- Revenue information;
- Actual and expected categories of customers (e.g., enterprise, residential, carrier), including any federal, state, and local governmental customers;
- Individuals and entities with ownership interests and the level of each's involvement in the company;
- Members of management;
- Other foreign persons with access to infrastructure or customer records;
- Location of current and anticipated customer and business records; and
- Anticipated access to public switched telephone networks or the internet.[1]
Depending on the nature of the responses, Team Telecom occasionally required the applicant to clarify or expand on the information provided.[2] This engagement of the applicant was done solely by Team Telecom; no FCC personnel were involved.[3] Throughout this process, Team Telecom was constantly assessing whether its concerns could be mitigated through a written security agreement―commonly referred to as a network security agreement or a letter of assurance.[4]
Team Telecom ultimately made one of three recommendations to the FCC:
- It had no concerns and therefore no objection to the application;
- Concerns existed but could be mitigated through a security agreement, so Team Telecom did not object to the FCC approving the application subject to the carrier agreeing to comply with the conditions and obligations contained in the security agreement; or
- ↑ See, e.g., TT-DOJ-001-15; TT-DOJ-045-60; FCC Proposed Executive Branch Review Reform, supra note 154, at ¶7 (citing to a letter explaining that "the reviewing agencies' current practice is to send an applicant a set of initial questions").
- ↑ Briefing with the Dep't of Justice (Aug. 1, 2019); FCC Proposed Executive Branch Review Reform, supra note 154, at ¶7. See also TT-DOJ-106–08; TT-DOJ-061–63; TT-DOJ-067–101 (China Telecom Americas responding to Team Telecom's clarification questions about its Section 214 application).
- ↑ FCC Proposed Executive Branch Review Reform, supra note 154, at ¶7.
- ↑ FCC Proposed Executive Branch Review Reform, supra note 154, at ¶7; Briefing with the Dep't of Justice (Aug. 1, 2019). According to DOJ, there is no substantive difference between a network security agreement and a letter of assurance. See Briefing with the Dep't of Justice (Aug. 1, 2019). Thus, for ease of reference, the Subcommittee uses security agreement throughout.
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