On Friday, Nov. 18, 2011, the FCC issued its order implementing major reforms in the universal service and intercarrier compensation regimes that have, for decades, governed the telecommunications industry. The FCC had formally approved these reforms at a meeting held on Oct. 27, 2011. We provided an earlier advisory describing the FCC’s key actions, based on an “Executive Summary” of the Order released at the time of the vote. Today’s advisory highlights details of the FCC’s actions that were not available earlier. We encourage readers to review the earlier advisory for a summary of the FCC’s actions.

Although many decisions in the Order will be implemented over time, some (for example, new compensation rules for the exchange of VoIP traffic) are set to become effective as soon as the Order is published in the Federal Register. That process normally takes several weeks, and at times much longer. We will provide an advisory when the Order actually takes effect.

The Order contains a Further Notice of Proposed Rulemaking (Further Notice) that seeks public comment on many issues surrounding the details of how to implement some of the specific decisions made in the Order. The Further Notice also seeks comment on issues related more generally to integrating the FCC’s new approach to universal service and intercarrier compensation into the overall regulatory scheme applicable to providers of telecommunications and broadband Internet services. We note here certain issues where the FCC is seeking additional public comment. We will, however, issue an advisory in the near future discussing the Further Notice in more detail.