The deadline for filing FCC Form 499-Q with the Universal Service Administrative Company (“USAC”) for the Fourth Quarter is February 1^st.

All non de minimis providers of telecommunications services and interconnected VoIP services are required to complete Form 499-Q and report actual revenue data for the Fourth Quarter of the following year (October 1^st – December 31^st) and projected revenue for the Second Quarter of this year  (April 1^st – June 30^th).

De minimis providers are not required to remit Form 499-Q, but must nevertheless complete and retain a Quarterly de minimis Worksheet in their files. The applicable document retention period for records related to the Universal Service Fund program is five (5) years.

Additional information on FCC Form 499s, including the most recent Form 499-Q and instructions, can be found on USAC’s website at:

https://www.universalservice.org/fund%2Dadministration/forms/

CLIENT ACTION ITEMS:

Clients subscribed to Compliance & Reporting Services (“C&R Services”) will be contacted by the firm directly 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 Form 499-Q, should contact us at your earliest convenience to ensure timely filing. Failure to remit required data in a timely manner may result in delinquent remittance and imposition of penalties. See FCC Form 499 Late Filing Policy.

C&R Services Subscribers: Clients currently subscribed to the firm’s C&R Services will be contacted shortly by either Olivia Hill or Chris Canter to ascertain your filing obligations. Clients who have revenue information prepared should remit this information to Olivia Hill directly at odh@commlawgroup.com, no later than January20^th.

Non-Subscribers: Clients not currently subscribed to C&R Services, but who require assistance with the preparation and filing of the Form 499-Q, may contact either Jonathan Marashlian at jsm@commlawgroup.comor Chris Canter at cac@commlawgroup.com to make appropriate arrangements and ensure timely filing.

If you have already sent us your revenue information, you may disregard this notice.

ADDITIONAL INFORMATION:

E-File System and Electronic Officer Certification Information

Electronically-filed Form 499s are not complete until the Officer Certification is submitted, either by filing a hard copy or conducting the certification through USAC’s E-File System. All clients wishing to perform officer certifications electronically must have access to their individual USAC E-file account.

Clients who do not have the correct E-file account information or whose information has changed since the last submission may encounter significant delays when filing and certifying Form 499s. Therefore, all clients with an existing account with USAC should locate and confirm the functionality of their USAC E-file System Username and Password as soon as possible in anticipation of the upcoming 499.

Clients who are unable to locate their current E-File System log-in information should contact USAC’s Help Desk at (888) 641-8722.

FCC Form 499 Late Filing Policy

Form 499s received by after the due date will be subject to a late filing fee. USAC and the FCC strictly enforce applicable filing deadlines and rarely make exceptions for late-filed Forms. Failure to timely file and accurately report revenue in a Form 499 is a violation of FCC rules and may result in a USAC audit, FCC investigation, or both. Examples of FCC enforcement actions are available on the FCC’s website: https://www.fcc.gov/eb/usfc/.

Clients who have specific questions about how to report revenue on the Form 499-Q should contact Jonathan Marashlian at jsm@commlawgroup.com or Chris Canter at cac@commlawgroup.com.