Remember that the absence of a tariff does not mean that the carrier no longer needs to pay attention to changes in regulations that used to require a tariff change. For example, if the interest rate on deposits is changed, it is changed even if it a tariff change is not required. Also remember that common carriers still have continuing regulatory obligations, such as providing service without unreasonable discrimination.
Are there enough states that allow de-tariffing to warrant the effort of setting up safeguards, service agreements and notice procedures? Currently a long distance reseller without operator services is only required to file tariffs or post price lists in 13 states. A facilities-based CLEC serving complex business customers, only needs local tariffs or price lists in 24 states. It is a good time for carriers to take a close look at current policies to either update the rationale for maintaining tariffs and/or to develop a migration path for a post-tariff environment.
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