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REGULATORY VIEW VOLUME 42 ISSUE 5

MAY 2026

FCC Launching High-Cost USF Reform

Inside This Issue

In its latest evaluation of USF programs that apply to rate-of-return carriers, the FCC has adopted a Notice of Proposed Rulemaking (NPRM) that signals a new review of the future of USF focusing on two categories of support, and seeks comment on strategies for the most efficient use of USF resources to update high-cost mechanisms, including Connect America Fund Broadband Loop Support (CAF BLS) and High Cost Loop Support (HCLS), which carry no forward-looking buildout obligations. Model-based mechanisms under consideration and set to sunset include A-CAM I (2026) and Revised A-CAM I and A-CAM II (both in 2028). The FCC states that its primary objectives with the proposed reforms are to strike the right balance between serving the needs of the public in an affordable and efficient manner, keeping pace with technology, facilitating fair and balanced competition among providers, and enabling longterm planning. Comments and Reply Comments will be due 60 and 90 days, respectively, after publication in the Federal Register. The NPRM seeks comment on:

» Three potential paths forward for the legacy and A-CAM support mechanisms at issue in the item: (1) updating these mechanisms to align with the current landscape; (2) establishing a single new, modernized fixed-support mechanism; or (3) maintaining the status quo for legacy support mechanisms and allowing the A-CAM support mechanisms to sunset;

» Whether ongoing support should be reduced or eliminated in areas where

the carrier or an unsubsidized competitor already provides service or will

FCC Gets Specific in “Know Your Upstream Provider” FNPRM

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FCC Moves to Streamline BDC Filing and Challenge Processes

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Audit Issues Highlight USAC Reform Comments

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FCC Improves Disaster Information Reporting System (DIRS)

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News from the States

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Important Deadlines and Due Dates

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Event Calendar

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(Continued on pg 2)

Upcoming Events

2026 TCA | Pinion Financial Conference Save the date for this year’s Financial Conference! Date: September 23-25 Location: The Mining Exchange Hotel in Colorado Springs, CO Registration and room block will open late June. Please reach out to broadband@pinionglobal.com for questions.

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May 2026 TCA | Pinion Regulatory View (Continued from pg 1)

provide service or where another provider has an enforceable commitment through a funding program such as the $42.5 billion Broadband Equity Access and Deployment (BEAD) Program;

» How the emergence of low-Earth orbit (LEO) satellite service will affect the

establishment of a new high-cost support mechanism, and if current mechanisms were modernized, how the FCC should consider the presence of satellite service in areas receiving support under those mechanisms;

» Deployment obligations for USF support and what support would be appropriate for carriers receiving legacy, A-CAM I, Revised A-CAM I, or A-CAM II support; and

» Adopting a short-term A-CAM I extension from the end of 2026 through

the end of 2028, thereby aligning the terms of the three sunsetting A-CAM mechanisms to all conclude at the end of 2028.

The NPRM also seeks further comment on the role, if any, that USF can play in supporting the transition to all IP-networks. As detailed in a recent report, NTCA is supportive of continued and targeted funding for the high-cost USF program, and in its May 20 press release, is optimistic that USF support remain “predictable and sufficient” and hopes that any reforms Congress will consider, “should continue to support robust broadband networks that rural Americans rely on for high-speed, reliable[,] and secure connectivity at affordable prices.” An important first step, according to NTCA, is to identify where market failures exist and then steer ongoing support only to rural areas where support is needed.

