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Quartely
PIU Certification - Free Consultation and Evaluation
The
FCC is ordering calling card companies to perform traffic
studies and issue certifications four times a year to
determine how much of your traffic is interstate. This
certification, which
goes to both the FCC and your transport carrier(s), must be
signed by an officer of your
company under a penalty of perjury.
To
help you tackle this requirement, we offer a free evaluation. All we need
is a copy of your latest 499.
Notes
from our FCC attorney:
DECLARATORY
RULING AND REPORT AND ORDER
Adopted:
June 1, 2006 Released:
June
30, 2006
FCC
06-79
As a result of
this Order, providers of prepaid calling cards that are
menu-driven or use IP transport to offer telecommunications services
are obligated to pay interstate or intrastate access charges based on
the location of the called and calling parties.
The
Commission addressed the logistics of requiring all prepaid calling
card service providers to pay intrastate and interstate access
charges.
The Commission recognized that, as
with other services that require the caller to dial an access number,
the assessment of interstate and intrastate access charges based on
the location of the called and calling parties can be complicated with
respect to prepaid calling card traffic because the caller initially
dials the 8YY number associated with the calling card platform and
only later dials the number of the called party.
As a result, the originating carrier will not be able to
determine the appropriate jurisdiction of the call based on a
comparison of the calling and called numbers because it only will know
the 8YY number associated with the platform, not the telephone number
of the called party. Moreover,
unless the calling party number (CPN) is passed, the terminating
carrier will face a similar problem.
The
Commission found that these complications can be addressed through
certification and reporting requirements that compel the prepaid
calling card provider to share the necessary information with the
carriers that it uses to transport traffic to and from the platform.
The
Commission cautioned, however, that as with any other service subject
to the Commission’s rules, if prepaid calling card providers do not
comply with the new certification and reporting rules they will be
subject to the Commission’s
enforcement authority,
including complaints and forfeitures.

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