RBO offers a full array of licensure and registration services related to carriers. These services include:

Filings with the Federal Communications Commission (FCC)

1. FCC Section 214 Authority (Common Carriers Resellers and Facility Based Providers) Under Section 214 of the Communications Act of 1934 (“Act”), all telecommunications providers (whether they are facilities-based carriers; switch or switchless resellers; prepaid calling card or PIN providers; Interconnected VoIP provider; or in select cases wireless providers) that offer or provide calling services between the U.S. and foreign points must obtain Section 214 authority as a prerequisite to operation of service
2. Department of Homeland Security Review of foreign applicants or foreign owners of carriers seeking Section 214 Authority
3. Reporting of Foreign Ownership to Department of Commerce as required by regulation

4. FCC Section 214 Authority Transfer of Control, Assets or Change of Ownership

b.) Sale of Assets Does Not Equal a Discontinuance of Service under 214 Authorities. Asset purchases that do not result in a loss of service for customers must be treated as an assignment, and not a discontinuance of service, and requires prior FCC approval. The Section 214 Authority of the selling carrier cannot not be assigned as a part of the asset purchase however the sale of a customer base in whole or in part by any common carrier requires prior Section 214 approval. CMRS carriers are not exempt from this rule

5. FCC 214 Discontinuance of Service due to merger or closing of business
6. FCC International Point Codes
7. 499 Filer ID Registration (for Common Carrier and Interconnected VoIP Providers)

Immediate Compliance with the Federal Communications Commission (FCC)

1. FCC Form 499-A. Due April 1st of every year with 499-Q reports due every March, May , August, and November. Requires pre-registration of Carrier of VoIP Provider with the FCC and thereafter Quarterly 499-Q reporting to certify status as direct contributor, or that, provider qualifies as "de minimus" indirect contributor. All intrastate, interstate, and international providers of telecommunications within the U.S. are required to file the Form 499-A and 499-Q.

3. International Resold Private Line Addition Report. Due March 31 of every year.

4. Prepaid Card Provider FCC Certification. Due March 31of every year.

5. Section 43.21(c) Annual Report. Due April 1st of every year.

6. CPNI Annual Certification. Due March 1st of every year.

8. Filing and Update of INFORMATIONAL FCC Tariff Requirements Due immediately upon commencement of Service. Non-dominant carriers (FCC 214 carriers and resellers) providing operator services as defined in section 64.708(i) of the Commission's rules must have on file informational tariffs. Informational tariffs must be filed when offering new operator services or at the same time existing services are de-tariff.

All telecommunications carriers (FCC 214 holders), as defined by CALEA section 102(8), 47 U.S.C. § 1001, must maintain up-to-date System Security and Integrity (SSI) plans with the Commission, as those plans are described in 47 C.F.R. § 1.20005. Facilities-based broadband Internet access providers and providers of interconnected Voice over Internet Protocol (VoIP) service must file their initial System Security and Integrity (SSI) plans with the Commission by March 12, 2007. See OMB Approves CALEA-Mandated System Security Filing Requirement For Providers Of Facilities-Based Broadband Internet Access and Interconnected VoIP Service, DA 06-2512, Public Notice (released Dec. 14, 2004). A telecommunications carrier may comply with CALEA in different ways. First, the carrier may develop its own compliance solution for its unique network. Second, the carrier may purchase a compliance solution from vendors, including the manufacturers of the equipment it is using to provide service. Third, the carrier may purchase a compliance solution from a trusted third party (TPP). These carriers, after May 14th 2007, must stand logistically ready to assist law enforcement in carrying out the interception of communications (whether via telephone or computer network) by providing "all information, facilities, and technical assistance necessary to accomplish the interception unobtrusively."

While CALEA specifically addresses lawful intercepts of communications through the telecommunication providers (a content based legal request) Title III, USA PATRIOT Act, Homeland Security Act, and Patriot II also place requirements on the telecommunication carrier to furnish non-content information about end-users and their usage of the carrier’s services. This includes Call Detail Records (or CDRs), billing information, account information, E-911 information, payment records, and other transactional records that the carrier may have in relation to providing service to the target of the investigation and request. Resellers of local exchange services, both facilities-based and switchless, must also comply with these rules by filing a SSI Plan.

