If you filed an FCC Form 477 to report your broadband connections and voice service locations (see TMI ‘s Blog “Time To Prepare For FCC Form 477 – Again” dated 6/5/14), you may receive an inquiry from auditors at the FCC that looks something like this:
Below, we have identified certain items in your filing which are unusual and potentially inaccurate, and corrections may be necessary. Some of these items may be the result of comparing this filing with your previous filing and finding unusual increases or decreases, or counts that are unchanged. Please use “Reply All” to this email so that for each item you can either:
1. EXPLAIN why the originally-submitted data are, in fact, accurate
2. AGREE that corrections need to be made and PROVIDE us with the date by which you expect to have completed those corrections in the Form 477 online filing system
If multiple items are listed below, please provide a response for each one.
The inquiry may result from comparing one filing to a previous filing (e.g., data reported as of December 31, 2014 to data reported as of June 30, 2014) and noticing a significant increase or decrease in one or more categories.
The inquiry may be pointing out unusual data in the filing, such as one connection in each reported census tract or bandwidth exceeding 1 gig. Or they may inquire about data they suspect is a misinterpretation of the rules.
In each case, once you have responded with either an explanation of why your filing is indeed accurate or with an agreement to amend the questioned filing, you will receive a message similar to this one:
We have received your email. We will get back to you as soon as we can regarding your question or inquiry. The deadline for filing June 30, 2015 FCC Form 477 data is September 1, 2015. If you haven’t filed yet, please do so as soon as possible. Thank you.
The FCC Form 477 Team
If TMI prepared your geocoding or Form 477 subscription and deployment files for uploading, please forward any inquiries to your TMI consultant so that we can assist you with an appropriate response or be aware of the issue for the next filing. Whether the response affirms the original filing or amends it, it will be more efficient if we are aware of the potential issue for the September 1, 2015 filing with the FCC.
Remember, the FCC rules set a base forfeiture of $3,000 for failure to file required forms or information for each violation or each day of a continuing violation. In addition, it has discretion, to depart from these guidelines, taking into account the particular facts of each individual case. (TMI Regulatory Bulletin Service subscribers see Bulletin dated 3/12/15).