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Rural Broadband Experiment Credit Requirement 'Onerous' if Applied to CAF II

FCC’s letter of credit requirement for recipients of rural broadband experiment funding would be “onerous” if applied to Connect America Fund (CAF) Phase II recipients, USTelecom said in comments posted Tuesday in docket 10-90. Rural broadband experiment recipients are required…

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to obtain a letter of credit (LOC) equal to the amount they’ve previously received through the 10-year program, plus the amount scheduled to be dispersed to them over the following year. The LOC must also remain open for 120 days after the program's completion, USTelecom said. For CAF Phase II, the requirement should be “tailored to the amount of money ‘at risk’ annually or at most within a one to two year range,” the filing said. An LOC could be required for the first two years, with no more than one to two years of disbursements protected by an LOC, the group said. USTelecom also agreed with CoBank’s proposal (see 1503230031) to reduce the credit amount only to cover funds to be disbursed over the following year, the filing said.