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    Deadline for CLECs to Comply with Mandatory Electronic Tariff Filing is January 17

    January 12, 2012

    Competitive Local Exchange Carriers (CLECs) with switched access tariffs on file with the Federal Communications Commission (FCC) are reminded that they have until Tuesday, January 17, 2012 to file a copy of their current tariff in the FCC’s Electronic Tariff Filing System (ETFS). Any tariffs that are currently on file with the FCC, but are not refiled in ETFS by January 17, 2012, will be cancelled by the FCC.

    As we have reported previously, see October 25 Client Alert here, the FCC has adopted a new rule that requires all tariff filers, including CLECs, to utilize ETFS to file all tariffs and tariff revisions. Until now, only incumbent carriers were required to use ETFS.

    This initial filing will serve as the CLEC’s Base Document. CLECs must include a transmittal letter with their Base Document filing. There is no filing fee applicable to this initial filing. A CLEC may not make changes to its Base Document prior to filing it via ETFS. CLECs are required to file all subsequent tariff revisions, along with any associated working papers, in ETFS going forward.

    A copy of the Report and Order establishing the rule may be found here. (FCC-11-92, WC Docket No. 10-141) A copy of the FCC’s public notice that announced the window for filing may be found here. (DA-11-1706, WC Docket No. 10-141)

    For more information please contact Katherine Barker Marshall or any of our attorneys in the Arent Fox Telecommunications Practice Group.

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