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                           Before the
                Federal Communications Commission
                     Washington, D.C. 20554

In the Matter of                 )    File No. EB-04-IH-0274
                                )
                                )
Carrera Communications, LP       )    NAL/Acct. No. 200532080137
                                )
                                )
Apparent Liability for           )    FRN No. 0010-7507-43
Forfeiture                       )

                  NOTICE OF APPARENT LIABILITY 
                    FOR FORFEITURE AND ORDER


Adopted: July 25, 2005                            Released:  July 
25, 2005

By the Commission:

I.  INTRODUCTION 

     1.   In this Notice of Apparent Liability for Forfeiture 
(``NAL''), we find that a telecommunications provider, operating 
since 1999 and at least indirectly benefiting from the federal 
programs supporting the telecommunications industry since that 
time, apparently failed to meet its statutory and regulatory 
obligations relating to those programs.  Despite multiple 
Commission inquiries into its compliance with our rules and the 
Communications Act of 1934, as amended (the ``Act''),1 and with 
the exception of a few isolated acts of post-investigative 
compliance, this carrier continues a pattern of egregious non-
compliance.  Based upon the facts and circumstances surrounding 
this matter we conclude that this company is apparently liable 
for a total forfeiture of $606,500.  

     2.   We specifically find that Carrera Communications, LP 
(``Carrera'') has apparently violated sections 54.711(a) and 
64.604 of the Commission's rules by failing to submit certain 
Telecommunications Reporting Worksheets (``Worksheets'') or 
predecessor forms from 1999 through the current date.2  Further, 
we find that Carrera has apparently violated section 254(d) of 
the Act and sections 54.706(a) and 64.604(c)(5)(iii)(A) of the 
Commission's rules by willfully and repeatedly failing to 
contribute to the Universal Service Fund (``USF'') and 
Telecommunications Relay Service (``TRS'') Fund.3  We also find 
that Carrera has apparently violated sections 1.1154 and 
1.1157(b)(1) of the Commission's rules by failing to pay 
regulatory fees to the Commission.4  Finally, we find that 
Carrera apparently violated Commission orders by willfully and 
repeatedly failing to respond to Commission directives to provide 
certain information.  

     3.   We order Carrera to submit within thirty days, either 
as part of its response to this NAL or separately, a report, 
supported by a sworn statement or declaration under penalty of 
perjury of a corporate officer, setting forth in detail its plan 
to come into compliance with the relevant payment and reporting 
rules discussed herein.  We further order Carrera to file with 
the Universal Service Administrative Company (``USAC'') within 
thirty days all annual Telecommunications Reporting Worksheets 
and amended Worksheets required under the Commission's rules from 
the date that Carrera commenced providing telecommunications 
services in the United States to the date of this NAL.5 

II.  BACKGROUND

     4.   The Commission is charged by Congress with regulating 
interstate and international telecommunications and ensuring that 
providers of such telecommunications comply with the requirements 
imposed on them by the Act and our rules.6  The Commission also 
has been charged by Congress to establish, administer and 
maintain various telecommunications regulatory programs, which 
are described in more detail below, and to fund these programs 
through assessments on the telecommunications providers that 
benefit from them.  To accomplish these goals, the Commission 
established ``a central repository of key facts about carriers'' 
through which it could monitor the entry and operation of 
interstate telecommunications providers to ensure, among other 
things, that they are qualified, do not engage in fraud, and do 
not evade oversight.7  Commission rules require that, upon entry 
or anticipated entry into interstate telecommunications markets, 
telecommunications carriers register by submitting information on 
an FCC Form 499-A, also known as the annual Telecommunications 
Reporting Worksheet.8  The Commission also requires 
telecommunications providers to submit financial information on 
annual and, with some exceptions not applicable to Carrera, 
quarterly short-form Worksheets to enable the Commission to 
determine and collect the statutorily mandated program 
assessments.9

     5.   The Telecommunications Act of 1996 codified Congress' 
historical commitment to promote universal service to ensure that 
consumers in all regions of the nation have access to affordable, 
quality telecommunications services.10  In particular, section 
254(d) of the Act requires, among other things, that ``[e]very 
telecommunications carrier [providing] interstate 
telecommunications services . . . contribute, on an equitable and 
nondiscriminatory basis, to the specific, predictable, and 
sufficient mechanisms established by the Commission to preserve 
and advance universal service.''11  In implementing this 
Congressional mandate, the Commission directed all 
telecommunications carriers providing interstate 
telecommunications services and certain other providers of 
interstate telecommunications to contribute to the Universal 
Service Fund based upon their interstate and international end-
user telecommunications revenues.12  

     6.   Section 225(b)(1) of the Act, which codifies Title IV 
of the Americans with Disabilities Act of 1990, directs the 
Commission to ``ensure that interstate and intrastate 
telecommunications relay services are available, to the extent 
possible and in the most efficient manner, to hearing-impaired 
and speech-impaired individuals in the United States.''13  To 
that end, the Commission established the TRS Fund to reimburse 
TRS providers for the costs of providing interstate 
telecommunications relay services.14  Pursuant to section 
64.604(c)(5)(iii)(A) of the Commission's rules, every carrier 
that provides interstate telecommunications services must 
contribute to the TRS Fund based upon its interstate end-user 
revenues.15

     7.   Finally, pursuant to section 9(a)(1) of the Act and 
section 1.1151 of the Commission's rules, interstate 
telecommunications carriers and other providers must pay 
regulatory fees to the Commission to cover the costs of certain 
regulatory activities.16  In particular, sections 1.1154 and 
1.1157(b)(1) of the Commission's rules require that interstate 
telecommunications carriers pay regulatory fees on the basis of 
their interstate and international end-user revenues.17  Such 
fees must be paid on an annual basis,18 and failure to do so 
subjects a carrier to late payment penalties, as well as possible 
revocation of its operating authority.19  Further, under the 
Commission's ``red light rule,'' action will be withheld on any 
application to the Commission or request for authorization made 
by any entity that has failed to pay when due its regulatory fees 
or any other program payment, such as USF contributions, and if 
payment or payment arrangements are not made within 30 days from 
notice to the applicant, such applications or requests will be 
dismissed.20

     8.   The Commission has established specific procedures to 
administer the programs for universal service, telecommunications 
relay services, numbering administration and regulatory fees.  A 
carrier must file Worksheets for the purpose of determining its 
USF, TRS, and regulatory fee program payments.21  These periodic 
filings trigger a determination of liability, if any, and 
subsequent billing and collection by the entities that administer 
the regulatory programs.  For example, USAC uses the revenue 
projections submitted on the quarterly filings to determine each 
carrier's universal service contribution amount.22  Carriers are 
required to pay their monthly USF contribution by the date shown 
on their invoice.23  The Commission's rules explicitly warn 
contributors that failure to file their forms or submit their 
payments potentially subjects them to enforcement action.24  The 
TRS Administrator and the Commission use the prior year's revenue 
information provided on the annual Worksheet to determine amounts 
owed for the TRS and regulatory fee programs, respectively.25

