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On March 12th, 2025, the Federal Communications Commission (“FCC”) issued a Public Notice (“Notice”) seeking comment on which FCC rules should be repealed or modified to alleviate “unnecessary regulatory burdens” and enhance investment and innovation in telecommunications networks. Along with inviting general feedback on which rules to eliminate, the Notice also urges commenters to consider several policy factors in their analysis, including:Continue Reading ALERT: Delete, Delete, Delete—FCC Calls for Comment on Which Rules Should be Eliminated

On December 10, 2024, the FCC’s Enforcement Bureau (“Bureau”) released an order (“Order”) determining that nearly 2,500 providers across the calling chain had submitted deficient submissions to the Commission’s Robocall Mitigation Database (“RMD”). Providers listed in the Order have until December 31, 2024, to cure the identified deficiencies, or otherwise explain why they should not be removed from the RMD, and notify the Bureau.Continue Reading ALERT: FCC Sets December 31, 2024 Deadline for Providers to Address Robocall Mitigation Database Deficiencies

On August 8, 2024, the Federal Communications Commission (“FCC”) issued a Notice of Proposed Rulemaking (“NPRM”) to address the growing use of AI-generated robocalls. The FCC’s NPRM follows a 2023 inquiry proceeding into how the FCC could use its authority under the Telephone Consumer Protection Act (“TCPA”) to better protect consumers from unwanted or illegal robocalls.Continue Reading FCC Proposes New Rules Governing AI-Generated Robocalls

In October 2020 and 2021, the FCC adopted a pair of Orders to streamline the processing of applications involving “reportable” foreign ownership that are referred to the Committee for the Assessment of Foreign Participation in the United States Telecommunications Services Sector—commonly known as “Team Telecom.” Team Telecom is tasked with assessing the national security, law enforcement, foreign policy, and trade policy concerns presented by FCC applications seeking licensing authority or approval for cross-border M&A transactions.Continue Reading ALERT: Team Telecom Streamlining Procedures Take Effect

Last week, the FCC’s Enforcement Bureau (“Enforcement Bureau”) entered into a consent decree (“Consent Decree”) with prepaid calling provider TracFone Wireless (“TracFone”), addressing TracFone’s failure to adequately safeguard customer proprietary network information (“CPNI”). In the Consent Decree, TracFone agreed to pay a $16,000,000 civil penalty along with a series of comprehensive directives to mitigate network vulnerabilities. Continue Reading Burners and Backdoors: The FCC’s $16 Million Settlement with TracFone for Breaches of Customer-Facing APIs

On July 26, 2024, the Federal Communications Commission (“FCC”) issued a Public Notice announcing that new pole attachment rules, which the FCC adopted in a December 2023 Report and Order, are effective as of July 25, 2024. The new rules – which we described in a prior blog post – are intended to “speed broadband deployment by making the pole attachment process faster, more transparent, and more cost effective.” Among other things, the FCC’s updated pole attachment rules establish the Rapid Broadband Assessment Team, an intra-agency rapid response team charged with prioritizing and expediting resolution of disputes that impede or delay broadband deployment, and also require utilities to provide pole attachment applicants with information about the status of their utility poles to aid communications providers in planning their build outs. Continue Reading UPDATE: FCC’s New Pole Attachment Rules are Now Effective

As the FCC continues to exercise close oversight of the use of Customer Proprietary Network Information (“CPNI”), telecom stakeholders should also be sensitive to potential data security obligations under any relevant mitigation agreements with “Team Telecom,” the collection of Executive Branch agencies tasked with reviewing and resolving any national security implications related to foreign ownership of telecom providers.Continue Reading Data Security Is National Security: Inside the FCC Enforcement Bureau’s Latest Crackdown

The Federal Communications Commission (“Commission”) has released a series of items pertaining to its annual regulatory fee assessment and collection process, including: (1) the 2024 Regulatory Fee Notice of Proposed Rulemaking regarding agency-wide regulatory fee assessment and collection; and (2) a concise Space and Earth Station Report and Order on certain regulatory fees for streamlined small satellite and In-Space Servicing, Assembly, and Manufacturing (“ISAM”) operators stemming from the Space and Earth Station Fee Notice of Proposed Rulemaking. Together, these documents reflect the Commission’s continuing efforts to revamp its methodology for assessing regulatory fees in light of the demands the rapidly evolving space industry places on the Commission, as well as significant internal reorganization to help address those challenges. The TLDR: All current and future Space Bureau regulatees will be assessed significantly higher fees in FY 2024 than in previous years. All that is left to be determined is who will be responsible for what proportion? And how much will that be? Continue Reading Space Bureau Regulatory Fees Skyrocket in FY 2024

While many venture capitalists and private equity sponsors are aware the Committee on Foreign Investment in the United States (“CFIUS”) has authority to review inbound investments in certain sensitive U.S. industries, many transaction parties may be unaware of CFIUS’s jurisdiction to also review the national security risks presented by real estate transactions involving foreign persons. Because real estate transactions do not trigger CFIUS’s mandatory filing requirements, it is uncommon for transaction parties to proactively seek CFIUS review of these deals.Continue Reading Know Thy Neighbor as Thyself: CFIUS Considerations in Commercial Real Estate Transactions

The FCC – in the latest iteration of its expanding role as a regulator in the national security space – recently adopted a Notice of Proposed Rulemaking (“NPRM”) proposing to fortify the security of the wireless supply chain by imposing heightened requirements on the Telecommunication Certification Bodies (“TCBs”) and Measurement Facilities (“Test Labs”) that approve devices marketed and sold in the U.S.Continue Reading FCC to Strengthen Equipment Authorization Process to Protect U.S. National Security