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SpaceX, by contrast, in its May 13 ex parte notice seeking changes to the draft For any questions on the NPRM prior to its adoption, expressed broad support for the FCC’s goal to “modRegulatory View or any ernize [its] rules and sunset outdated legacy programs” but argued that satellite regulatory matters, contact broadband and the Broadband, Equity, Access, and Deployment (BEAD) program have eliminated the need for subsidy programs, chief among them USF. In addition to urging the FCC to phase out most of the High Cost program, SpaceX has recommended revisions to the program which propose an expanded role for low Earth orbit (LEO) satellite services and expands on the NPRM’s question of whether terrestrial networks should be treated as primary infrastructure, while satellite should qualify as an unsubsidized competitive service rather than a secondary, redundant layer. The satellite provider expects that current and planned third-generation satellite launches by its company (and other satellite broadband providers such as Amazon Leo) will increase future download and uplink capacities of subscribers many times over, erasing “the access gaps the subsidies were designed to fix.” TCA | Pinion View: It is noteworthy that the agency has sought and listened to recommendations of bicameral, bipartisan groups, including the Congressional USF Working Group, which has received feedback from stakeholders, industry groups, advocacy organizations, and the public. And because there are strong and differing positions held on this issue so crucial to rural providers and their consumers, it remains vital that the FCC hears RLECs about the importance of USF to rural consumers. TCA | Pinion will be weighing in and invites clients to share your thoughts on this topic. TCA | Pinion will likewise keep you updated on any developments that are relevant to you. TCA | Pinion Contact: Angela Phoenix

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May 2026 TCA | Pinion Regulatory View

FCC Gets Specific in “Know Your Upstream Provider” FNPRM The FCC adopted another Further Notice of Proposed Rulemaking (FNPRM) this month that aims to strengthen the STIR/SHAKEN caller ID authentication framework and eliminate persistent gaps that allow illegal robocalls to reach consumers. The FNPRM proposes to significantly expand the “Know Your Upstream Provider” (KYUP) obligations of voice service providers across the entire call chain. Specifically, the FNPRM includes three interrelated initiatives: strengthening KYUP requirements, raising and codifying attestation standards, and closing structural loopholes in how STIR/SHAKEN is implemented. Initial comments on the FNPRM are due June 25, and reply comments are due July 27. The most significant proposed change is the transition from a general principles-based KYUP obligation to a structured compliance framework for all voice providers. Under current rules, providers must take “reasonable steps” to ensure upstream partners are not transmitting large volumes of illegal traffic. The FNPRM proposes to replace that standard with a set of explicit baseline requirements that all providers must follow. These requirements include five areas: collecting detailed information about upstream providers, reviewing their regulatory compliance, verifying the accuracy of the information provided, continuously monitoring their traffic and behavior, and taking decisive action when risks are identified. Under the information collection component, providers would be required to gather detailed business, ownership, operational, financial, and service-level information directly from upstream partners, including beneficial ownership data, regulatory history, and indicators of foreign control. This information would then feed into a compliance review process that includes confirming the upstream provider’s presence in the Robocall Mitigation Database, verifying possession of STIR/SHAKEN credentials such as SPC tokens, and checking for inclusion on national security or enforcement watchlists. The FNPRM’s verification and monitoring requirements would require voice providers to conduct independent due diligence to confirm the authenticity of upstream entities, including evaluating digital presence, ownership structures, and operational consistency, while also deploying call analytics and other tools to detect suspicious traffic patterns. The FNPRM claims that these steps are critical to preventing bad actors from disguising themselves as legitimate providers or re-entering the ecosystem under new identities. The FNPRM also proposes to require providers to take “responsive action” when KYUP reviews raise

concerns. This includes refusing or discontinuing service to upstream providers that cannot be validated, lack required certifications, appear linked to illegal activity, or otherwise fail compliance checks. The proposal establishes an “objectively reasonable” standard for such decisions and would require providers to document their determinations and provide notice before terminating service. In parallel, the FNPRM seeks to reinforce KYUP obligations through enhanced oversight of the STIR/SHAKEN Governance Authority, which controls access to the authentication system via SPC tokens and certification processes. The FNPRM proposes requiring the Governance Authority to adopt stricter vetting procedures for issuing credentials, apply those standards to existing participants, and take more aggressive action to revoke credentials from providers engaged in misconduct. The FCC cites evidence that providers are frequently assigning higher-than-warranted attestation levels, particularly A-level “full” attestations, even to calls associated with illegal activity. To address this, the FNPRM would formally codify the three attestation levels (Continued on pg 4)