     9.   Carrera is a Texas-based telecommunications carrier 
that has been providing telecommunications services as a 
competitive local exchange carrier and interexchange carrier 
since 1999.26  In 2004, the Enforcement Bureau (``Bureau'') audit 
staff sought to identify resellers of telecommunications services 
that failed to register as telecommunications service providers 
with the Commission, and, thus, may also have failed to satisfy 
various Commission program requirements.27  To identify such 
resellers, the Bureau audit staff compared lists of resellers 
provided by wholesale service providers against the Commission's 
central repository of registered telecommunications service 
providers with filer identification numbers.  If a reseller did 
not appear to have an identification number, the audit staff sent 
an inquiry to that reseller.  On March 30, 2004, the Bureau's 
audit staff sent a letter to Carrera requesting information 
pertaining to Carrera's compliance with section 64.1195 of the 
Commission's rules.28  Thereafter, Carrera registered and 
belatedly filed on May 5, 2004, certain revenue information that 
had been due April 1, 2004.  Carrera then responded to the 
Bureau's audit staff that it had registered and filed.29  

     10.  After determining that Carrera appeared to have failed 
to timely register with the Commission or timely file required 
Telecommunications Reporting Worksheets, the Bureau issued a 
letter of inquiry (``LOI'') to Carrera on July 29, 2004.30  The 
LOI directed Carrera, among other things, to submit a sworn 
written response to a series of questions relating to Carrera's 
apparent failure to register and file Telecommunications 
Reporting Worksheets and to make mandated federal 
telecommunications regulatory program payments.  Carrera did not 
respond as required on August 18, 2004.  After Bureau staff 
telephoned Carrera in late August regarding its failure to 
respond, Carrera requested additional time to respond to the LOI 
and the Bureau granted Carrera the extension.  Carrera provided 
an incomplete response on September 13, 2004.31  The Bureau 
issued two additional letters to Carrera, on November 5, 2004 and 
on January 21, 2005, directing it to provide complete responses 
to the original LOI and warning that ``[f]ailure to respond fully 
to the Bureau's LOI can by itself subject Carrera to potential 
enforcement action.''32  Carrera failed to respond to the 
November 2004 and January 2005 LOIs in any manner.  Carrera also 
failed to respond to telephone and voicemail messages left by 
Bureau staff regarding Carrera's continuing failure to respond.  
During this same period, Carrera continued to fail to make any 
universal service contribution and regulatory fee program 
payments, paid its TRS Fund contribution four months late and 
only after repeated collection efforts by the Administrator, 
failed to file the quarterly Telecommunications Reporting 
Worksheets due May 1, August 1, and November 1, 2004, and 
February 1 and May 1, 2005, and failed to file the annual 
Worksheet due April 1, 2005.

III.  DISCUSSION

     11.  Under section 503(b)(1)(B) of the Act, any person who 
is determined by the Commission to have willfully or repeatedly 
failed to comply with any provision of the Act or any rule, 
regulation, or order issued by the Commission shall be liable to 
the United States for a forfeiture penalty.33  To impose such a 
forfeiture penalty, the Commission must issue a notice of 
apparent liability and the person against whom the notice has 
been issued must have an opportunity to show, in writing, why no 
such forfeiture penalty should be imposed.34  The Commission will 
then issue a forfeiture if it finds by a preponderance of the 
evidence that the person has violated the Act or a Commission 
rule.35  As set forth below, we conclude under this standard that 
Carrera is apparently liable for forfeiture for its apparent 
willful and repeated violations of section 254(d) of the Act36 
and sections 54.711(a), 64.604(c)(5)(iii), 54.706(a), 1.1154, and 
1.1157(b)(1) of the Commission's rules.37

     12.  The fundamental issues in this case are whether Carrera 
apparently violated the Act and the Commission's rules by:  (1) 
willfully or repeatedly failing to file Telecommunications 
Reporting Worksheets; (2) willfully or repeatedly failing to make 
requisite contributions toward the Universal Service and TRS 
Funds; (3) willfully or repeatedly failing to pay regulatory fees 
to the Commission; and (4) willfully or repeatedly failing to 
respond to Commission communications and comply with the 
associated orders.  We answer these questions affirmatively.  
Based on a preponderance of the evidence, we conclude that 
Carrera is apparently liable for a forfeiture of $606,500 for 
apparently willfully and repeatedly violating section 254(d) of 
the Act,38 sections 54.711(a), 64.604(c)(5)(iii), 54.706(a), 
1.1154, and 1.1157(b)(1) of the Commission's rules,39 and 
Commission orders.

     13.  Specifically, we propose the following forfeitures for 
apparent violations within the last year: (1) $250,000 for 
failure to file five Telecommunications Reporting Worksheets; (2) 
$325,000 for failure to make any monthly USF contributions; (3) 
$13,500 for making its 2004 TRS Fund contribution over four 
months after it was due on July 26, 2004; (4) $10,000 for failure 
to make its 2004 regulatory fee program payment; and (5) $8,000 
for failure to respond to Commission directives.  Although we 
propose forfeitures only for apparent violations within the last 
year, we discuss below the history of Carrera's noncompliance in 
prior years as useful background and to demonstrate the scope of 
Carrera's misconduct and the context of the misconduct that is 
within the statute of limitations period and thus covered by this 
NAL.

     A.        Submission of Telecommunications Reporting 
       Worksheets 

     14.  We conclude that Carrera apparently has violated 
sections 54.711(a) and 64.604(c)(5)(iii)(B) of the Commission's 
rules by willfully and repeatedly failing to file annual and 
quarterly Telecommunications Reporting Worksheets and predecessor 
forms since it began providing telecommunications services in 
1999 through the current date.40  Since 1999, Carrera has filed 
only one Telecommunications Reporting Worksheet, the 2004 annual 
form it filed late after receiving the March 30 Audit Letter.41  
Within the past year alone, Carrera has failed to file the 
quarterly Worksheets due August 1 and November 1, 2004 and 
February 1 and May 1, 2005, and the annual form due April 1, 
2005.

     15.  Sections 54.711(a) and 64.604(c)(5)(iii)(B) of the 
Commission's rules each clearly establish a carrier's obligation 
to file periodic Telecommunications Reporting Worksheets.42  A 
carrier's failure to file these Worksheets as required has 
serious implications for the USF, TRS, and regulatory fee 
programs.  As discussed above, the filing of a Telecommunications 
Reporting Worksheet prompts a determination of liability for, and 
subsequent billing and collection of, regulatory fees and 
contributions by the administrators of the Universal Service and 
TRS Funds.  With regard to the federal universal service program 
in particular, the failure of a carrier such as Carrera to abide 
by its federal filing obligation has a direct and profound 
detrimental impact by removing from the base of USF contributions 
telecommunications revenues that otherwise should be included, 
thereby shifting to compliant carriers additional economic 
burdens associated with the federal universal service program.43  
Consequently, a carrier's failure to file required Worksheets 
thwarts the very purpose for which Congress enacted section 
254(d) - to ensure that every interstate carrier ``contribute, on 
an equitable and nondiscriminatory basis, to the specific, 
predictable, and sufficient mechanisms established by the 
Commission to preserve and advance universal service.''44  Viewed 
in this context, the Telecommunications Reporting Worksheet is 
not only an administrative tool, but a fundamental and critical 
component of the Commission's universal service, TRS, and 
regulatory fee programs.
  
