CallTrackingMetrics’ Post

A good read, three points that stood out for me: 1. "The industry’s position seems to be that allowing in-country consolidation of telecoms assets is a precursor to cross-border consolidation and pan-European ownership. This is doubtful." 2. "We all know that technological forces are pulling the industry towards vertical disaggregation rather than horizontal aggregation. The White Paper recognises this but positions it mainly as a threat to vertically integrated European telecoms operators... I think the Commission should instead accept and anticipate that today’s vertically integrated telecom operators will see further disaggregation or unbundling of their functions." 3. "The Digital Markets Act has now introduced various regulatory measures which are intended to open up third party access to software and hardware in digital devices. I think we may require something similar with respect to virtualised local telecoms networks."

Thanks for sharing this insightful note. Key take-aways for me: 1) Cross-border consolidation is a red herring - economies of scale in telecoms are largely local. 2) "...the Commission should accept and anticipate that today’s vertically integrated telecom operators will see further disaggregation or unbundling of their functions. It then needs to consider how regulation should evolve to ensure that Europe will benefit from this to the greatest extent possible." However, while I can see that the regulatory toolbox may need upgrading to catch up with the softwarisation of networks, I am puzzled by the broad sweep of examples which include many telecoms markets where there have been no findings of persistent market power (i.e. mobile) and also many fixed markets - especially as Richard's paper earlier this year set this out so compellingly (sharing again: https://lnkd.in/dT3S7Dc7).

𝗙𝗲𝗱𝗲𝗿𝗮𝗹 𝗖𝗼𝗺𝗺𝘂𝗻𝗶𝗰𝗮𝘁𝗶𝗼𝗻𝘀 𝗖𝗼𝗺𝗺𝗶𝘀𝘀𝗶𝗼𝗻 (𝗙𝗖𝗖) 𝗙𝗬 𝟮𝟬𝟮𝟰 𝗥𝗲𝗴𝘂𝗹𝗮𝘁𝗼𝗿𝘆 𝗙𝗲𝗲𝘀 𝗗𝘂𝗲 𝗦𝗲𝗽𝘁𝗲𝗺𝗯𝗲𝗿 𝟮𝟲, 𝟮𝟬𝟮𝟰 The Federal Communications Commission recently announced that annual regulatory fees for FY 2024 are due by September 26, 2024. These fees are crucial for supporting the FCC’s enforcement, public service, policy, and rulemaking efforts. The fee schedule applies to a variety of federal licensees and regulated entities, including telecommunications providers, spectrum licensees, and satellite operators. Some key highlights: • Telecom Provider Fees: Fees remain steady at 0.005420 per revenue dollar • International Bearer Circuits Fees: Reduced by 37.8% • No New Regulatory Fees for Unlicensed Radiofrequency Device Manufacturers • Ensure timely payment to avoid late penalties (25%) and meet all electronic payment requirements via the FCC’s CORES system 💡 For any questions about navigating the FCC fee payment process, feel free to reach out to Chip Yorkgitis or Winafred Brantl. See the comments for the full article. #FCC #Telecom #CommunicationsLaw #RegulatoryCompliance #KelleyDrye

