Client Alert
FCC Extends Form 477 Requirement to Providers of Interconnected Voice over Internet Protocol
June 18, 2008
On June 12, 2008, the FCC adopted an order extending the FCC's Form 477 filing requirements to interconnected VoIP providers. Once implemented, interconnected VoIP providers will be required to report the following information:
- The number of end-user and resale subscribers the provider has in individual states.
- The percentage of subscribers who purchase the provider’s residential grade service plan.
- A list of 5-digit ZIP Codes within each state in which the provider has at least one subscriber.
- Information regarding the number of subscribers who receive broadband service in conjunction with interconnected VoIP and and the types of broadband connections the provider or its affiliates provide in conjunction with interconnected VoIP service, if any.
Whether the interconnected VoIP service must be used over a single predetermined broadband connection or whether it can be used over any broadband connection.
The information reported will vary slightly based on the interconnected VoIP provider’s services. For example, entities that provide interconnected VoIP service to end users in conjunction with a broadband connection will report information about the interconnected VoIP subscription separately from other providers of interconnected VoIP service to end users.
The FCC relied on its authority under Title I of the Communications Act of 1934, as amended, to extend this filing requirement to interconnected VoIP providers. See Development of Nationwide Broadband Data to Evaluate Reasonable and Timely Deployment of Advanced Services to All Americans, Improvement of Wireless Broadband Subscribership Data, and Development of Data on Interconnected Voice over Internet Protocol (VoIP) Subscribership, Report and Order and Further Notice of Proposed Rulemaking, FCC 08-89 (rel. June 12, 2008).
The new requirements will be effective thirty days after publication of the notice of the Report and Order in the Federal Register subject to the Office of Management and Budget approval for new or modified information collection requirements. The FCC has stated that, regardless of the effective date, the new requirements will not affect the filing requirements due on September 2, 2008, which reports data from June 30, 2008.
If you have any questions regarding this client alert, please contact the Womble Carlyle attorney with whom you usually work, or one of the following members of our Telecommunications team:
Ross Buntrock (202) 857-4479
Jon Canis (202) 857-4454
Mike Hazzard (202) 857-4540
Stephanie Joyce (202) 857-4534
Katherine Marshall (202) 857-4493
Danielle Benoit (202) 857-4537
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