     16.  As noted above, Carrera untimely registered and late 
filed the 2004 annual Telecommunications Reporting Worksheet 
(reporting 2003 revenue and due April 1, 2004) on May 5, 2004, 
and did so only after receiving an inquiry from the Commission.45  
Since May 5, 2004, Carrera has not filed any required Worksheet, 
including the 2005 annual Worksheet due April 1, 2005.  Thus, 
Carrera still has not submitted all the information it is 
obligated to provide under our rules, including the financial 
information that is needed to calculate accurately the regulatory 
program payments it failed to make from 1999 through 2002 and 
from 2004 to the present.  Based on a preponderance of the 
evidence, we find that Carrera apparently has violated section 
254 of the Act46 and sections 54.711 and 64.604 of the 
Commission's rules47 by willfully and repeatedly failing to file 
required information with the Commission on multiple occasions 
since 1999, including failure to make five filings within the 
last year, the time period covered by this NAL.  The NAL proposes 
a forfeiture for Carrera's failure to file the Worksheets due 
August 1 and November 1, 2004, and February 1, April 1, and May 
1, 2005.


     B.   Universal Service Contributions

     17.  We further conclude that Carrera apparently violated 
section 254(d) of the Act and section 54.706 of the Commission's 
rules by willfully and repeatedly failing to contribute to 
universal service support mechanisms.48  Section 54.706(c) of the 
Commission's rules unambiguously directs that ``entities 
[providing] interstate telecommunications to the public . . . for 
a fee . . . contribute to the universal service support 
programs.''49  Although Carrera has been providing interstate 
telecommunications services to end-users since 1999, Carrera has 
made no universal service contributions to date.50  During the 
relevant period, Carrera was required, pursuant to section 
54.706(b) of the Commission's rules, to contribute to universal 
service mechanisms based upon either its historical or projected 
revenues.51  We reiterate that Carrera has not yet provided the 
information necessary to calculate how much it owes for past 
universal service contribution obligations, nor has it made any 
attempt to pay these long past due obligations.52  As we 
previously have stated,

       [c]arrier nonpayment of universal service 
       contributions undermines the efficiency and 
       effectiveness of the universal service support 
       mechanisms.  Moreover, delinquent carriers may 
       obtain a competitive advantage over carriers 
       complying with the Act and our rules.  We consider 
       universal service nonpayment to be a serious threat 
       to a key goal of Congress and one of the 
       Commission's primary responsibilities.53 

Based on a preponderance of the evidence, we find that Carrera 
apparently has violated sections 254(d) of the Act and 54.706 of 
the Commission's rules by willfully and repeatedly failing to 
make any of its monthly universal service contribution payments 
for a period of years, including 12 such failures within the past 
year.  

     C.   Telecommunications Relay Service Contributions

     18.  We also find that Carrera apparently has violated 
section 64.604(c)(5)(iii)(A) of the Commission's rules by failing 
to make required contributions to the interstate TRS Fund.54  As 
an interstate telecommunications carrier, Carrera is obligated to 
contribute to the TRS Fund on the basis of its interstate and 
international end-user telecommunications revenues.55  A 
carrier's contribution to the TRS Fund is based upon its subject 
revenues for the prior calendar year and a contribution factor 
determined annually by the Commission.56  Subject carriers must 
make TRS contributions on an annual basis, with certain 
exceptions that are not applicable to Carrera.57  

     19.  Carrera's first TRS payment was made only on November 
29, 2004, over five years after it first began offering 
interstate telecommunications services, four months after its 
2004 TRS contribution became due on July 26, 2004, and eight 
months after it first received a letter of inquiry from the 
Commission regarding its compliance with the Commission's 
rules.58  We note further that Carrera has not yet provided the 
information necessary to calculate how much it owes for past TRS 
contribution obligations, nor has it made any attempt to pay 
these long past due obligations.59  Based on a preponderance of 
the evidence, we therefore find that Carrera apparently has 
violated section 64.604 of the Commission's rules by willfully 
and repeatedly failing to pay its TRS contributions when due, 
including its failure to make on a timely basis the payment due 
in July 2004.
     
     D.   Payment of Regulatory Fees

     20.  We also conclude that Carrera apparently has violated 
sections 1.1154 and 1.1157(b)(1) of the Commission's rules by 
failing to pay required regulatory fees to the Commission.60  As 
an interstate telecommunications service provider, Carrera was 
required as early as 2000 to pay regulatory fees.61  Carrera 
admits and Commission records corroborate that Carrera has not 
made any regulatory fee program payment.62  Carrera apparently 
thus has failed to make its annual regulatory fee program 
payments a total of five times.  For these reasons, we find that 
Carrera apparently has violated section 1.1157 of the 
Commission's rules by willfully and repeatedly failing to make 
its statutorily mandated regulatory fee program payments, 
including one such failure in the past year.

     E.   Failure to Respond to Commission Communications.
     
     21.  The Commission has broad authority to investigate the 
entities it regulates under, inter alia, sections 4(i), 4(j), 
218, and 403 of the Act.63  Section 4(i) authorizes the 
Commission to ``issue such orders, not inconsistent with this 
Act, as may be necessary in the execution of its functions,'' and 
section 4(j) states that ``the Commission may conduct its 
proceedings in such manner as will best conduce to the proper 
dispatch of business and to the ends of justice.''  Section 218 
of the Act authorizes the Commission to ``obtain from . . . 
carriers . . . full and complete information necessary to enable 
the Commission to perform the duties and carry out the objects 
for which it was created.''  Section 416 of the Act requires 
carriers to follow Commission orders.64

     22.  Carrera apparently willfully and repeatedly failed to 
provide certain documents and information required by the Bureau 
in order to enable the Commission to perform its enforcement 
function.  Specifically, Carrera failed to respond fully to the 
first LOI the Bureau issued and failed to respond in any manner 
to the two additional LOIs the Bureau issued.  As indicated 
above, on July 29, 2004, the Bureau directed Carrera to provide 
certain documents and information in order to enable the 
Commission to perform its enforcement function and evaluate 
allegations that Carrera had violated Commission rules.  Carrera 
did not respond to the first LOI as required on August 18, 2004, 
or request an extension of time in which to meet its obligations 
under the LOI.  Instead, only after Bureau staff telephoned 
Carrera in late August regarding its failure to respond and 
retroactively granted Carrera an extension of time in which to 
respond in full to the LOI, Carrera provided an incomplete 
response on September 13, 2004.65  The Bureau issued two 
subsequent LOIs directing Carrera to provide a complete 
response.66  Carrera failed to respond in any manner to these 
LOIs or to telephone or voicemail messages made by Bureau staff 
regarding Carrera's continuing failure to respond.  Carrera 
received the LOIs, as evidenced by return of the mail receipt to 
the Bureau and confirmation of the facsimile transmission.67  
Carrera's willful and repeated failures to respond to the 
Bureau's LOIs constitute apparent violations of Commission 
orders.68  Based on a preponderance of the evidence, we find that 
Carrera apparently has willfully and repeatedly failed to respond 
to the Bureau's LOIs. 

