Discontinuance Application Of Working Assets Funding Service, Inc
Federal Communications Commission
News Media Information 202 / 418-0500445 12th St., S.W.
Washington, D.C. 20554
Released: December 6, 2012
COMMENTS INVITED ON APPLICATION OF WORKING ASSETS FUNDING SERVICE,
INC. D/B/A CREDO LONG DISTANCE TO DISCONTINUE DOMESTIC
WC Docket No. 12-347
Comp. Pol. File No. 1070
Comments Due: December 21, 2012
Section 214 Application
Applicant: Working Assets Funding Service, Inc. d/b/a Credo Long Distance
November 26, 2012, Working Assets Funding Service, Inc. d/b/a Credo Long Distance(Working Assets or Applicant), located at 101 Market Street, Suite 700, San Francisco, CA 94105, filed
an application with the Federal Communications Commission (FCC or Commission) requesting authority,
under section 214 of the Communications Act of 1934, as amended, 47 U.S.C. § 214, and section 63.71 of
the Commission’s rules, 47 C.F.R. § 63.71, to discontinue a certain domestic telecommunications service
in the District of Columbia and all states except Alaska (collectively Service Areas).1
Working Assets indicates that it currently offers post-paid calling card service in the Service
Areas. Working Assets explains that its post-paid calling card service allows customers to make calls
using the calling card and allows for the cost of those calls to be billed to the customer’s account.
Working Assets states that its post-paid calling card service once was extremely popular, and that it has
been provided both as an additional service to Working Assets’ long distance subscribers and as a stand-
alone service. Working Assets asserts, however, that use of the cards has significantly declined.
Consequently, Working Assets indicates that it plans to decommission the billing platform that supports
the service and discontinue its post-paid calling card service in the Service Areas on December 31, 2012,
subject to Commission authorization. According to Working Assets, there are approximately 9,000
current post-paid calling card customers. Working Assets states that affected customers’ long distance
service with Working Assets will not be impacted by the proposed discontinuance. Working Assets also
maintains that the public convenience and necessity should not be impaired by the proposed
discontinuance because affected customers will have the opportunity to switch to other providers of post-
paid calling cards, and pre-paid calling cards and mobile phones (both pre-paid and monthly plans) are
widely available at competitive rates. Working Assets indicates that it sent notices regarding the proposed
discontinuance to affected customers by first class U.S. Mail on November 21, 2012. Working Assets states
that it is considered non-dominant with respect to the service it proposes to discontinue.
1 Working Assets’ application was subsequently received in the Competition Policy Division of the Wireline
Competition Bureau on December 3, 2012.
In accordance with section 63.71(c) of the Commission’s rules, Working Assets’ application will
be deemed to be granted automatically on the 31st day after the release date of this public notice, unless
the Commission notifies Working Assets that the grant will not be automatically effective. In its
application, Working Assets indicates that it plans to discontinue its post-paid calling card service in the
Service Areas on December 31, 2012, subject to Commission authorization. Accordingly, pursuant to
section 63.71(c) and the terms of Working Assets’ application, absent further Commission action,
Working Assets may terminate its post-paid calling card service in the Service Areas on or after
January 6, 2013, in accordance with Working Assets’ filed representations. The Commission normally
will authorize proposed discontinuances of service unless it is shown that customers or other end users
would be unable to receive service or a reasonable substitute from another carrier, or that the public
convenience and necessity would be otherwise adversely affected.
Comments objecting to this application must be filed with the Commission on or before
December 21, 2012. Such comments should refer to
WC Docket No. 12-347 and Comp. Pol. File No.
on the commenter, including any inability to acquire reasonable substitute service. Comments may be
filed using the Commission’s Electronic Comment Filing System (ECFS) or by filing paper copies. See
Electronic Filing of Documents in Rulemaking Proceedings, 63 FR 24121 (1998). Comments may be
filed electronically using the Internet by accessing the ECFS: http://fjallfoss.fcc.gov/ecfs2/. Filers should
follow the instructions provided on the Web site for submitting comments. Generally, only one copy of
an electronic submission must be filed. In completing the transmittal screen, filers should include their
full name, U.S. Postal Service mailing address, and the applicable docket or rulemaking number.
Parties who choose to file by paper must file an original and one copy of each filing. Filings can
be sent by hand or messenger delivery, by commercial overnight courier, or by first-class or overnight
U.S. Postal Service mail. All filings must be addressed to the Commission’s Secretary, Office of the
Secretary, Federal Communications Commission. All hand-delivered or messenger-delivered paper
filings for the Commission’s Secretary must be delivered to FCC Headquarters at 445 12th Street, S.W.,
Room TW-A325, Washington, D.C. 20554. The filing hours are Monday through Friday, 8:00 a.m. to
7:00 p.m. All hand deliveries must be held together with rubber bands or fasteners. Any envelopes and
boxes must be disposed of before entering the building. Commercial overnight mail (other than U.S.
Postal Service Express Mail and Priority Mail) must be sent to 9300 East Hampton Drive, Capitol
Heights, MD 20743. U.S. Postal Service first-class, Express, and Priority mail must be addressed to 445
12th Street, S.W., Washington, D.C. 20554.
Two copies of the comments should also be sent to the Competition Policy Division, Wireline
Competition Bureau, Federal Communications Commission, 445 12th Street, S.W., Room 5-C140,
Washington, D.C. 20554, Attention: Carmell Weathers. In addition, comments should be served upon the
Applicant. Commenters are also requested to fax their comments to the FCC at (202) 418-1413,
Attention: Carmell Weathers.
This proceeding is considered a “permit but disclose” proceeding for purposes of the
Commission’s ex parte rules.2 Persons making ex parte presentations must file a copy of any written
presentation or a memorandum summarizing any oral presentation within two business days after the
presentation (unless a different deadline applicable to the Sunshine period applies). Persons making oral
ex parte presentations are reminded that memoranda summarizing the presentation must (1) list all
persons attending or otherwise participating in the meeting at which the ex parte presentation was made,
and (2) summarize all data presented and arguments made during the presentation. If the presentation
2 47 C.F.R. §§ 1.1200 et seq.
consisted in whole or in part of the presentation of data or arguments already reflected in the presenter’s
written comments, memoranda or other filings in the proceeding, the presenter may provide citations to
such data or arguments in his or her prior comments, memoranda, or other filings (specifying the relevant
page and/or paragraph numbers where such data or arguments can be found) in lieu of summarizing them
in the memorandum. Documents shown or given to Commission staff during ex parte meetings are
deemed to be written ex parte presentations and must be filed consistent with rule 1.1206(b). In
proceedings governed by rule 1.49(f) or for which the Commission has made available a method of
electronic filing, written ex parte presentations and memoranda summarizing oral ex parte presentations,
and all attachments thereto, must be filed through the electronic comment filing system available for that
proceeding, and must be filed in their native format (e.g., .doc, .xml, .ppt, searchable .pdf). Participants in
this proceeding should familiarize themselves with the Commission’s ex parte rules.
People with Disabilities: To request materials in accessible formats for people with disabilities
(Braille, large print, electronic files, audio format), send an e-mail to email@example.com or call the
Consumer & Governmental Affairs Bureau at (202) 418-0530 (voice), (202) 418-0432 (tty).
For further information, contact Carmell Weathers, (202) 418-2325 (voice),
firstname.lastname@example.org, or Rodney McDonald, (202) 418-7513 (voice), email@example.com, of
the Competition Policy Division, Wireline Competition Bureau. The tty number is (202) 418-0484. For
further information on procedures regarding section 214 please visit
– FCC –
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