telecommunications services using their own facilities (the facilities-base providers). Both of these entities are required to have their own 214 authorizations. It is important to emphasize that a reseller cannot “ride” or use another carrier’s 214. The reseller must apply and obtain its own 214 license. After obtaining a 214 authorization, carriers must remember two ongoing requirements:
SIX WAYS FOR TELECOMMUNICATIONS IVE PROVIDERS TO BE PROACT WITH FCC REGULATIONS by Raul Magallanes
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Telecommunications service providers should be concerned with complying with the regulations of the U.S. Federal Communications Commission (FCC). This article will discuss six major areas where telecommunications carriers can be proactive to keep their regulatory compliance in check. Namely: (1) Obtain and maintain an international 214 authorization; (2) Comply with provisions of the Universal Service Fund; (3) Comply with Customer Proprietary Network Information regulations; (4) Respond timely and accurately to FCC inquiries; (5) Comply with 911 emergency regulations; and (6) Comply with the Communications Assistance for Law Enforcement Act.
1. OBTAIN AND MAINTAIN AN INTERNATIONAL 214 AUTHORIZATION Telecommunications providers wishing to offer services to or from the United States are required to obtain an International 214 authorization from the FCC. This authorization is derived from Section 214 of the U.S. Communications Act and is commonly referred to as a 214 License. Classification of 214 Holders There are two broad classifications of 214 holders. One, the carriers that resale the telecommunications services of other carriers (the resellers), and two, the carriers that provide
Keep Information Updated. The 214 holder remains responsible for the continuing accuracy of the certifications made in its original application and must notify the FCC of any alteration such as changes in business address, ownership structure and affiliations with dominant carriers. File Annual Disclosures. The 214 holder must file annual reports of overseas telecommunications traffic as well as revenue. The Application Process The application process and the time it takes for an application to be granted depend on several factors, which include the applicant’s relationship with other carriers, intended service destinations and foreign ownership. Applications with foreign ownership are reviewed by the Executive Branch as well as the FCC. Generally, applications involving any one of the following scenarios are reviewed with greater scrutiny and consequently take longer to grant: The applicant is affiliated with a nonU.S. dominant carrier in the market it seeks to serve.