     F.   Proposed Forfeiture

     23.  Section 503(b)(1)(B) of the Act provides that any 
person that willfully or repeatedly fails to comply with any 
provision of the Act or any rule, regulation, or order issued by 
the Commission, shall be liable to the United States for a 
forfeiture penalty.69  For the apparent violations in this case, 
section 503(b)(2)(B) of the Act authorizes the Commission to 
assess a forfeiture of up to $120,000 for each violation or each 
day of a continuing violation, up to a statutory maximum of $1.2 
million for a single act or failure to act before September 7, 
2004, and up to $130,000 for each violation or each day of a 
continuing violation, up to a statutory maximum of $1.325 million 
for a single act or failure to act for violations occurring on or 
after September 7, 2004.70  In determining the appropriate 
forfeiture amount, we consider the factors enumerated in section 
503(b)(2)(D) of the Act, including ``the nature, circumstances, 
extent and gravity of the violation, and, with respect to the 
violator, the degree of culpability, any history of prior 
offenses, ability to pay, and such other matters as justice may 
require.''71

     24.  Under section 503(b)(6) of the Act, we may only propose 
forfeitures for apparent violations that occurred within one year 
of the date of this NAL.72  Nevertheless, section 503(b) does not 
bar us from assessing whether Carrera's conduct prior to that 
time period apparently violated the Act or our rules in 
determining the appropriate forfeiture amount for those 
violations within the statute of limitations.73  Therefore, 
although we find that Carrera apparently violated the Act and our 
rules for over five years, we propose forfeitures here only for 
violations that occurred within the last year.

     25.  In the past, we have held that a substantial forfeiture 
of $50,000 is warranted for a carrier's failure to file a 
Telecommunications Reporting Worksheet for revenue reporting 
purposes.74  We find that Carrera's willful and repeated failure 
to file periodic Telecommunications Reporting Worksheets is 
egregious.  As we noted above, a carrier's obligation to file 
these Worksheets is directly linked to, and thus has serious 
implications for, administration of the USF, TRS, and regulatory 
fee programs.  By ignoring its reporting obligations, Carrera has 
unilaterally shifted to compliant carriers and their customers 
the economic costs associated with the universal service, TRS, 
and regulatory fee programs.  Therefore, we find that Carrera is 
apparently liable for a $250,000 forfeiture for its failure to 
file five Worksheets within the last year; i.e., those due August 
1 and November 1, 2004, and February 1, April 1, and May 1 2005.

     26.  Based on the facts above, it also appears that Carrera 
has failed to make the requisite contributions into the Universal 
Service Fund for a period of over five years.  Nonpayment of 
universal service contributions is an egregious offense that 
bestows on delinquent carriers an unfair competitive advantage by 
shifting to compliant carriers the economic costs and burdens 
associated with universal service.  A carrier's failure to make 
required universal service contributions hampers realization of 
Congress' policy objective in section 254(d) of the Act to ensure 
the equitable and non-discriminatory distribution of universal 
service costs among all telecommunications providers.75  The 
Commission has established a base forfeiture amount of $20,000 
for each month in which a carrier has failed to make required 
universal service contributions.76  Consequently, we find Carrera 
apparently liable for a base forfeiture of $240,000 for its 
willful and repeated failure to make universal service 
contributions for each of the last twelve months. 

     27.  In the past, we have calculated upward adjustments to 
forfeitures for failure to make USF and TRS payments based on 
half of the company's unpaid contributions.77  In situations such 
as this one, however, where the subject company has failed to 
file timely and accurate information, we cannot determine the 
full amount owed to the funds until and unless the subject 
company provides complete and accurate information to the fund 
administrators.  Thus, our ability to calculate and assess 
accurately an upward adjustment based on a percentage of unpaid 
contribution amounts can be inhibited by the violator.  In this 
regard, Commission enforcement action can be delayed pending the 
company's full revenue disclosures, or foreclosed altogether if 
the statute of limitations expires during the period of delay.  
In such circumstances, companies that comply with our 
registration and filing requirements might be worse off than 
those, like Carrera, that appear to ignore them.  Such a result 
is not only unfair, but is bad public policy.  During the course 
of the investigation, however, we did receive certain revenue 
information which we have used to estimate the amount Carrera 
should have paid in USF contributions since it began operations 
(approximately $170,000) for purposes of calculating an upward 
adjustment of about half that amount.  Therefore, we propose an 
upward adjustment of $85,000 for Carrera's apparent failure to 
make universal service contributions, taking into account all of 
the factors enumerated in section 503(b)(2)(D) of the Act.  We 
thus find Carrera liable for a total proposed forfeiture of 
$325,000 for its apparent willful and repeated failure to make 
contributions into the Universal Service Fund.

     28.  We also find that Carrera apparently has failed to make 
any TRS contributions from 2000 until November 29, 2004.  The 
November 2004 contribution was for the 2004 TRS obligation billed 
by the TRS administrator and due on July 26, 2004, and Carrera 
made this payment only after it received multiple Bureau 
inquiries into its compliance with the related rules.78  Where a 
carrier fails to satisfy its TRS obligations for an extended 
period of time, it thwarts the purpose for which Congress 
established section 225(b)(1) of the Act and its implementing 
regulations -- to ensure that telecommunications relay services 
``are available to the extent possible and in the most efficient 
manner, to hearing-impaired and speech-impaired individuals in 
the United States.''79  

     29.  The Commission has established a base forfeiture amount 
of $10,000 for each instance in which a carrier fails to make 
required TRS contributions.80  In light of Carrera's failure to 
pay timely its TRS obligation for the 2004-2005 funding period, 
we find it apparently liable for a base forfeiture in the amount 
of $10,000.  For the reasons discussed above regarding Carrera's 
failure to make universal service contributions and generally 
consistent with Commission precedent,81 we find that an upward 
adjustment in an amount approximately one half of the carrier's 
estimated unpaid TRS contributions (approximately $7,000) is 
appropriate for Carrera's apparent failure to make TRS 
contributions.  Taking into account the factors enumerated in 
section 503(b)(2)(D) of the Act, we conclude that a $3,500 upward 
adjustment is reasonable.  Consequently, we find Carrera liable 
for a total proposed forfeiture of $13,500 for its willful and 
repeated failure to satisfy its TRS obligations for the 2004-2005 
funding period.

     30.  We also conclude that Carrera has apparently failed to 
make any regulatory fee payments to the Commission since it 
became obligated to do so in 2000 through the current date, 
including the 2004 regulatory fee payment due August 19, 2004.82  
A carrier's failure to contribute toward the costs of certain 
regulatory activities from which it benefits undermines the 
efficiency, equitability, and effectiveness of the regulatory fee 
program and accomplishment of Congress' objectives in section 
9(a)(1) of the Act.  The Commission has not established a base 
forfeiture amount for failure to pay regulatory fees.  Regulatory 
fee obligations, however, are similar to TRS contributions in 
that they are due annually and are assessed at similar rates.83  
For this reason, we find that a base forfeiture in the amount of 
$10,000 for failure to make required regulatory fee payments is 
appropriate.  We, therefore, find Carrera apparently liable for a 
$10,000 forfeiture for its apparent violation of sections 1.1154 
and 1.1157 of the Commission's rules.

