Telecom Law Monitor : Washington D.C. Telecom Lawyer & Attorney : Kelley Drye & Warren Law Firm : New York, Chicago, Connecticut, New Jersey, Brussels

Here is another compliance item for our readers.  The FCC's rules requiring all tariffs to be filed electronically takes effect today.  For competitive carriers, this means that you must file tariffs via the new electronic portal; paper tariffs are no longer permitted. 

The FCC released two public notices on the tariff filing procedures earlier this week.  (One notice addressed the effective date, the other the filing procedures.)

All competitive carriers must file their existing base tariff within the next 60 days.  (It's probably not a good idea to file in the first few days or the last few days of this window).  Thereafter, changes to the tariffs must be filed electronically.  Operator service providers, if there are any still out there, also must file the base tariff electronically. 

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In June, the FCC adopted an order requiring all carriers (not just incumbent carriers) to file FCC tariffs via an electronic portal.  The FCC announced today that the new filing requirement will become effective on November 17th.

For carriers with FCC tariffs, you must file your base tariff within 60 days after November 17th.  Anticipating potential server issues, the FCC encouraged carriers not to wait until the 60th day to make these filings.

For Operator Service Providers -- if there are any of you still out there -- informational tariffs must also be filed within this 60 day window.

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