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May 2026 TCA | Pinion Regulatory View (Continued from pg 3)

and establish detailed criteria for when each level may be used. It would also link attestation decisions directly to KYUP and Know Your Customer processes, ensuring that providers must have verified knowledge of both the caller and its right to use the associated number. The FNPRM further proposes to define and explicitly prohibit “improper attestation,” including both overstatement and understatement of trust levels, as well as the use of unrelated factors such as commercial incentives in assigning attestations. By codifying these requirements, the FCC aims to create a clearer enforcement framework and deter practices that undermine the credibility of authentication data. Finally, the FNPRM addresses gaps in STIR/SHAKEN deployment that allow calls to evade authentication or lose authentication data in transit. It proposes eliminating the remaining STIR/SHAKEN exemptions and extensions, requiring all providers that serve end users to participate in attestation decisions, prohibiting intentional routing of calls over non-IP networks to strip authentication information, and expanding obligations on intermediate providers to authenticate calls. The FNPRM claims that these changes are intended to ensure that authentication data remains intact throughout the call path and that all providers share responsibility for maintaining that integrity. TCA | Pinion View: The proposals in this FNPRM signal a shift in the FCC’s approach to robocall mitigation. Rather than relying primarily on technical standards and voluntary compliance with general mitigation practices, the FCC proposes detailed requirements that include explicit obligations, continuous monitoring, and enforced accountability across the entire call path. For RLECs, the degree to which these proposals would require significant changes depends on how many and what types of upstream providers you interconnect with. At a minimum, if these proposals were to become rules, all voice providers would need to update their Robocall Mitigation Database plans to meet the new KYUP standards.

RAD ID REMINDER USAC requires Representative Accountability Database (RAD) IDs for all service providers that enroll and manage Lifeline subscribers in the National Lifeline Accountability Database (NLAD) and access the National Verifier. Annual renewal notices sent to your personal email must be completed at least once per year by the deadline to continue performing transactions for your subscribers in USAC’s system. TCA | Pinion Contact: Angela Phoenix

TCA | Pinion Contact: David Wright

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May 2026 TCA | Pinion Regulatory View

FCC Moves to Streamline BDC Filing and Challenge Processes During this month’s open meeting, the FCC unanimously approved a Sixth Report and Order (Order) and Fifth Further Notice of Proposed Rulemaking (FNPRM) related to its Broadband Data Collection (BDC) rules and requirements. Both the adopted and proposed rules focus on refining and streamlining processes that underpin the National Broadband Map and look to simplify requirements and eliminate legacy obligations that the FCC says may no longer serve policy objectives. The Order introduces rule changes designed to streamline how broadband availability and subscription data are collected, validated, and corrected. For example, the Order aligns the “broadband” definition used in FCC Form 477 with that used in the BDC. According to the FCC, harmonizing these definitions should reduce inconsistencies between datasets, improve data comparability, and simplify reporting obligations for providers. This adjustment narrows the scope of Form 477 by excluding customized enterprise services, while also expanding it to capture low-bandwidth mass-market offerings, which should institute a more consistent statutory interpretation of broadband service, according to the Order. The Order also takes steps meant to simplify the BDC challenge and verification processes. Most notably, it eliminates the requirement that service providers be notified of and allowed to respond to challenges during the development cycle of the Broadband Serviceable Location Fabric (Fabric). Instead, providers will retain the opportunity to challenge outcomes after updates are incorporated into the map. This change is paired with a clarification that statutory deadlines under the Infrastructure Investment and Jobs Act apply only to availability challenges, not Fabric challenges. Additionally, the Order includes changes to the BDC verification and audit processes. Providers will no longer be required to correct their filings following an adverse audit or verification finding. While providers will remain responsible for initial data accuracy and may still face enforcement consequences for misreporting, the FCC will directly amend or remove inaccurate coverage data from the National Broadband Map. The Order states that this streamlining should accelerate data correction and reduce administrative burdens on providers, particularly smaller entities with limited staff and compliance resources. Going beyond the Order’s changes, the FNPRM’s proposals include some potentially transformational changes to the current BDC rules. Among the most notable propos-