     31.  Finally, based on the facts discussed above, we also 
conclude that Carrera apparently willfully and repeatedly failed 
to respond to the Bureau's LOIs.  Specifically with respect to 
the LOI issued August 18, 2004, Carrera provided only an untimely 
and partial response and with respect to the LOIs issued November 
5, 2004 and January 21, 2005, Carrera never responded in any 
manner, despite repeated attempts by Bureau staff to elicit 
responses from Carrera.84  Section 1.80 of the Commission's rules 
and the Commission's Forfeiture Policy Statement establish a base 
forfeiture amount of $4,000 for failure to respond to a 
Commission communication.85 However, misconduct of this type 
warrants an upward adjustment because it exhibits a disregard for 
the Commission's authority that cannot be tolerated, and, more 
importantly, it threatens to compromise the Commission's ability 
to adequately investigate violations of its rules.86  The Bureau 
must act swiftly to investigate potential violations of the 
Communications Act or the Commission's rules in order to take 
action within the one year period specified in section 503(b)(6) 
of the Act.87  Prompt and full responses to Bureau inquiry 
letters are, accordingly, critical to the Commission's 
enforcement function.  Recently the Bureau assessed a forfeiture 
of $20,000 against a company that failed to respond to a Bureau 
LOI.88  In that case, the company, represented by counsel, 
requested several extensions of time in which to respond to the 
LOI, but then failed to provide any of the required information 
or documents.89  In Carrera's case, the company is not 
represented by counsel in this matter and did provide a portion 
of the information and documents it was ordered to produce, 
although untimely and only after Bureau efforts to obtain 
Carrera's compliance.  Taking into account the factors enumerated 
in section 503(b)(2)(D) of the Act, we conclude that an upward 
adjustment of the base forfeiture amount to $8,000 is warranted 
in this case for repeatedly and willfully failing to respond to 
Commission communications.

IV.  CONCLUSION

     32.  In light of the seriousness, duration and scope of the 
apparent violations, and to ensure that a company with 
substantial revenues such as Carrera does not consider the 
proposed forfeiture merely ``an affordable cost of doing 
business,''90 we find that a proposed forfeiture in the amount of 
$606,500 is warranted.  As discussed above, this proposed 
forfeiture amount includes:  (1) a total proposed penalty of 
$250,000 for failing to file five Telecommunications Reporting 
Worksheets within the past year; (2) a total proposed penalty of 
$325,000 for failing to make any of its monthly universal service 
contributions within the past year; (3) a proposed total penalty 
of $13,500 for failing to make its 2004 TRS program contribution 
when due; (4) a total proposed penalty of $10,000 for failing to 
make its 2004 regulatory fee program payment; and (5) a total 
proposed penalty of $8,000 for failing to respond to Commission 
communications.     

     33.  We caution that additional violations of the Act or the 
Commission's rules could subject Carrera to further enforcement 
action.  Such action could take the form of higher monetary 
forfeitures and/or possible revocation of Carrera's operating 
authority, including disqualification of Carrera's principals 
from the provision of any interstate common carrier services 
without the prior consent of the Commission.91  Further, we also 
note that Carrera is subject to the Commission's ``red light 
rule'' as a result of the non-payments detailed above and the 
Commission will not act on, and may dismiss, any application or 
request for authorization filed by Carrera in accordance with the 
Commission's rules.92  We order Carrera to submit within thirty 
days, either as part of its response to this NAL or separately, a 
report, supported by a sworn statement or declaration under 
penalty of perjury of a corporate officer, stating its plan to 
come into compliance with the relevant payment and reporting 
rules discussed herein.  We further order Carrera to file with 
USAC within thirty days all Annual Telecommunications Reporting 
Worksheets and amended Worksheets required under the Commission's 
rules from the date that Carrera commenced providing 
telecommunications services in the United States to the date of 
this NAL.  

V.  ORDERING CLAUSES

     34.  ACCORDINGLY, IT IS ORDERED THAT, pursuant to section 
503(b) of the Communications Act of 1934, as amended, 47 U.S.C. § 
503(b), and section 1.80 of the Commission's rules, 47 C.F.R. § 
1.80, that Carrera is hereby NOTIFIED of its APPARENT LIABILITY 
FOR A FORFEITURE in the amount of $606,500 for willfully and 
repeatedly violating the Act and the Commission's rules.

     35.  IT IS FURTHER ORDERED THAT, pursuant to section 1.80 of 
the Commission's Rules, 47 C.F.R. § 1.80, within thirty days of 
the release date of this NOTICE OF APPARENT LIABILITY, Carrera 
SHALL PAY the full amount of the proposed forfeiture or SHALL 
FILE a written statement seeking reduction or cancellation of the 
proposed forfeiture.

     36.  IT IS FURTHER ORDERED THAT, pursuant to sections 4(i), 
9(a)(1), 219(b), 254(d), and 225(b)(1) of the Act, 47 U.S.C. §§ 
4(i), 159(a)(1), 219(b), 254(d), and 225(b)(1) and sections 
54.706(a), 64.604(c)(5)(iii), 54.711(a), 1.1154, and 1.1157(b)(1) 
of the Commission's rules, 47 C.F.R. §§ 54.706(a), 
64.604(c)(5)(iii), 54.711(a), 1.1154, and 1.1157(b)(1), within 
thirty days of the release of this NOTICE OF APPARENT LIABILITY 
AND ORDER, Carrera SHALL SUBMIT a report, supported by a sworn 
statement or declaration under penalty of perjury by a corporate 
officer, stating its plan promptly to come into compliance with 
the payment and reporting rules discussed herein.  Carrera also 
SHALL SUBMIT to USAC within thirty days all Annual 
Telecommunications Reporting Worksheets and amended Worksheets 
required under the Commission's rules from the date that Carrera 
commenced providing telecommunications services to the date of 
this NAL.

     37.  Payment of the forfeiture must be made by check or 
similar instrument, payable to the order of the Federal 
Communications Commission.  The payment must include the 
NAL/Acct. No. and FRN No. referenced above.  Payment by check or 
money order may be mailed to Federal Communications Commission, 
P.O. Box 358340, Pittsburgh, PA 15251-8340.  Payment by overnight 
mail may be sent to Mellon Bank /LB 358340, 500 Ross Street, Room 
1540670, Pittsburgh, PA 15251.   Payment by wire transfer may be 
made to ABA Number 043000261, receiving bank Mellon Bank, and 
account number 911-6106.  

     38.  The response, if any, to this NOTICE OF APPARENT 
LIABILITY must be mailed to William H. Davenport, Chief, 
Investigations and Hearings Division, Enforcement Bureau, Federal 
Communications Commission, 445 12th Street, S.W., Washington, 
D.C.  20554 and must include the NAL/Acct. No. referenced above.

     39.  The Commission will not consider reducing or canceling 
a forfeiture in response to a claim of inability to pay unless 
the petitioner submits:  (1) federal tax returns for the most 
recent three-year period; (2) financial statements prepared 
according to generally accepted accounting practices (GAAP); or 
(3) some other reliable and objective documentation that 
accurately reflects the petitioner's current financial status.  
Any claim of inability to pay must specifically identify the 
basis for the claim by reference to the financial documentation 
submitted.

