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The Law Offices of
Edward A. Maldonado, PA

2850 S. Douglas Road
Suite 303
Coral Gables, FL 33134

Tel: (305) 477-7580 
Fax: (305) 477-7504 
Toll-Free: 1+ (877) 245-6326


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

Edward A. Maldonado, Esq.
Practicing Attorney
since 1997

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Federal Communications Commission 499 Filer ID

FCC logoUpon grant of your licenses and certificates there are a number of regulatory reporting requirements that must be met on a monthly, quarterly and annual basis.  Many of these reporting requirements are based upon the revenues your company generates from the sale of services.  These reports are largely financial in nature and require the diligent eye of seasoned and experienced accounting and auditing personnel that can analyze how to best report under existing rules and exceptions.

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In 2007, the FCC required interconnected VoIP providers to contribute to the Universal Service Fund, thereby supporting communicatons services in high-cost areas and for income-eligible telephone subscribers and file the FCC Form 499-A and 499-Q as well as to comply with the Communications Assistance for Law Enforcement Act of 1994 (CALEA). To quell any confusion on the regulatory status of VoIP, the FCC in 2007 further ruled that the Communications Services Act of 1934 “does not differentiate” between telecommunications service providers – thereby making it clear the FCC has the right to require VoIP providers to meet these obligations. For “Interconnected” VoIP Providers, VoIP Resellers (Wholesale), Direct Inward Dial (DID) and Direct Outward Dial VoIP Providers, and VoIP “In-the-Middle.”

Our services in this area include, but are not limited to:                         

FCC Form 499-A.  Due April 1st of every year with 499-Q reports due every March 17, May 17, August 17, and November 17.  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.  All intrastate, interstate, and international providers of telecommunications within the U.S. are required to file the Form 499-A and 499-Q.

This also includes services for:

    • Review of past 499-A and 499-Q filings to ensure correctness

    • Amended filings for past 499-A and 499-Qs

    • Assessment of liabilities and agency payment plan negotiations

    • Review of invoices from NECA (TRS), NANPA, USAC (USF) and for the FCC fee

Registration Requirements

FCC Registration Number (FRN)
Anyone doing business with the Commission, regardless of their de minimis status, must obtain an FCC Registration Number (FRN). 47 C.F.R. § 1.8002(a). 

Registration and Designation of an Agent for Service of Process
All telecommunications carriers, payphone aggregators, and interconnected VoIP providers, regardless of their de minimis status, must register with the Commission and designate an agent for service of process. See. 47 C.F.R. §§ 1.47, 64.1195.  They may do so by filing FCC Form 499-A with the Universal Service Administrative Company (USAC) or with the Office of the Secretary.  See. 47 C.F.R. §§ 1.47, 64.1195. This is submitted directly to USAC.  All telecommunications carriers and interconnected VoIP providers must notify the Commission of any changes to registration information and agent for service of process information within one week of such changes.   See. 47 C.F.R. §§ 1.47, 64.1195.  Changes to registration information must be filed with USAC. See. 47 C.F.R. § 64.1195.  Changes to the agent for service of process must be filed with the Chief of the Market Disputes Resolution Division of the Enforcement Bureau.

Periodic Reporting Requirements

Telecommunications providers must file Telecommunications Reporting Worksheets (FCC Forms 499-A and 499-Q) periodically.  See.47 C.F.R. §§ 52.17, 52.32, 54.706, 54.711, 54.713, 64.604(c)(5)(iii)(B).  The data reported on these forms are used to calculate their contributions to the USF, the North American Numbering Plan (NANP), Local Number Portability (LNP) cost recovery mechanisms, and the Telecommunications Relay Services (TRS) Fund.