als is the potential elimination of reporting requirements for “grandfathered” broadband services and fixed broadband offerings below 25/3 Mbps. The FNPRM questions whether these data provide sufficient policy value to justify their reporting burden, especially given the upward revision of the benchmark for broadband capability to 100/20 Mbps. Similarly, the FNPRM considers ending the collection of 3G mobile broadband and mobile voice availability data. However, the FNPRM acknowledges that such data may still hold relevance for certain programs, particularly in remote regions such as Alaska, and seeks input on whether targeted or “special” collections should replace blanket reporting obligations. The FNPRM also explores technical and procedural flexibilities aimed at reducing filers’ compliance burdens, including eliminating the requirement to report maximum buffer sizes for wireline networks, relaxing the seven-meter antenna height assumption used in fixed wireless modeling, and simplifying the coverage restoration process following successful challenges or failed audits. (Continued on pg 6)

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May 2026 TCA | Pinion Regulatory View (Continued from pg 5)

The FNPRM also offers several significant proposals for modifying the BDC challenge process. For instance, it proposes to allow providers to rebut certain fixed challenges using structured infrastructure data, which could speed up resolution timelines and enable more data-driven outcomes. Additionally, the FNPRM considers shortening the current two-step challenge timeline—currently up to 120 days—into a single-window process for consumer challenges, while evaluating whether similar reforms are appropriate for bulk disputes. Similarly, the Commission is examining how to better facilitate and revise the BDC’s use of crowdsourced mobile data, which plays a supplementary role in validating provider-reported coverage. Proposed changes include relaxing requirements for user identification and data parameters, integrating additional third-party datasets, and incorporating results from the FCC’s Speed Test App. The FNPRM also suggests changes to BDC governance requirements, such as data retention and confidentiality. The FNPRM contemplates imposing mandatory retention periods for underlying data used in BDC filings versus establishing voluntary best practices. It also proposes granting automatic confidential treatment to certain categories of sensitive data, such as infrastructure details and subscriber information, which would eliminate the need for repetitive confidentiality requests.

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TCA | Pinion View: Taken together, the BDC updates included in this Order and FNPRM demonstrate that the FCC is aware of the BDC-related issues providers have been dealing with since the process’s inception. The FCC says it is focused on process optimization, reducing redundancy, eliminating outdated requirements, and improving the resulting broadband Fabric as well. These are worthwhile goals, but some of the changes contemplated in the FNPRM may risk undermining the accuracy and value of the Fabric in the name of “efficiency and streamlining.” In the long run, the accuracy of our broadband maps should not be sacrificed just to make reporting simpler or the FCC’s updates easier to automate. TCA | Pinion Contact: David Wright

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May 2026 TCA | Pinion Regulatory View

Audit Issues Highlight USAC Reform Comments The FCC received over 20 responses to its Public Notice, requesting input on potential reforms of the Universal Service Administrative Company (USAC) (see TCA | Pinion Regulatory View for April 2026). Many of the comments focus on a variety of issues experienced during USAC audits, and, generally, the criticisms described USAC administrative and audit processes as sometimes being burdensome, unpredictable, and overly long. At the same time, the comments reveal differences of opinion regarding USAC governance, oversight, and the extent to which the FCC should restructure the organization. Both NTCA and WTA argue that current USAC audits often impose disproportionate burdens on small rural carriers with limited staffing and administrative resources. These industry groups describe lengthy audits, overlapping information requests, and review cycles that can last multiple years, requiring providers to divert management time and operational resources away from network deployment and customer service. The Small Company Coalition (Coalition) similarly argues that smaller carriers are uniquely vulnerable to excessive audit demands because they lack the compliance and legal staffing available to larger companies. The Coalition emphasizes that even audits resulting in no significant findings can impose major operational and financial strain. Consequently, a major area of consensus involves the need for more predictable and proportionate audits. Several commenters argue that audits often focus heavily on technical or immaterial discrepancies that have little actual financial impact on the USF. For example, WISPA argues that many existing audit and documentation requirements were originally developed with larger legacy telecommunications carriers in mind and do not always fit the operational realities of smaller broadband providers. WISPA urges the FCC to ensure that audit processes are scalable and proportionate based on provider size and risk profile. To that end, multiple commenters ask the FCC to adopt formal materiality standards similar to those used in traditional auditing practices so that oversight efforts are directed toward meaningful compliance risks rather than minor documentation issues. Commenters also broadly agree that audit timelines need reform. WTA criticizes situations in which carriers received large information requests with extremely short response deadlines, while audits themselves remained open for years. NTCA proposes formal “shot clocks” governing audit duration and agency response times. Another com-

