Reminder to clients providing international telecommunications services, the deadline to file International Traffic Reports with the Federal Communications Commission (“FCC”) is July 31st.
All carriers providing international telecommunications services between any U.S. point and any non U.S. point – i.e. clients required to possess an FCC Section 214 License – must file an International Traffic Report with the FCC in accordance with Section 43.61(a) of the Commission‘s rules. This includes foreign carriers that serve a U.S. point, as well as private carriers and carriers that provide non-tariffed international communications services.
Both facilities-based carriers and resellers must file the International Traffic Report. The Report must include, among other things, actual traffic and revenue data for each service provided, divided among services billed in the United States, outside the United States, and services transiting the United States. However, carriers providing exclusively resold international telecommunications services can file a simplified report. Carriers providing both facilities-based and resold services must file separate reports.
REPORTING DETAILS:
All carriers possessing a FCC Section 214 License and who provided international telecommunications services during 2008 must file an International Traffic Report with the FCC. This report must include, among other things:
- The number of calls to specific international destinations;
- The number of minutes for calls to international destinations;
- Revenue derived from international minutes of use; and
- The specific countries or international points to which your company terminated international minutes of use.
The International Traffic Report must include a Certification, signed by an officer of the company under penalty of perjury, attesting to the accuracy of the reported data.
CLIENT ACTION ITEMS:
Clients subscribed to Compliance & Reporting Services (“C&R Services”) will be contacted by our firm’s regulatory consulting affiliate, The Commpliance Group, regarding the timely submission of revenue and other required data. Clients not currently subscribed to the firm’s C&R Services, but who require assistance preparing and filing the International Traffic Report, should contact us promptly to ensure timely filing.
C&R Services Subscribers: Clients currently subscribed to C&R Services through our firm’s regulatory consulting affiliate, The Commpliance Group, should remit required data to Meghan Ruwet, at mruwet@commpliancegroup.com, no later than July 27th.
Non-Subscribers: Clients not currently subscribed to C&R Services through The Commpliance Group, but who require assistance with the preparation and filing of the International Traffic Report may contact Meghan Ruwet, at mruwet@commpliancegroup.com, to make appropriate arrangements and ensure timely filing.
If you have already sent us data for the International Traffic Report, you may disregard this notice.
ADDITIONAL INFORMATION:
FCC Enforcement
The FCC imposes steep fines against entities that fail to comply with its “reporting” regulations. These FCC fines frequently exceed one hundred thousand dollars ($100,000.00) for a single offense. Examples of recent enforcement actions are available on the FCC‘s website: https://www.fcc.gov/eb/usfc/. Thus, clients should provide us with the required reporting information as soon as possible to avoid a delinquent filing.
Clients who would like additional information about the International Traffic Report should contact Meghan Ruwet of The Commpliance Group at mruwet@commpliancegroup.com.