𝐂𝐥𝐞𝐚𝐫𝐢𝐧𝐠 𝐭𝐡𝐞 𝐄𝐢𝐫 A pretty punchy article from Kjeld Hartog of Eir in todays Business Post underlines the fractured nature of the relationship between the French-owned incumbent and ComReg, the state regulator. It is worth noting that Kjeld was poached from ComReg in 2016 - something of a coup for eir Ireland at the time and the published rates of return on investment on regulated products since then suggests it was a shrewd appointment. Here he advocates strongly for Eir (𝘯𝘢𝘵𝘶𝘳𝘢𝘭𝘭𝘺, 𝘐'𝘷𝘦 𝘥𝘰𝘯𝘦 𝘖𝘱𝘌𝘥𝘴 𝘭𝘪𝘬𝘦 𝘵𝘩𝘪𝘴 𝘮𝘺𝘴𝘦𝘭𝘧) as being hard done by but some context around a number of the criticism is worthwhile. Firstly, Eir has long been one of the most (and possibly 𝒆𝒗𝒆𝒏 𝒎𝒐𝒔𝒕) profitable fixed line incumbents in the world (a𝘧𝘵𝘦𝘳 𝘦𝘹𝘵𝘦𝘯𝘴𝘪𝘷𝘦 𝘴𝘦𝘢𝘳𝘤𝘩𝘦𝘴 𝘐 𝘤𝘢𝘯𝘯𝘰𝘵 𝘧𝘪𝘯𝘥 𝘰𝘯𝘦 𝘮𝘰𝘳𝘦 𝘱𝘳𝘰𝘧𝘪𝘵𝘢𝘣𝘭𝘦 𝘣𝘶𝘵 𝘢𝘮 𝘩𝘢𝘱𝘱𝘺 𝘵𝘰 𝘣𝘦 𝘤𝘰𝘳𝘳𝘦𝘤𝘵𝘦𝘥 𝘰𝘯 𝘵𝘩𝘦 𝘴𝘢𝘮𝘦?). It boasts fixed line EBITDA margins typically in the high 40s-low 50s percents. Usually when incumbents are upset with regulators its because they are making insufficient returns on investment due to regulatory restrictions - that charge simply doesn't apply here. The suggestion that ComReg has '𝘣𝘭𝘰𝘵𝘵𝘦𝘥 𝘪𝘵𝘴 𝘤𝘰𝘱𝘺𝘣𝘰𝘰𝘬 𝘸𝘪𝘵𝘩 𝘌𝘶𝘳𝘰𝘱𝘦' is an accurate and fair assessment even they would not deny. However, if anything this has either not effected or benefitted rather than hindered Eir in recent years e.g. pole and duct pricing was due to fall significantly in early 2022 but because the EC were of the view that ComReg went about their task in the wrong way, well above cost pricing was maintained in the market for a further (at least) 2 years adding millions to the Eir coffers and effectivley paid for by the Irish taxpayer through the #NBP. The article also correctly notes that in 2017 the EC threatened legal action on the Irish state for ComReg's delay in conducting a key market review. What it doesn't say is that it was 𝐄𝐢𝐫'𝐬 𝐜𝐨𝐦𝐩𝐞𝐭𝐢𝐭𝐨𝐫𝐬 rather than Eir that were most vocal and unhappy about this (I appeared before an Oireachtas Committe myself raising concerns on this matter in 2018). Consequently, I would strongly suggest the main beneficiary from the delay, from a balance sheet perspective, was Eir and its shareholders that sold to Iliad around this time are unlikely to have regrets about it. WRT to the latest market reivew, it is clear Eir are unhappy about ComReg's proposals underpinning regulation for the next 5 years. However, barring a High Court appeal of the ultimate decisions (expected this month) the horse would appear to have bolted on these issues so the value and timing of this piece is unclear...but for those that work in regulation sometimes catharsis is its own reward. https://lnkd.in/evx3thwv

FCC hits Lingo Telecom with a $2m fine for getting their S/S attestation wrong on the Joe Biden deep fake robocalls. Lingo Telecom basically assumed because they had a contract with the company making the calls, they could attest those calls with an "A". On top of that, they weren't aware of what their customer was actually doing until regulators brought it to their attention. This highlights not only that carriers have to get attestation right, but also to monitor their customers traffic to know if they are misbehaving. In the meantime, it's an expensive mistake. https://lnkd.in/gmtwU5Ds

Ever experienced calls going straight to voicemail, or worse, being rejected without a clear reason? The evolving FCC regulations and the adoption of STIR/SHAKEN have introduced complexities. Different carriers have varied approaches, causing scenarios like calls vanishing into voicemail or being bluntly rejected. Understand the challenges in this dynamic telecom environment. #telecomchallenges #callerexperience

#TLP’s latest Weekly Wireless Wrap-Up is here! Check out the post below for your update on the telecommunications world, including the Federal Communications Commission’s February Open Meeting, its Report and Order and Further Notice of Proposed Rulemaking mandating DIRS reporting and Report and Order mandating location-based routing for 911 calls. For additional information or assistance on telecommunications matters, please contact the #TLPTeam. #law #telecommunications #wirelesscommunications #publicsafety

Slowly but surely, the final reforms to FCC rules related to Team Telecom and national security reviews of transactions that the FCC adopted in 2020 - yes, 2020! - are becoming effective.

Big news! As of August 23, 2024, the FCC's Office of International Affairs has implemented major updates to the Team Telecom review process for foreign ownership applications. Stay tuned for how these changes might impact your business! https://lnkd.in/eqcc2DQx #FCC #TeamTelecom #ForeignOwnership #RegulationUpdate

DG COMPETITION recently published a substantial report examining the state of competition in the EU. Mobile telecoms received detailed treatment, but the analysis here is deeply flawed. In this response I explain why.