There are two separate FCC compliance filing deadlines on Friday, May 1, 2015 for carriers operating in the United States.
First, detariffed, non-dominant providers of interstate interexchange telecommunications services are required to file their Annual Geographic Rate Averaging Certification on or before Friday, May 1, 2015, as required by 47 C.F.R. § 64.1900. In this filing, providers must certify that their rates in high cost and rural areas are not higher than their rates in urban areas, in accordance with Section 254(g) of the Communications Act of 1934, as amended. 47 U.S.C. § 254(g). An officer must sign the certification under oath. Certifications must be filed in CC Docket No. 96-61, and addressed to the attention of Assistant Chief of the Pricing Policy Bureau.
Second, FCC Form 499-Q is also due Friday, May 1, 2015 for all filers that are not considered de minimis for Universal Service filing purposes. This filing encompasses historical revenues from the first quarter of 2015 and projected revenues for the third quarter of 2015. Interconnected Voice over Internet Protocol (VoIP) providers and Commercial Mobile Radio Service (CMRS) providers who rely on traffic studies to report interstate revenues on FCC Form 499-Q must submit these studies by May 1, 2015 to the Universal Service Administrative Company (USAC) and the Chief, Industry Analysis and Technology Division of the FCC. As a reminder, USAC now requires this filing to be made electronically via their filing portal, found here.
If you have any questions about this matter, please contact Katherine Barker Marshall, or the Arent Fox professional who handles your matters.