On April 18, 2012, the Coalition filed an ex parte letter with the FCC expressing support for USTelecom’s recommendations to improve the Carrier’s Carrier Rule (“CCR”).
The Coalition cited its August 2010 ex parte letter which presented a similar solution and summarized the key provisions of its proposal to eliminate the carrier-to-carrier exemption process in favor of a streamlined CCR with an improved verification process incorporating better technology and information.
Specifically, the Coalition proposed that the FCC:
(a) eliminate USF exemption forms in favor of an all electronic database;
(b) adopt clearly defined rules with clear limited duties on wholesalers;
(c) collect information on resellers and wholesalers on a routine, confidential basis and establish a real-time online databas and verification system; and
(d) require wholesalers to verify resellers’ status only once and thereafter limit their liability at most to actual receipts.