Compliance Obligations Remain, Even with Recent Disruptions

JSI is here to provide whatever support you may need  

With the constant disruptions in daily life due to the efforts underway to address the increasing threat of the coronavirus, JSI reminds clients that we are here to provide whatever support you may need. One tool that we thought might be helpful is a checklist of upcoming compliance deadlines, which we provide below.

While from the FCC’s perspective, “deadlines are deadlines” and should always be met, the FCC has been known to grant waivers if a company can demonstrate that compliance was not possible given the “extraordinary” circumstances.  Accordingly, we encourage clients to contact us if they believe that they will not be able to meet a filing deadline in order to discuss whether filing a waiver would be an option or explore alternative ways to ensure that the deadline is met.  Also, there is always the possibility that the FCC could extend some of these deadlines; however, unless and until that occurs, companies are still required to comply with the specified deadline.

Please contact John Kuykendall or Ryan Denzel with any questions about the filings listed below, if you would like our assistance with any of the filings, or would like to discuss seeking a waiver.

Compliance Checklist

  • March 24 – 2020 Advanced Services Demand Data Request due for those companies that received correspondence from NECA in January requiring completion of the 2020 Advanced Services Demand Data request
  • March 26 – Annual Continued Qualification (ACQ) certification letters to iconectiv. Applies to all registered users of the Number Portability Administration Center (NPAC)
  • March 26 – 3.5 GHz auction short-form application window opens
  • March 30 – USF 2019-4 Quarterly Updates
  • March 30 – FCC 492 Report
  • March 31 – Year-end 2019 financial and operating reports for all RUS Telecommunications and Electric Borrowers that file annually
  • March 31 – FCC Form 508 CAF BLS Projection Data and Certifications due to USAC
  • March 31 – Reconnect applications extended deadline
  • April 1 – Annual Accessibility Recordkeeping Compliance Certification
  • April 1 – Billing systems updated for 2nd Quarter Federal Universal Service Contribution Factor reduced to 19.6%
  • April 1 – FCC 499A
  • April 9 – 3.5 GHz auction short-form application window closes at 6:00 pm ET
  • April 22 – Supply Chain Filing due for all ETCs
  • April 28 – Toll Cost Studies for the A-CAM/BDS electors remaining in the NECA tariff are due to NECA
  • May 1 – FCC 499Q
  • May 1 – Section 254(g) Geographic Rate Average and Rate Integration Certifications due from long distance providers