     40.  Requests for payment of the full amount of this NAL 
under an installment plan should be sent to Chief, Credit and 
Management Center, 445 12th Street, S.W., Washington, D.C.  
20554.93

     41.  IT IS FURTHER ORDERED that a copy of this NOTICE OF 
APPARENT LIABILITY AND ORDER shall be sent by certified mail, 
return receipt requested, to Ms. Joann P. Bennett, General 
Partner, Carrera Communications, LP, P.O. Box 90417, San Antonio, 
TX , 78209.



                         FEDERAL COMMUNICATIONS COMMISSION

                          


                         Marlene H. Dortch
                         Secretary 
_________________________

147 U.S.C. § 254(d).  
247 C.F.R. §§ 54.711(a), 64.604.
347 C.F.R. §§ 54.706(a), 64.604(c)(5)(iii)(A).
447 C.F.R. §§ 1.1154, 1.1157(b)(1).
5The Commission has appointed USAC as the administrator of 
federal universal service support mechanisms and has made it 
responsible for billing and collection of USF contributions.  47 
C.F.R. §§ 54.701(a), 54.702(b).
6See, e.g., 47 U.S.C. § 151.
7See Implementation of the Subscriber Carrier Selection 
Provisions of the Telecommunications Act of 1996, Third Report 
and Order and Second Order on Reconsideration, 15 FCC Rcd 15996, 
16024 (2000) (``Carrier Selection Order'').  Existing carriers 
such as Carrera were required to register on or before April 2, 
2001.  Id. at 15996, 16025 (requiring existing carriers to 
register on the date the new registration requirement becomes 
effective); 66 Fed. Reg. 17083 (Mar. 29, 2001) (announcing that 
the OMB approved information collection requirement in 4 C.F.R. § 
64.1195 would take effect on April 2, 2001).  
847 C.F.R. § 64.1195.
9See 47 U.S.C. §§ 159(a),(b); 225(d)(3); 251(e)(2); 254(d).  In 
1999, to streamline the administration of the programs and to 
ease the burden on regulatees, the Commission consolidated the 
information filing requirements for multiple telecommunications 
regulatory programs into the annual Telecommunications Reporting 
Worksheet.  See 1998 Biennial Regulatory Review, Report and 
Order, 14 FCC Rcd 16602 (1999).  The next year the Commission 
revised the Telecommunications Reporting Worksheet slightly to 
collect the additional information necessary to achieve its goal 
of establishing a central repository for interstate 
telecommunications providers by the least provider-burdensome 
method.  Carrier Selection Order, 15 FCC Rcd at 16026.  
10The Telecommunications Act of 1996 amended the Communications 
Act of 1934.  See Telecommunications Act of 1996, Pub. L. No. 
104-104, 110 Stat. 56 (1996).
1147 U.S.C. § 254(d).  
1247 C.F.R. § 54.706(b).  Beginning April 1, 2003, carrier 
contributions were based on a carrier's projected, rather than 
historical, revenues.  Id.
1347 U.S.C. § 225(b)(1).
14See Telecommunications Relay Services and the Americans with 
Disabilities Act of 1990, Third Report and Order, 8 FCC Rcd 5300, 
5301, ¶ 7 (1993).  Telecommunications relay services enable 
persons with hearing and speech disabilities to communicate by 
telephone with persons who may or may not have such disabilities.  
Such services provide telephone access to a significant number of 
Americans who, without it, might not be able to make or receive 
calls from others.  See Telecommunications Relay Services and 
Speech-to-Speech Services for Individuals with Hearing and Speech 
Disabilities, Report and Order, 15 FCC Rcd 5140, 5143, ¶ 5 
(2000).  NECA currently is responsible for administering the TRS 
Fund.
1547 C.F.R. § 64.604(c)(5)(iii)(A).  
16Section 9(a)(1) of the Act directs the Commission to ``assess 
and collect regulatory fees to recover the costs of the following 
regulatory activities of the Commission:  enforcement activities, 
policy and rulemaking activities, user information services, and 
international activities.''  47 U.S.C. § 159(a)(1); see also 47 
C.F.R. § 1.1151.
17See 47 C.F.R. §§ 1.1154, 1.1157(b)(1).
1847 C.F.R. § 1.1157(b)(1).  Section 1.1154 of the Commission's 
rules sets forth the schedule of annual regulatory charges and 
filing locations for common carrier services.  See 47 C.F.R. § 
1.1154.
19See 47 U.S.C. §§ 159(c)(1), (c)(3).
2047 C.F.R. § 1.1910.  The rule went into effect on November 1, 
2004.  See ``FCC Announces Brief Delay in Enforcement of Red 
Light Rule,'' Public Notice, 19 FCC Rcd 19452 (2004).
21Upon submission of a Form 499-A registration, the carrier is 
issued a filer identification number by USAC.  The filer 
identification number is then to be included on all further 
filings by the company and is used by the Commission and its 
administrators to track the carrier's contributions and invoices.
22Individual universal service contribution amounts that are 
based upon quarterly filings are subject to an annual true-up.  
See Federal-State Joint Board on Universal Service, Petition for 
Reconsideration filed by AT&T, Report and Order and Order on 
Reconsideration, 16 FCC Rcd 5748 (2001); 47 C.F.R. § 54.709(a).  
23 See Globcom, Inc. Notice of Apparent Liability for Forfeiture 
and Order, 18 FCC Rcd 19893, 19896 (2003) (``Globcom''); 47 
C.F.R. § 54.711(a) (``The Commission shall announce by Public 
Notice published in the Federal Register and on its website the 
manner of payment and the dates by which payments must be 
made.'').  See, e.g., ``Proposed Third Quarter 2003 Contribution 
Factor,'' Public Notice, 18 FCC Rcd 11442 (WCB 2003) 
(``Contribution payments are due on the date shown on the [USAC] 
invoice.'')  The Act and our rules, however, do not condition 
payment on receipt of an invoice or other notice from USAC.  See 
47 U.S.C. § 254(d); 47 C.F.R. § 54.706(b).  A carrier that does 
not file may fail to receive an invoice from USAC, but is 
nonetheless required to contribute to the universal service fund, 
unless its revenues are considered de minimus.  See Globcom, 18 
FCC Rcd at 19896, n. 22.  The instructions for the 
Telecommunications Reporting Worksheet include tables for 
carriers to determine their annual contributions.  Carrera does 
not qualify for the de minimus exception.
2447 C.F.R. § 54.713.
25See 47 C.F.R. § 64.604(c); Assessment and Collection of 
Regulatory Fees for Fiscal Year 2004, Report and Order, 19 FCC 
Rcd 11662, 11675, 11717 (2004).  
26See www.callcarrera.com.
27See 47 C.F.R. § 64.1195(a).
