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The Law Offices of
Edward A. Maldonado, PA

815 Ponce De Leon Blvd.
Suite 304
Coral Gables, FL 33134

Tel: (305) 477-7580 
Fax: (305) 477-7504 
Toll-Free: 1+ (877) 245-6326
eam@maldonado-group.com

Our hours of operation are:
9:00am EST to 5:00pm EST

Edward A. Maldonado, Esq.
Practicing Attorney
since 1997

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Prepaid Calling Service Providers

When a provider places their name on a Prepaid Calling Card as the primary service provider, or declares it on similar prepaid phone services (online PINs, PINless/PIN Free ANI Accounts, Top-up ANI Accounts) there is an automatic implication of federal registration as a common carrier of telecommunication services under 47 USC Section 214, and a requirement to abide by all regulations of the FCC related to common carriers and report telecommunication revenues to end-users on the FCC Form 499-A and 499-Q.  We offer a full array of licensure and registration services related to prepaid calling providers and carriers.  These services include:

Filings with the Federal Communications Commission (FCC)

  • FCC Section 214 Authority
  • Department of Homeland Security Review of foreign applicants or foreign owners of carriers seeking Section 214 Authority
  • 499 Filer ID registration
  • FCC Form 499-A.Due April 1st of every year with 499-Q reports due every March, May, August, and November. Requires pre-registration of carrier of VoIP Provider with the FCC and thereafter quarterly 499-Q reporting to certify status as direct contributor, or that provider qualifies as "de minimis" indirect contributor. 
  • FCC Caller Party Number (CPN) reports.
  • FCC Dial Around Compensation reporting requirements & outsourced tariff audits to ensure proper regulatory revenue reporting.
  • Drafting of FCC and compliance manuals tailored to your business (before or after an FCC Enforcement Action)


State Certification of Prepaid Calling Cards

Interstate and international prepaid calling cards and prepaid calling services sold within a state’s borders require certification as a provider of inter-exchange services and sometimes even as a certified prepaid calling card provider. This is done under a state’s Certification for Public Necessity & Convenience (CPNC), and the requirements (Bond Requirements, Hearings, Local Counsel, Financial Stability, Technical Capacity) vary from state-to-state.  This certification must be done prior to entering the cards into markets within that particular state. Providers are required to file a tariff defining the terms and conditions under which they will sell these services to consumers in that state.  The appropriate PUC/PSC reviews terms and conditions along with rates when it certifies the prepaid calling card provider.  Federal regulation supports the state processes under CRF 42.11 (a) which requires federally detariffed non-dominant carriers who provide international service to make available to the public information concerning their existing rates, terms and conditions for all of its international and interstate services. This includes state agencies such as Public Service Commissions, Public Utility Commissions, and Public Utility Control Commissions.

We perform the Preparation, Processing, Submission, and Docket Tracking/Supplements for Multiple State IXC (Inter-Exchange Carrier) Applications for Certification for Public Necessity & Convenience (CPNC) as carrier or reseller in all 50 U.S. States&U.S. Territory of Puerto Rico. This Includes:

Filing for State Certification and Interstate Registrations (Public Utility Commissions)

  • Prepaid Calling Card or Service Provider where separate from IXC;

  • Prepaid Long Distance Carrier as IXC Carrier;

  • Preparation and filing of tariff updates to include new card pricing, remove discontinued cards, and update policies of the company

  • Multi-State Corporate filings

    • Incorporation in all 50 states and Puerto Rico
    • Access to our Registered Agent Network
    • Application for State Certificates of Authority to do business - all 50 States and Puerto Rico

  • State IXC CPNC Certification Compliance

    • Regulatory Annual Assessment reports and filings for IXC in all 50 states and Puerto Rico
    • Quarterly reports for State USF Worksheets, Telecommunications Assessment reports, Statement of Gross Intrastate Operating Revenues, Emergency Telephone Users Surcharge Returns, State Telephone Surcharge Transmittal reports, Emergency Telephone Users Surcharge returns and others similar State Utility Commission reports and returns related to telecommunications.

Card Compliance and Disclosure Compliance

Beginning in 2006, state and federal consumer protection agencies have focused attention on the prepaid calling card industry.  As of July 2008, State Attorney General investigations were active or concluding in New Jersey, Florida, Illinois, Texas, California.  The Federal Trade Commission has also initiated investigations in a number of states in relation to a number of prepaid calling card providers.  Disclosure laws are now on the table in New Jersey, Illinois, Florida, and California. 

There are two layers to the recent thrust of FTC and State Attorney General investigations that have ensued over false advertising and unfair trade practice claims. The first layer is regulatory in nature and concerns the practices of calling card companies in what and how they charge consumers. These issues relate to the billing increments per call, what rates or charges are actually assessed and how much per call, and whether charges (or surcharges) have been portrayed as taxes and regulatory fees when they are not. Much of what governs these issues is found more substantively in state law and regulation as a Certified IXC (CPCN) offering prepaid calling cards or as a certified prepaid calling card provider.

The second layer relates to clarity of disclosures. More specifically, what constitutes “clear and conspicuous” disclosures associated with charges on the prepaid calling cards and found within promotional materials. It is focused on how effective the provider is in not miscommunicating the policies, rates and charges applicable to end user consumers. This has come to include: the accuracy of voice prompt dollar or time balances, the use of English versus foreign language disclosures, and whether your company has properly identified governmental taxes and fees or “coined” a catchall term for a variety of other things, including government taxes and charges. The issue boils down to one of transparency and the effectiveness of your stated policies, as well as the actual practices of charges related to cards and service.


Contact our firm today at (305) 477- 7580, Toll-Free at 1-877-245-6326, or via e-mail for general questions as to our specific services or representation on a particular matter.

Individuals and businesses facing the threat of imminent lawsuits, regulatory Enforcement Actions or criminal charges are urged to contact The Law Offices of Edward A. Maldonado PA today to schedule a complementary consultation from our South Florida law firm.  Time is always of the essence in such cases.

Most of all, thank you for visiting The Law Offices of Edward A. Maldonado PA website. Let us know if this site and its links were a helpful resource as a prospective or existing client.