On Wed, 26 Mar 2014 12:44:57 -0500
  Roger Howard <[email protected]> wrote:
> So if I'm de minimis, do I have to register anything with the FCC? or just
> ignore it and let Vitelity pay until I get big?

Get a telcom lawyer. This is a minefield and can blow up in your face if you
do it wrong. There are several groups that do just this and they are not that
expensive. If I remember correctly there are a couple on this list.

We provide "wholesale voip" to a couple of WISP's. We "own" the customer, we 
handle
the e911 and USF and we bill though the WISP in the customer's name and the
"agent" doesn't have access to the CPNI data. It's all running through our 
switch and
it's still a minefield. We have had to consult the lawyers multiple times to 
be sure
to keep us and the WISP out of hot water.

So, the salesman could be right or he might not know and doesn't care. Don't 
trust
what he say's or anybody else for that matter. Get you own lawyer that knows 
both Federal
and your State requirements. The fines for mistakes are designed to get the 
attention of
multi-national companies. They could easily kill one of us.


> 
> 
> On Wed, Mar 26, 2014 at 12:14 PM, Fred Goldstein 
><[email protected]>wrote:
> 
>>  On 3/26/2014 12:53 PM, Randy Cosby wrote:
>>
>> Doesn't sound right to me, unless they are going to do all the billing and
>> tax filing in your behalf.
>>
>> If they charge you USF on your wholesale rate, who pays on the difference
>> between your wholesale rate and the customer's marked up rate?
>>
>>
>> USF rules are pretty strict.  If a USF-subject class of carrier has
>> interstate telecommunications revenues (not Internet per se) that would
>> subject it to USF payments of <$10k/year, then it is "de minimis" and does
>> not pay.  BUT then its suppliers treat it as retail and they pay on the
>> services supplied to the de minimis carrier.  Once the carrier crosses out
>> of de minimis, it suppliers must verify that it is paying USF, and then
>> should not charge it USF on their wholesale sales.  So it's paid once, only
>> once, by the last non-de mimimis carrier en route to the retail customer.
>> (Disclaimer: IANAL and that's just my understanding.)
>>
>> E911 is a state requirement.  Interconnected VoIP services have to do it,
>> but the state sets the price.
>>
>>
>>
>> On 3/26/2014 10:51 AM, Roger Howard wrote:
>>
>> So I've been using Vitelity for a while in the office here, with
>> freeswitch, and it works great.
>>
>> I was considering reselling the vitelity service to my customers, the only
>> thing that has held me back is the legal requirements. I thought I had to
>> collect USF fees, register with the FCC, pay it to them. Maybe sales tax.
>> etc.
>>
>> I was at wispamerica yesterday and talked to a fellow at the Vitelity
>> booth. He told me that they collect the USF, so we don't have to, the e-911
>> is optional, all I have to do is sign up as a reseller to get better
>> pricing and charge what I like to the customers.
>>
>> Is this correct? I've learned to never trust a salesman. Something doesn't
>> sound right, surely it can't be that easy?
>>
>> Thanks,
>> Roger
>>
>>
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>> Randy Cosby
>> InfoWest, Inc435-674-0165 x 2010
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>> --
>>  Fred R. Goldstein      k1io     fred "at" interisle.net
>>  Interisle Consulting Group
>>  +1 617 795 2701
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Larry Ash
Network Administrator
Mountain West Telephone
123 W 1st St.
Casper, WY 82601
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