FCC Form 499-A is due on April 1 of each year. The FCC Form 499-A must be filed with USAC.  All telecommunications carriers, payphone aggregators, and interconnected VoIP providers must file a completed FCC Form 499-A regardless of their de minimis status.  Providers that offer telecommunications for a fee exclusively on a non-common carrier basis need not file Form 499-A if their contribution to the USF would be de minimis under the universal service rules unless they are required to do so by the rules governing TRS, LNP administration, and NANP administration:  See. 47 C.F.R. § 54.708. FCC Form 499-Q is due on February 1, May 1, August 1, and November 1 of each year.  FCC Form 499-Q must be filed with USAC. 

Contribution Requirements  

Universal Service Fund
In general, telecommunications providers contribute to the USF based on a percentage of their interstate and international end-user telecommunications revenues. However, telecommunications providers that would be required to contribute to USF but meet the de minimis standard in a given year are not required to contribute to the USF that year.  

Universal Service Fund De minimis Telecommunications Providers
Under the FCC rules, a telecommunications provider is considered de minimis if it is required to contribute to the federal Universal Service Fund (USF), but its contribution to the USF in a given year would be less than $10,000.Under47 C.F.R. § 54.708, the term “telecommunications providers” includes “telecommunications carriers” as well as certain other providers of “telecommunications,” such as payphone providers that are aggregators, providers of interstate telecommunications for a fee on a non-common carrier basis, and interconnected Voice over Internet Protocol (VoIP) providers found under  47 C.F.R. § 54.706.  The terms “telecommunications carrier” and “telecommunications” are also defined in section 54.5 of the Commission’s rules under 47 C.F.R. § 54.5  Telecommunications providers that are required to contribute to the USF include wireline telephone companies, wireless telephone companies, paging service providers, and certain Voice over Internet Protocol (VoIP) providers, known as “interconnected VoIP providers.”  See. 47 C.F.R. § 54.706.  and 47 C.F.R. § 54.5 (defining “interconnected VoIP provider”); 47 C.F.R. § 9.3 (defining “interconnected VoIP service”).  Should a telecommunications provider meet de minimis standards, it may be exempt from some, but not all, of the requirements described below.

North American Numbering Plan Administration
The North American Numbering Plan (NANP) is the telephone numbering scheme for 19 North American countries, including the United States.  47 C.F.R. § 52.5(c).  All telecommunications carriers in the United States must contribute to meet the costs of administering the NANP regardless of their de minimis status. 47 C.F.R. § 52.17(a).  Carriers contribute based on a percentage of their intrastate, interstate, and international end-user telecommunications revenues. 47 C.F.R. § 52.17(a).  The minimum contribution amount is $25, even if a carrier has no end-user telecommunications revenues.  47 C.F.R. § 52.17(a). Local Number Portability Administration:  Local Number Portability (LNP) is a service that allows telecommunications customers to keep the same telephone number (at the same location) when switching from one telecommunications carrier to another. 47 C.F.R. § 52.21(l).  All telecommunications carriers must contribute to meet the costs of administering LNP, on a regional basis, regardless of their de minimis status. 47 C.F.R. § 52.32.  Carriers contribute based on their intrastate, interstate, and international end-user telecommunication service revenues. 47 C.F.R. § 52.32(a)(2). Carriers that have no intrastate, interstate, or international end-user revenues derived from providing telecommunications services must contribute $100. 47 C.F.R. § 52.32(a)(1).

Telecommunications Relay Services Fund
The TRS Fund supports the provision of telecommunications relay services allowing individuals with a hearing or speech disability to communicate through the telephone system with individuals without hearing or speech disabilities. 47 C.F.R. § 64.601(14).  Interstate telecommunications carriers must contribute to the TRS Fund based on a percentage of their interstate and international end-user telecommunications revenues regardless of their de minimis status. 47 C.F.R. § 64.604(c)(5)(iii)(A). Every carrier providing interstate and international telecommunications services, which receives some revenues, must contribute at least $25.  If a carrier contributes less than $1,200 annually, that payment must be made at the beginning of the contribution period. 47 C.F.R. § 64.604(c)(5)(iii)(B). Otherwise, a carrier may divide contributions into equal monthly payments. 47 C.F.R. § 64.604(c)(5)(iii)(B).


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.

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