mon theme was the need for clearer guidance and more consistent interpretations of FCC rules. NTCA argues that similarly situated providers can receive very different audit outcomes (like playing “audit roulette”) depending on the auditor involved, creating uncertainty and undermining confidence in the process. The Coalition of Over 800 499 Filers raises similar concerns, emphasizing that providers often face retroactive scrutiny based on evolving interpretations of contribution and reporting rules. Several commenters, therefore, urge the FCC and USAC to provide clearer prospective guidance and centralized interpretations to reduce disputes before audits occur. Several commenters also concur that the underlying complexity of FCC universal service rules contributes to audit problems. For instance, former FCC official Carol Mattey emphasizes that years of layered reporting requirements and compliance obligations have created a system that is difficult for providers and applicants to navigate consistently. To that point, USTelecom suggests reforms designed to im(Continued on pg 8)

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May 2026 TCA | Pinion Regulatory View (Continued from pg 7)

prove efficiency, transparency, and processing consistency across USAC operations, arguing that clearer guidance, more predictable timelines, and improved coordination between USAC and the FCC would reduce unnecessary administrative costs and compliance uncertainty for providers participating in USF programs. At the same time, most commenters broadly support maintaining strong USF program oversight and accountability mechanisms. No commenter argues against audits entirely or questions the importance of protecting universal service funding from fraud, waste, and abuse. Instead, the consensus position was that audits should be more targeted, transparent, and proportionate to the risks involved. There was less agreement regarding broader governance reforms at USAC itself. Some commenters propose restructuring the USAC Board to include more independent directors with auditing and compliance expertise, while groups such as the State E-Rate Coordinators’ Alliance argue that stakeholder representatives with direct program experience remain essential to effective and fair governance. Even here, however, commenters generally agree that improved communication, operational transparency, and stakeholder engagement would benefit USAC’s processes. TCA | Pinion View: These comments present the FCC with a relatively unified message: stakeholders support reasonable oversight of USF programs, but they believe USAC’s current audit and oversight practices too often impose excessive costs, timelines, and administrative burdens, relative to the compliance issues being examined. RLECs, nationwide providers, wireless operators, former FCC staff, schools, and libraries alike recommend that the FCC adopt USAC reforms that improve predictability, consistency, transparency, and procedural fairness, while preserving accountability for the billions of dollars administered through USF programs. TCA | Pinion Contact: David Wright

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May 2026 TCA | Pinion Regulatory View

FCC Improves Disaster Information Reporting System (DIRS) By a unanimous vote, the FCC has adopted a Third Report and Order (Order) to modernize and streamline the Disaster Information Reporting System (DIRS) reporting and data collection process for communications service providers during and after major disasters. Since DIRS reporting became mandatory (see Regulatory View, February 2025 and Regulatory View, August 2025), the FCC has sought comment on ways to reduce reporting burdens for smaller entities in particular so they can redirect their limited time and critical resources on restoring service rather than filing redundant, time-consuming reports. When enacted, the new rules will:

» Enable manual filers to submit a single streamlined form instead of multiple worksheets; » Create a “one-click” option for manual filers when there are no changes from the previous day’s report; » Remove fields containing data shown elsewhere in the report(s) or that do not offer public safety stakeholders new or significant information;

» Limit DIRS reporting obligations to facilities-based providers, exempting resellers and mobile virtual network operators (MVNOs) not operating communications infrastructure;

» Direct the Public Safety and Homeland Security Bureau (PSHSB) to streamline the process by which filers voluntarily submit geographic information about areas that are out of service; and

