Regulatory Reporting and Compliance & VoIP Regulation Jonathan E. Allen Kristopher E. Twomey Rini Coran, PC Law Office of Kristopher E. Twomey, P.C th Street, NW, Suite Commercial Street, Suite 2 Washington, DC 20036Boston, MA

WISP Regulatory Compliance VoIP Regulatory Compliance Recent Developments Future Developments Outline for Presentation

Equipment certification and marketing Antenna structures Pole attachments Spectrum and Interference Net Neutrality –Transparency rule –Open Internet Compliance Statements Periodic FCC filings (Form 477, CALEA) WISP Regulatory Compliance

FCC Federal Registration Number FCC USF Form 499-A due April 1 –(and later) 499-Q CALEA Form 445- asap CPNI- every March 1 st Form 477- March 1 st and September 1 st Regulatory Fees- LNP/NANPA, FCC Annual, TRS –Yes, even if de minimis VoIP Providers Regulatory Compliance

Take a look at – – December 2011, EB Notified (for First Time!) Providers of Form 477 Obligations $25,000 for failure to file CPNI certifications $1,000 to $6,000 for non-compliant CPNI statements June 30, Advisory Guidance on Open Internet Rules Various fines for failing to pay USF on time or the proper amount Fines by the FCC Enforcement Bureau

Universal Service Fund Reform FCC Pole Attachment Rules FCC Wireless Backhaul Order VoIP Outage Reporting by December 16, 2012 State PUC involvement Recent Developments

FCC petitions for VoIP providers access to numbering resources Special Access Rulemaking Appeal of Net Neutrality Rules USF Contribution Methodology WISPA Filings Copper retirement IP to IP Interconnection obligations AT&T TDM Sunset of TDM network White House drafting cybersecurity executive order Anything the audience is hearing/or interested in? Pending Legal and Regulatory Changes

Thank You! Jonathan E. Allen Kristopher E. Twomey Rini Coran, PC Law Office of Kristopher E. Twomey, P.C th Street, NW, Suite Commercial Street, Suite 2 Washington, DC Boston, MA