In 2014, the FCC radically overhauled its Local Competition and Broadband Reporting form (FCC Form 477), adding complex data reporting obligations and requiring carriers to use a brand-new electronic form. The form must be filed twice annually, with the next filing due March 1, 2016. The FCC’s online filing system is now accepting data for the March 1 filing, reporting data as of December 31, 2015.
The following types of entities are required to file Form 477:
• Common carriers and their affiliates providing telephone exchange or exchange access service;
• Facilities-based CMRS providers offering mobile phone service;
• Interconnected VoIP providers; and
• Facilities-based broadband Internet service providers, including, but not limited to Wireless ISPs (WISPs).
After taking a relatively hands-off approach as providers adjusted to the new requirements, the FCC has begun to monitor these filings more aggressively. Recently, the FCC issued an Enforcement Advisory reminding providers of the importance of filing timely and accurate Form 477 data, and warning that providers who do not comply will be subject to financial penalties.
Please note that Form 477 is a time-intensive undertaking. When it developed the current version of Form 477, the FCC estimated that it would take respondents an average of 387 hours to complete a filing. Some parts of the form require analysis by engineering experts and preparation of maps and other files using specialized software. Therefore, all providers who are subject to Form 477 reporting should begin reviewing and compiling their data as early as possible.