International 214 Licenses
What is an International 214 License ?
And Who Needs One?
The Federal Communications Commission (FCC) requires any person that provides telecommunications services to or from the United States to receive an authorization under Section 214 of the Communications Act of 1934. This authorization is called an International Section 214 Authorization, or, commonly, an International 214 License. The definition of “telecommunications services” is very broad and includes private line, switched long distance, prepaid services, calling cards, VOIP services and many similar services. Whether you resell the telecommunications services of another company or provide services using your own facilities, you will need the International 214 Authorization.
Frequently Asked Questions
Attorneys at Thomas Lynch & Associates have filed hundreds of applications with the FCC for the International 214 License. As a result, we are very familiar with the FCC’s filing requirements and understand the regulations. We also know the FCC staff and the staff of the Department of Homeland Security that reviews the applications. To date, every one of our applications has been granted. That includes applications with foreign ownership. Most are granted within two to three weeks. If you review the applications that have been filed by others, including those that advertise heavily, you will find that some have taken six or more months to be processed. And others are still not granted after more than a year. Be careful when choosing someone to assist with your application. We have the experience, the contacts and the track record to get your application granted — promptly and affordably.
If the application qualifies for “streamlined processing,” and there is no objection to the application, either by individuals, entities or other branches of the government, the application will be granted after 14 days on public notice and a notice of the grant will be published by the FCC. If the application does not qualify for streamlined processing (because of certain foreign affiliations, for example), there is no time frame during which the FCC must process the application. Most applications submitted by our firm qualify for streamlined processing and are granted within 20 days after you contact us (see below for how to begin the process). Note, however, that applications with foreign ownership are being heavily scrutinized by the Department of Homeland Security because of 9/11. If your company has 10% or more foreign ownership, call Mr. Lynch at Thomas Lynch & Associates for more information.
The FCC charges a filing fee of $1,195. Thomas Lynch & Associates charges a flat fee of $550 to prepare the application and prosecute it at the FCC if you have foreign ownership less than 10%. Therefore the total is $1,745. If you have foreign ownership of 10% or more, the legal fees are $950, making the total $2,145. Our flat-rated fees are among the lowest offered for expert assistance and reflects the firm’s efficiency and experience in filing and prosecuting Section 214 applications. In addition, if you obtain your International 214 Authorization through Thomas Lynch & Associates, you will receive a comprehensive table of common regulatory requirements that includes a summary of the requirement, the code section applicable and the due date for any associated filing. The table also contains many web links to manuals and other helps in satisfying the regulatory requirements. This table was developed by our firm and is free for our 214 clients. It is worth hundreds of dollars of legal time (we sell the table individually for $550) and is an added value that is not available from others.
The regulatory requirements that apply to a telecommunications provider depend on the type of service offered. For almost all carriers, the most time consuming and expensive regulatory obligation involves the Universal Service Fund (USF) and its associated Form 499 filings (499-A and 499-Q). Other regulations include Circuit Status Reports, the Regulatory Fee filing and the International Telecommunications Traffic Report. But these obligations do not apply to all service providers. If you obtain your International 214 Authorization through Thomas Lynch & Associates, you will receive a comprehensive table of common regulatory requirements that includes a summary of the requirement, the code section applicable and the due date for any associated filing. The table also contains many web links to manuals and other helps in satisfying the regulatory requirements. This table was developed by Mr. Lynch and is free for his 214 clients. It is worth hundreds of dollars of legal time (we sell the table individually for $550) and is an added value that is not available from others. If you need assistance with making regulatory filings, we can assist you in all aspects of compliance. For more information about the most important filing, the 499A, please click here.
The short answer is probably not. The FCC does not presently regulate VOIP the way it regulates circuit-switched services, but the FCC requires VOIP providers to comply with certain regulations that apply to traditional phone service, such as E911 and law-enforcement requirements under CALEA. The FCC also decided that VOIP providers must pay into the Universal Service Fund. Although previously the FCC had taken the position that an international 214 license was not required for VOIP providers, in a 2008 decision it was determined that VOIP providers, and even wholesale VOIP providers, are providers of “telecommunications services” and are subject to many additional regulations. This may include the international 214 license requirement. Since it is a grey area, many VOIP providers do not obtain the license.
The type of service you provide will determine whether a state’s regulatory requirements apply. Generally, if you are only providing international services, or services between states, state registration is not necessary. But the regulatory requirements of each state are different and you must check to make sure, especially if you are providing prepaid or calling card services. We can assist you with state filings as well. Click here for more information.
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Overview of License
And How to Get Started
Who Needs the License? Anyone providing telecom services to or from the United States, with limited exceptions.
How Long Does It Take? Usually 20 days or less, unless there is foreign ownership of the applicant or foreign affiliations.
How Much Does it Cost? $1,195 FCC filing fee, plus $550 in legal fees if there is less than 10% foreign ownership. For more than 10% foreign ownership, the legal fees are $950. We accept payment by credit card using PayPal. Please note this fee includes the table of regulatory requirements applicable to holders of an International 214 license — a proprietary table developed by our firm and not available from others. This table is available individually for $550, but we provide it free for our 214 license clients.
How Do I Get Started? Click here to create an account. Then complete the 214 questionnaire in the online portal after you register. An attorney at Thomas Lynch & Associates will contact you after receiving your submitted questionaire. You can also contact us by phone or e-mail to begin the application process. Contact information is here.
What Our Clients Say
“I thought it would take a lot longer to get the approvals. But Tom Lynch was able to obtain our international license in only a few weeks. We’ll definitely call him again for our licensing needs.”
Lijun Niu, President
Nucom Technology, Inc.
“Tom Lynch is prompt, professional and affordable. His in-depth knowledge of domestic regulatory issues and compliance is outstanding. We now to turn to Tom for all of our licensing needs.”
Gregory Wasilewski, President
IPC Network Services, Inc.