» Eliminate the requirement for a final report after DIRS is deactivated. Public safety voice and broadband network operators will also be required to report on the status of their network infrastructure and the impact that disaster outages have had on the public safety of their customers. TCA | Pinion View: This latest Order is an indication that the FCC is listening to the most common hurdles providers must overcome in restoring service to their customers during outages. Because time is one of the most precious commodities when customers’ services need to be restored in as timely a manner as possible, the less duplicative paperwork providers are encumbered with, the more time they have to address the concerns of their customers. As these new improvements work their way through the approval process, please let us know if you have any questions or need assistance with these reporting systems and requirements. TCA | Pinion Contact: Angela Phoenix

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May 2026 TCA | Pinion Regulatory View

News from the States California’s Public Utilities Commission (PUC) has published a proposal, Resolution T-17925, which will update the state’s 2021 Broadband Loan Loss Reserve Program by adding a direct loan option. If adopted, broadband providers, including local government agencies, nonprofit organizations, and tribal governments will be eligible for loan funds to cover costs related to financing broadband infrastructure deployment, payment of debt issuance, obtaining credit enhancement, and funding of reserves for the payment of principal and interest on the debt. The PUC has scheduled to vote on the draft order at its June open meeting. Iowa Governor Kim Reynolds (R) has signed a bill to expand the sales tax exemption for telecommunications equipment by removing the “primarily” usage requirement and making all such purchases used in the furnishing of telecommunications services exempt from sales tax. Taking effect on July 1, the law exempts sales tax on the purchase of central office equipment or transmission equipment used by certain entities in the furnishing of telecommunications services on a commercial basis. The current law specifies that the tax exemption is available only for central office equipment or transmission equipment that is “primarily” used by certain telecommunications companies in the provision of telecommunications services. Minnesota Governor Tim Walz (D) signed a bill into law that will largely deregulate the state’s telecommunications sector. The law becomes effective July 1, and repeals numerous state-level consumer protections and regulatory requirements. According to the bill’s sponsors, HF 4052 “reflects the changing realities of the telecommunications marketplace while maintaining consumer protections and regulatory oversight.” The law removes several existing statutes related to rate regulation, service classification, reporting, and specific telecommunications services and also repeals statutes governing coin-operated telephones, detailed rate regulation procedures, special pricing plans for government entities, service classification processes, and alternative regulation plans, among others. The legislation also aligns state eligibility and discount rates with the E-Rate program, removes the Public Utilities Commission’s authority to set intrastate discounts by order, and introduces new customer notification requirements. North Carolina Governor Josh Stein (D) signed into law a bill that will result in the reclassification or reallocation of certain unspent federal recovery funds so long as the money remains within eligible uses and complies with federal law and guidance. The funds could be used for broadband infrastructure, among other uses. HB 433 specifically deals with state fiscal recovery funds provided to North Carolina through the American Rescue Plan Act and administered through state budget and pandemic recovery offices. The state will now be allowed to reallocate state fiscal recovery funds when there is a reasonable expectation that the money will not be spent before the applicable federal deadline. On April 29, the Oklahoma House passed SB 1122 into law that modifies the current ad valorem tax from around 22.85 percent down to 15 percent for tax years 2026 through 2036. Passed without the governor’s signature, the measure applies to the state’s underserved areas where there is less than 10 percent broadband coverage and exclusively to qualifying service such as fiber lines and network facilities by broadband service providers building infrastructure and offering broadband-based services including internet access, Voice over Internet Protocol, or Internet Protocol television to end-user consumers offering wired internet exceeding 100/20 Mbps. Excluding other property, the bill requires that the specified infrastructure be taxed, “constructed or installed and placed in service” after the bill’s effective date. The Tax Commission estimates that the bill likely will reduce local property tax collections by approximately $20 million. Wisconsin Governor Tony Evers (D) announced that the state would make $60 million in broadband grant funding available, with the goal to “close gaps by reaching locations not served by the federally funded Broadband, Equity, Access and Deployment (BEAD) program.” The state claims that approximately 30,000 locations in Wisconsin would remain unserved by the BEAD program. NTIA disputes this claim, stating that, “Nearly 25,000 of those locations are already being served through BEAD-funded satellite service. It is extremely disappointing that Wisconsin would seek to spend additional taxpayer dollars to overbuild a federally funded broadband program that is already delivering speeds at or above 100/20 Mbps.” Gov. Evers, however, argues that the funding is necessary because NTIA chose to “utilize less reliable technologies and infrastructure with shorter useful lives and lower performance speeds than fiber” in its BEAD plan for the state.

