The FCC proposed a $100,000 fine against telecom company Cause Based Commerce for filing late paperwork concerning the Universal Service Fund (USF).
Carriers are required to file quarterly and annual worksheets with the Universal Service Administrative Company (USAC), which administers the USF for the FCC. The USAC relies on the accuracy of worksheet information to determine providers’ USF contribution obligations.
In the Notice of Apparent Liability for Forfeiture, the Enforcement Bureau says when a carrier underreports its revenues, “and then exacerbates the problem by not complying with USAC’s attempts to verify the reported revenues through supporting documentation,” the actions prevent administrators from invoicing the carrier for the fu amount they owe for the USF.
The privately-held Cause Based Commerce provides and “markets toll services directly to the public under its corporate name, [Cause Based Commerce]” and mobile voice and data services to the public under its trade name, “Charity Mobile.” The company began providing interstate telecommunications services in late 2006.
Between March 23, 2021, and September 26, 2023, the USAC repeatedly tried to verify the accuracy of data reported in Cause Based Commerce’s annual worksheet filings for 2021 through 2023. The USAC sought the company’s financial statements showing total gross billed revenues for all services, “not merely telecommunication or VoIP services,” according to the FCC. The USAC also asked for the company’s income statement, certain company reports as well as documentation showing how each revenue number reported was determined.
The company repeatedly failed to respond, responded late, or submitted non-responsive documents to USAC over the course of three years, according to the NALF. The USC had to ask for some of the material six times before the telecom responded. It finally told the telecom it wasn’t in compliance with the requirements.
Cause Based Commerce denies that it failed to respond “fully and timely to USAC correspondence concerning the company’s 2021, 2022, and 2023” annual worksheet filings. The telecom “admits that it had submitted the documentation … late because information is compiled by various sources—the company’s billing company, compliance company, accounting firm, and the underlying carrier—and because information provided by the underlying carrier is never accurate and often results in credits being sought and obtained by Cause Based Commerce for inaccurate billing.”
Cause Based Commerce claims that it must carefully review the accuracy of the information received from these sources and provided to USAC, which “requires substantial effort and time to prepare and cannot be reasonably prepared in one (1) week.”
The FCC said the company’s arguments aren’t a valid justification for its actions, noting that Cause Based Commerce’s explanations refer to “issues within its own organization, as well as its underlying carrier.” The agency also pointed out that the telecom never asked for deadline extensions.
Cause Based Commerce must pay the fine within 30 days, or submit documentation to substantiate why it should be reduced or canceled.
By Leslie Stimson, Inside Towers Washington Bureau Chief
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