After a wait of over a year, the FCC’s new rural call completion rules are finally effective and carriers will have to scramble to comply. Of particular urgency is the April 1 deadline for:
- recording and retaining the required data; and
- filing one-time notification letters.
Most of the attention has focused on the new recording, retention, and reporting obligations of carriers that make the initial long-distance call path choice for more than 100,000 domestic retail subscriber lines. Less attention has been paid to the fact that all providers with more than 100,000 domestic retail subscriber lines actually have a reporting obligation. Therefore, providers must act now to determine whether, and which, rules may apply to them.
Originating long-distance voice service providers that serve more than 100,000 domestic subscriber lines and do not make the initial long distance call path decision for more than 100,000 domestic retail subscriber lines must file a one-time letter by April 1, 2015. This requirement applies to LECs, IXCs, interconnected and non-interconnected VoIP providers, wholesale providers, and wireless providers. The letter must explain that they have more than 100,000 long-distance subscriber lines, but they do not make the initial long-distance call path choice for more than 100,000 long-distance voice service subscriber lines. It must also identify the long-distance provider or providers to which they hand off their end user customers’ calls. A copy of the letter must be submitted simultaneously to each provider identified in the letter as having reporting responsibility.
Providers of long-distance voice service that do make the initial long-distance call path choice for more than 100,000 domestic retail subscriber lines will need to do the following starting April 1:
- Record specific information about each call attempt to a rural operating company number (OCN) from subscriber lines for which the providers make the initial long distance call path choice;
- Retain the recorded information in a readily retrievable form for a period including the six most recent complete calendar months; and
- Submit, on a quarterly basis, a certified report containing information on long-distance call attempts from subscriber lines for which the covered providers make the initial call path choice. The reports must separate out call attempts by month. The first quarterly reports (reflecting monthly data from April through June 2015) are due August 1, 2015.
The FCC’s Orders give some guidance as to how a provider may determine that it makes the initial long distance call path choice and what lines should be counted for purposes of determining if a provider meets the 100,000 subscriber line threshold.
TMI’s Consultants have reviewed the Order thoroughly and are familiar with the requirements. We are currently helping a number of carriers determine if and how they are covered by the
new rules and to file their reports. Please contact your TMI Consultant if you have any questions. If you do not have a TMI Consultant, click on the button below for assistance.