28See letter from Hugh Boyle, Chief Auditor, Investigations and 
Hearings Division, Enforcement Bureau, to Carrera dated March 30, 
2004 (``March 30 Audit Letter'').  
29See electronic mail response to the March 30 Audit Letter from 
Carrera dated May 7, 2004.
30Letter from Hillary S. DeNigro, Deputy Chief, Investigations 
and Hearings Division, Enforcement Bureau, to Joann P. Bennett, 
Carrera, dated July 29, 2004.  
31Letter from Joann P. Bennett, General Partner, Carrera, to 
Hillary S. DeNigro, Deputy Chief, Investigations and Hearings 
Division, Enforcement Bureau, dated September 10, 2004, with 
facsimile transmission date of September 13, 2004 (``Carrera 
Response'').  Carrera did not respond fully to LOI Inquiry 
Numbers 8, 9, 10, and 12 regarding various regulatory program 
payments.  In addition, the affidavit Carrera supplied to support 
its response did not contain a statement that it was made under 
penalty of perjury, as specifically required in the LOI, and thus 
failed to conform to Commission Rule 1.16, 47 C.F.R. § 1.16.  
Moreover, in response to LOI Inquiry Number 5, Carrera did not 
provide a specific response setting forth the required revenue 
information.
32Letters from Hillary S. DeNigro, Deputy Chief, Investigations 
and Hearings Division, Enforcement Bureau, to Joann P. Bennett, 
Carrera, dated November 5, 2004 and January 21, 2005.  Carrera's 
receipt of the letters was confirmed by return of the mail 
receipts to the Bureau and confirmations of the facsimile 
transmissions.
3347 U.S.C. § 503(b)(1)(B); 47 C.F.R. § 1.80(a)(1).  Section 
312(f)(1) of the Act defines willful as ``the conscious and 
deliberate commission or omission of [any] act, irrespective of 
any intent to violate'' the law.  47 U.S.C. § 312(f)(1). The 
legislative history to section 312(f)(1) of the Act clarifies 
that this definition of willful applies to both sections 312 and 
503(b) of the Act, H.R. Rep. No. 97-765, 97th Cong. 2d Sess. 51 
(1982), and the Commission has so interpreted the term in the 
section 503(b) context.  See, e.g., Application for Review of 
Southern California Broadcasting Co., Memorandum Opinion and 
Order, 6 FCC Rcd 4387, 4388 (1991) (``Southern California 
Broadcasting Co.'').  The Commission may also assess a forfeiture 
for violations that are merely repeated, and not willful.  See, 
e.g., Callais Cablevision, Inc., Grand Isle, Louisiana, Notice of 
Apparent Liability for Monetary Forfeiture, 16 FCC Rcd 1359 
(2001) (issuing a Notice of Apparent Liability for, inter alia, a 
cable television operator's repeated signal leakage).  
``Repeated'' means that the act was committed or omitted more 
than once, or lasts more than one day.  Callais Cablevision, 
Inc., 16 FCC Rcd at 1362, ¶ 9; Southern California Broadcasting 
Co., 6 FCC Rcd at 4388, ¶ 5.
3447 U.S.C. § 503(b); 47 C.F.R. § 1.80(f).
35See, e.g., SBC Communications, Inc., Forfeiture Order, 17 FCC 
Rcd 7589, 7591, ¶ 4 (2002) (``SBC Forfeiture Order'') (forfeiture 
paid).
3647 U.S.C. § 254(d).
3747 C.F.R. §§ 54.711(a), 64.604(c)(5)(iii), 54.706(a), 1.1154, 
1.1157(b)(1).
3847 U.S.C. § 254(d).
3947 C.F.R. §§ 54.711(a), 64.604(c)(5)(iii), 54.706(a), 1.1154, 
1.1157(b)(1). 
4047 C.F.R. §§ 54.711(a), 64.604(c)(5)(iii)(B).
41In response to the relevant LOI inquiry directing Carrera to 
provide copies of all Telecommunications Reporting Worksheets it 
has filed, Carrera provided only the annual form that it late 
filed on May 5, 2004.  USAC records confirm that that it is the 
only Worksheet Carrera has filed to date.  With certain 
exceptions that do not apply to Carrera, interstate 
telecommunications carriers must file quarterly, reporting 
revenue information in February, May, August and November of each 
year, and annually, by April 1 of each year.  See Instructions 
for Completing the Worksheet for Filing Contributions to 
Telecommunications Relay Service, Universal Service, Number 
Administration and Local Number Portability Support Mechanisms, 
FCC Form 499, April 2004, at 9.
42See 47 C.F.R. §§ 54.711(a), 64.604(c)(5)(iii)(B).
43Sixty days prior to the start of each quarter, USAC is required 
to provide the Commission with a projection of the high cost, low 
income, schools and libraries, and rural health care funding 
requirements for the following quarter.  See 
www.universalservice.org/overview/filings.  Based on USAC's 
projection of the needs of the USF, and revenue projections from 
the registered carriers subject to universal service 
requirements, the Commission establishes a specific percentage of 
interstate and international end-user revenues that each subject 
telecommunications provider must contribute toward the USF.  This 
percentage is called the contribution factor.  The contribution 
factor, and, consequently, the amount owed to the USF by each 
affected telecommunications company, changes each quarter, 
depending on the needs of the USF and carrier-provided revenue 
projections.  See www.fcc.gov/wcb/universal_service/quarter.  
Thus, in cases where a carrier, such as Carrera, fails to file 
required Worksheets reporting its revenue projections in a timely 
fashion, its revenues are excluded from the contribution base 
from which universal assessments are derived, and the economic 
burden of contributing falls disproportionately on carriers that 
have satisfied their reporting obligations.   
4447 U.S.C. § 254(d).
45See March 30 Audit Letter. The Commission has repeatedly held 
that post-investigation corrective measures are not sufficient to 
avoid enforcement action.  See AT&T Wireless Services, Inc., 
Forfeiture Order, 17 FCC Rcd 21866, 21870-71 (2002); America's 
Tele-Network Corp., Order of Forfeiture, 16 FCC Rcd 22350, 22355, 
¶ 15 (2001); Coleman Enters., Inc. d/b/a/ Local Long Distance, 
Inc., Order of Forfeiture, 15 FCC Rcd 24385, 24388, ¶ 8 (2000).
4647 U.S.C. § 254.  
4747 C.F.R. §§ 1.1157, 54.711, 64.604.
4847 U.S.C. § 254(d); 47 C.F.R. § 54.706.
4947 C.F.R. § 54.706(c).  
50See Carrera Response at 3.  USAC's records show further that 
Carrera has not made any universal service support payments to 
date.
51See 47 C.F.R. § 54.706(c).  
52In response to a Commission inquiry to provide all FCC Form 499 
filings, Carrera submitted only the FCC Form 499-A filed on May 
