Finally, a limitation was adopted on the number of abandoned or “dead air” calls telemarketers can make during a calling campaign.
A copy of the FCC’s Report and Order is linked here.
Good faith efforts to comply with the directives of the Universal Service Administrative Company (“USAC”) were punished yet again as disclosed in a recent Petition for Review filed with the Federal Communications Commission (“FCC”). InComm Solutions, Inc. (“InComm”), a provider of call-bridging services, is appealing USAC’s decision to deny its request to offset over $250,000 in USF contribution payments paid by InComm to its supplier, Sprint, during a period in which InComm concedes it was not in compliance with FCC rules requiring call-bridging providers to directly contribute.
On February 6, 2012, representatives of the following Multi-Protocol Label Switching ("MPLS") service providers: Verizon, BT Americas, XO Communications, Orange Business Services and NTT America ("MPLS Providers"), met with staff of the Federal Communications Commission's ("FCC") Wireline Competition Bureau. At the meeting, the MPLS Providers discussed the urgent need for the FCC to resolve legal uncertainties regarding the applicability of Universal Service Fund fees and requirements to MPLS Services.
On February 1, 2012, the Universal Service Administrative Company (“USAC”) submitted the federal Universal Service Support Mechanisms fund size and administrative cost projections for the second quarter of calendar year 2012 (2Q2012), in accordance with Federal Communications Commission (“FCC”) rules. The 2Q2012 report details steps taken by USAC during the past two years to beef up its audit capabilities, budget and resources in response to FCC directives. On its face, the 2Q2012 report indicates that the industry – both on the USF recipient and contribution side – can expect an active and aggressive year of USAC enforcement ahead.
With last year's reforms to the Intercarrier Compensation regime and Universal Service Fund (“USF”) distribution system, moves which clearly shifted the policy focus from the switched telephone network of today to the Broadband networks of tomorrow, the Federal Communications Commission (“FCC”) now stands poised to tackle the sticky issue of how to pay for these reforms. Although the FCC has yet to announce the much-anticipated USF Contribution Reform Notice of Proposed Rulemaking (“NPRM”), powerful lobbies are already hard at work seeking to influence the Commission; none has been more active than the National Telecommunications Cooperative Association (“NTCA”), a trade group representing the interests of rural, independent telephone companies.
Representatives of The CommLaw Group and its regulatory compliance consulting and administration affiliate, The Commpliance Group, will be exhibiting at the Internet Telephony Expo (IT EXPO East) in Miami, FL from February 1 – 3.
On October 7, 2011, the Federal Communications Commission (“FCC”) adopted a Report and Order implementing certain provisions of the Twenty-First Century Communications and Video Accessibility Act of 2010 (“CVAA”). The CVAA was enacted to ensure that people with disabilities have access to the modern and innovative communications technologies of the 21st century. The FCC also released an accompanying Further Notice of Proposed Rulemaking (“FNPRM”) that seeks comment on outstanding issues regarding the implementation of the CVAA.