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May 2026 TCA | Pinion Regulatory View

Important Deadlines and Due Dates *Dates falling on a weekend or Holiday will be due the next business day. June 8, Low Income Customer Claims: All ETCs that request reimbursement for participating in the low-income program must certify and submit to USAC their Lifeline and Link-Up Customer Claims. This must be electronically submitted using the Lifeline Claims System by the eighth day of each month to receive support in that month. If the form is not received by the eighth, support will be received the following month. June 15, Reassigned-Number Database: On the 15th of every month, service providers must report permanent disconnections of their subscribers’ telephone numbers to the Reassigned Numbers Database Administrator (RNDA). July 1, FCC Form 481, Annual Reports: Rate of return (RoR) LECs and CETCs are required to file the following annual reporting requirements mandated by the USF/ICC Transformation Order: (1) certification of the ability to function in emergency situations, (2) certification that USF is not used for equipment that poses a national security risk, (3) list of holding companies and affiliates, (4) Tribal engagement information if applicable, (5) voice service rates comparability certification, (6) terms and conditions for Lifeline subscribers, (7) RUS Operating Report or audited financial statements or equivalent., (8) FCC Form 470 bids for category one telecommunications and access services with certifications required following E-Rate program year obligations. July 8, Low Income Customer Claims: All ETCs that request reimbursement for participating in the low-income program must certify and submit to USAC their Lifeline and Link-Up Customer Claims. This must be electronically submitted using the Lifeline Claims System by the eighth day of each month to receive support in that month. If the form is not received by the eighth, support will be received the following month. July 15, Reassigned-Number Database: On the 15th of every month, service providers must report permanent disconnections of their subscribers’ telephone numbers to the Reassigned Numbers Database Administrator (RNDA). July 15, Performance Measures Testing Quarterly Results: All carriers that receive High Cost Program USF support with a broadband deployment obligation are required to submit speed and latency test data from performance measures testing conducted in the previous quarter at a random sample of locations reported in the HUBB. August 1, FCC Form 499-Q: Telecommunications Reporting Worksheet: All telecommunications carriers that expect to contribute more than $10,000 annually to Federal Universal Service Fund support mechanisms must file this quarterly form. August 1, FCC Form 502: Number Utilization and Forecast Report: Service providers that receive numbering resources from NANPA or another service provider are required to report on its utilization using the Numbering Resource Utilization/ Forecast Report (NRUF) Form 502 under the following number use categories: Administrative, Aging, Assigned, Available, Intermediate and Reserved. August 8, Low Income Customer Claims: All ETCs that request reimbursement for participating in the low-income program must certify and submit to USAC their Lifeline and Link-Up Customer Claims. This must be electronically submitted using the Lifeline Claims System by the eighth day of each month to receive support in that month. If the form is not received by the eighth, support will be received the following month. August 15, Reassigned-Number Database: On the 15th of every month, service providers must report permanent disconnections of their subscribers’ telephone numbers to the Reassigned Numbers Database Administrator (RNDA). August 29, Copyright Statement of Account Form: for Cable Companies: This form, plus royalty payment for the first half of the calendar year. The form covers the period of January 1 to June 31 and is to be mailed directly by cable TV operators to the Library of Congress’ Copyright Office.

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May 2026 TCA | Pinion Regulatory View

June 2026

Look for TCA | Pinion Consultants at the following meetings: Sun

Mon

Tues

Wed

Thu

Fri

Sat

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TCA | Pinion Management Conference (Colorado Springs, CO)

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OTA Summer Conference (Plano, TX)

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15 CFC Forum (Chula Vista, CA)

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CCK Annual Conference (Manhattan, KS)

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July 2-3 Independence Day Observance

Contact Us

Give us a call for more information about our services and products TCA | Pinion 526 Chapel Hills Dr,. #100 Colorado Springs, CO 80920 719) 266-4334 regconsultants@tcatel.com Visit us on the web at www.tcatel.com

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