5, 2004.  USAC's records indicate that Carrera did not and has 
not filed annual Telecommunications Reporting Worksheets for any 
years prior to 2004, has not filed any quarterly forms, and has 
not filed the annual Worksheet due April 1, 2005. 
53Globcom, 18 FCC Rcd at 19903 ¶ 26.
5447 C.F.R. § 64.604(c)(5)(iii)(A).
55Id.  Each subject carrier must contribute at least $25 per 
year.  Carriers whose annual contributions are less than $1,200 
must pay the entire amount at the beginning of the contribution 
period.  Id. 47 C.F.R. § 64.604(c)(5)(iii)(B).  Otherwise, 
carriers may divide their contributions into equal monthly 
payments.  Id.
5647 C.F.R. § 64.604(c)(5)(iii)(B).
57See 47 C.F.R. § 64.604(c)(5)(iii)(B).
58The TRS Administrator's records indicate that Carrera made its 
2004 contribution payment on November 29, 2004; see also Carrera 
Response at 3 (stating that Carrera had not made any TRS payments 
as of the date of its response, September 10, 2004.)  
59In response to a Commission inquiry to provide all FCC Form 499 
filings, Carrera submitted the FCC Form 499-A filed on May 5, 
2004.  USAC's records indicate that Carrera did not and has not 
filed annual Telecommunications Reporting Worksheets for this 
year or any years prior to 2004. 
6047 C.F.R. §§ 1.1154, 1.1157.  Payments of standard regulatory 
fees applicable to common carrier services must be filed in full 
on an annual basis.  Id. § 1.1157(b)(1).
61Regulatory fee program payments for interstate 
telecommunications providers are calculated on prior year 
revenue.  See, e.g., Assessment and Collection of Regulatory Fees 
for Fiscal Year 2004, 19 FCC Rcd at 11675.  
62See Carrera Response at 3 (stating that Carrera has not made 
payments).
6347 U.S.C. §§ 4, 218, & 403.  
6447 U.S.C. § 416.
65See supra Carrera Response, note 31.
66Letters from Hillary S. DeNigro, Deputy Chief, Investigations 
and Hearings Division, Enforcement Bureau, to Joann P. Bennett, 
Carrera, dated November 5, 2004 and January 21, 2005.
67See supra note 32.
68See, e.g., SBC Forfeiture Order, 17 FCC Rcd at 7600, ¶ 28; 
Globcom, 18 FCC Rcd at 19898, n. 36; BigZoo.com Corp., Notice of 
Apparent Liability for Forfeiture and Order, 19 FCC Rcd 24437 
(Enf. Bur. 2004) (``BigZoo.com Corp. ''), Order of Forfeiture, 20 
FCC Rcd 3954 (Enf. Bur. 2005); American Family Association, 
Licensee of Station KBMP(FM), Enterprise, Kansas, Notice of 
Apparent Liability for Forfeiture, 19 FCC Rcd 14072, Forfeiture 
Order, 19 FCC Rcd 22025 (Enf. Bur. 2004); World Communications 
Satellite Systems, Inc., Notice of Apparent Liability for 
Forfeiture, 18 FCC Rcd 18545 (Enf. Bur. 2003) (``WCSS Forfeiture 
Order''); Donald W. Kaminski, Jr., Notice of Apparent Liability 
for Forfeiture, 16 FCC Rcd 10707 (Enf. Bur. 2001), Forfeiture 
Order, 18 FCC Rcd 26065 (Enf. Bur. 2003).
6947 U.S.C. § 503(b)(1)(B); see also 47 C.F.R. § 1.80(a)(2).
7047 U.S.C. § 503(b)(2)(B); see also 47 C.F.R. § 1.80(b)(2).
7147 U.S.C. § 503(b)(2)(D); see also Commission's Forfeiture 
Policy Statement and Amendment of Section 1.80 of the Rules to 
Incorporate the Forfeiture Guidelines, Report and Order, 12 FCC 
Rcd 17087, 17100, ¶ 27 (1997) (``Forfeiture Policy Statement''); 
recon. denied 15 FCC Rcd 303 (1999); 47 C.F.R. § 1.80(b).
7247 U.S.C. § 503(b)(6)(B); 47 C.F.R. § 1.80(c)(3).  Effective 
September 7, 2004, the Commission amended its rules to increase 
the maximum penalties to account for inflation since the last 
adjustment of the penalty rates.  See Amendment of Section 1.90 
of the Commission's Rules, Order, 19 FCC Rcd 10945, 10946 ¶ 6 
(2004).
73See, e.g., Globcom, 18 FCC Rcd at 19903; Roadrunner Transp., 
Inc., Forfeiture Order, 15 FCC Rcd 9669, 9671 (2000); Liab. of E. 
Broad. Corp., Memorandum Opinion and Order, 10 F.C.C. 2d 37 
(1967).
74In the Globcom NAL, the Commission proposed a $50,000 
forfeiture for each instance within the statute of limitations 
that Globcom failed to file a required Worksheet.  Globcom, 18 
FCC Rcd at 19905.
75See 47 U.S.C. § 254(d).
76See Globcom, 18 FCC Rcd at 19903-19904, ¶¶ 25-27.
77See, e.g., id.
78Carrera made its late TRS program payment only after receiving 
two LOIs from the Commission specifically inquiring into its 
compliance with the payment requirement and multiple collection 
demands from the TRS Administrator.  Commission precedent is 
clear that subsequent remedial measures do not cure a violation 
for enforcement purposes.  See supra note 45.
7947 U.S.C. § 225(b)(1).
80See Globcom, 18 FCC Rcd at 19904, ¶ 29.
81See id.
82See ``FY 2004 Regulatory Fees Due No Later Than August 19, 
2004,'' Public Notice, (rel. Jul. 2, 2004).
83For example, the 2004 TRS Fund contribution factor was .00356 
per dollar of interstate and international end-user revenue and 
the 2004 interstate telecommunications regulatory fee assessment 
was .00218 per dollar of interstate and international end-user 
revenue.  See Telecommunications Relay Services and Speech-to-
Speech Services for Individuals with Hearing and Speech 
Disabilities, Order, 19 FCC Rcd 12224, 12225 (Con. & Gov. Aff. 
Bur. 2004); Assessment and Collection of Regulatory Fees for 
Fiscal Year 2004, 19 FCC Rcd at 11691.
84See supra ¶ 22.
8547 C.F.R. § 1.80; Forfeiture Policy Statement, 12 FCC Rcd at 
17114.
86See, e.g., WCSS Forfeiture Order, 18 FCC Rcd at 18545 
(proposing a monetary forfeiture of $10,000 against regulatee for 
submitting a jurisdictional objection rather than a substantive 
response to a Bureau LOI); SBC Forfeiture Order, 17 FCC Rcd at 
7600, ¶ 28 (issuing a monetary forfeiture of $100,000 against SBC 
for violating an order to submit a sworn statement with its 
response to a Bureau LOI).
8747 U.S.C § 503(b)(6).
88BigZoo.com Corp, Order of Forfeiture, DA 05-449, (Enf. Bur.  
Rel. Feb. 23, 2005). 
89See BigZoo.com Corp., 19 FCC Rcd at 24437-38.  
90Forfeiture Policy Statement, 12 FCC Rcd at 17099; see also 47 
C.F.R. § 1.80(b)(4).
91See Business Options, Inc., Consent Decree, 19 FCC Rcd 2916 
(2003); NOS Communications, Inc., Affinity Network Incorporated 
and NOSVA Limited Partnership, Consent Decree, 2003 WL 22439710 
(2003).
9247 C.F.R. § 1.1910.  The rule went into effect on November 1, 
2004.  See ``FCC Announces Brief Delay in Enforcement of Red 
Light Rule,'' Public Notice, 19 FCC Rcd 19452 (2004).
93See 47 C.F.R. § 1.1914.