Effectively all Communications services providers are legally obligated to assist law enforcement in carrying out communications surveillance. Even before CALEA, federal law required communication service providers to assist law enforcement in carrying out the interception of communications (whether via telephone or computer network) by providing "all information, facilities, and technical assistance necessary to accomplish the interception unobtrusively." Recent Surveys by RBO indicate that the majority of small to mid-sized carriers have not filed the SSI or developed internal policies for the handling of CALEA and other law enforcement requests

10. Filing and Update of International Service Tariff Filed on particular U.S international routes for particular services when carrier is classified as a dominant international carrier for such routes and/or services for any other reason other than having an affiliation with a foreign carrier that possesses market power. (Section 63.10 of the Commission's rules.) Non-dominant carriers are permitted to continue to file tariffs for international 101-XXX dial-around type services. Non-dominant carriers also are permitted to tariff services for customers who subscribe to international services indirectly through a local exchange carrier.

Such tariffs will be applicable only for an individual customer until the parties consummate a written agreement, but in no event for a period of more than 45 days. In addition, non-dominant carriers may continue to tariff international inbound collect calls to the United States and the provision of certain "on-demand" mobile satellite services.

11. FCC Dial Around Compensation Reporting Requirements & Outsourced Tariff Audits to ensure proper regulatory revenue reporting.

12. Drafting of FCC and Compliance Manuals tailored to your business (before or after an FCC Enforcement Action)

Explanation & Overview: In the United States, there are two levels of regulation and compliance for companies and businesses when providing telecommunication and VoIP services directly to the general public or end-users (retail) or, to other carriers that provide that resell the service downstream to the public (wholesale/resale). The first level is federal regulations and compliance.The second level is state certification and compliance. Both work concurrent with one another wherein state regulation merely supplements the gap areas of federal regulations.Both are independent with one another wherein compliance with state regulation does not equate to federal compliance, and visa versa. Companies providing VoIP and telecommunications services need to be keenly aware of these regulatory divisions and the benefits and obligations they carry. Being regulated does not simply mean that governmental burdens are carried with your services. For example, state certification as a telecommunications utility company may shield your from certain consumer-based lawsuits by relegating those claims to be dismissed from the civil court’s jurisdiction and handled through administrative law processes through the state utility or public service commission. Federal licensure and registrations may allow you to pass down certain regulatory fees and contributions assessments to the carriers closest to the end-user. Whether this benefits or burdens your Company’s telecom or VoIP services depends largely your own regulatory compliance strategy, or lack thereof.

There are three (3) basic Compliance requisites for all telecommunications carriers and VoIP Providers at the federal and state level:

Licensure, certification and registration with the FCC and individual state utility commission were you have Points of Presence for resale of services (wholesale/resale) or the state in which your services are sold to consumers on a prepaid or post paid basis.

Regular Reporting of Revenues, Traffic, Compliance with statutory requirements (such as Dial Around Compensation, E-911 and CALEA), usage, and your exemption status as to certain regulatory fees or contributions.

Ongoing Annual and Quarterly Assessment of regulatory reporting & contribution with client payment of those contributions to the appropriate state of federal agency.

All RBO Compliance programs are comprised of interplay of all three processes. The process begins with intake and regulatory analysis of your business. In general, wholesale/resale telecom or VoIP businesses require greater federal compliance with state compliance limited to their interconnection points or IP points of presence with other Interconnected VoIP carriers. Similarly, retail VoIP and telecom Providers require greater state compliance to meet individual state consumer protection mandates from public service and utility commissions in the states where consumers purchase their services, either prepaid or post paid. To this end, the RBO tailors Compliance programs to the budget and needs of the service provider. Recent FCC and state regulations have also begun to catch up with both technology and industry practices and the lack of regulatory compliance. With the advent of the new regulatory class of the Interconnected VoIP Provider, by virtue of the FCC’s E-911 Order, services long argued by the industry to be un-defined by statute and regulation are finding their way into requirements for contribution and reporting. This now brings an entire sector once thought to be distinct, specifically VoIP, into the mainstream of regulation.

For further information, or to get in contact with an RBO regulatory analyst click on the QUOTE button on the navigator. RBO analysts are available to schedule an intake interview with you to assess your current needs and pricing for such work and ongoing compliance.