Notes to Table of Billing Codes: * Facilities-based services are provided using international transmission facilities owned in whole or in part by the carrier providing service. Facilities-resale services are provided by a carrier using non-switched international circuits leased from other reporting carriers. These are distinct from pure resale services, which are switched services that are provided by reselling the international switched services of other carriers. ** Traditional settlement arrangements consist of traffic settled pursuant to the Commission's International Settlement's Policy (ISP). See 47 C.F.R. §§ 43.51(e), 64.1001, 64.1002 (2008). Non-Traditional settlement arrangements consist of all traffic other than traditionally settled traffic. *** The U.S. carrier does not make a settlement or settlement-like payment directly to the carrier in the country of termination. The U.S. carrier reports as settlement payments for the country of termination any amounts owed to the carrier(s) in the intermediate point. This amount should include any amounts paid by affiliates to the terminating carrier associated with this traffic. In 2004, the Commission lifted the ISP requirements from agreements involving foreign carriers that do not have market power and on routes where the termination rates for U.S.-international services were below benchmark. See International Settlements Policy Reform, International Settlement Rates, IB Docket No. 02-234, First Report and Order, 19 FCC Rcd 5709, 5723-25, paras. 27-28 (2004). Currently, 165 routes are exempted from the ISP. See http://www.fcc.gov/ib/pd/pf/isp_exempt.html. See also U.S.- Cambodia Route Exempted from the International Settlements Policy , Public Notice, IB Docket Nos. 02-324, 96-261, 20 FCC Rcd 963 (Int’l. Bur. 2005). For a discussion of benchmarks, see International Settlement Rates , IB Docket No. 96-261, Report and Order, FCC 97-280, 12 FCC Rcd 19806, 19806, ¶ 1 (1997); Report and Order on Reconsideration and Order Lifting Stay , 14 FCC Rcd 9256 (1999); aff’d sub nom. Cable & Wireless P.L.C. v. FCC , 166 F.3d 1224 (D.C. Cir. 1999). Attachment 1 Table of Billing Codes Billing Codes for Facilities-Based and Facilities-Resale Services * Switched Services Traditional Settlement Arrangements ** public proprietary public proprietary I. Service originates from the U.S. point served A. Billed by U.S. carrier 1. Settled with a carrier in destination point; or exchanged with an affiliate in destination point a. Direct routing to destination point: traffic exchanged directly with 1 1 11 11 a carrier in destination point. b. Indirect routing: switched transit through an intermediate international point. (U.S. carrier owes settlement to carrier in destination point and transit fee to intermediate carrier.) 1 1 n.a. n.a. 2. Hubbed by a carrier in an intermediate international point *** n.a. n.a. 11 11 B. Billed by foreign carrier 1. Collect call 2 2 12 12 2. Subscriber toll free (800, 888, etc) 2 2 12 12 3. Calling card or other billing arrangement 2 2 12 12 II. Service originates from international point A. And terminates in the U.S. point served 1. Billed by foreign carrier 2 2 12 12 2. Billed by U.S. carrier a. Collect call 1 1 11 11 b. Subscriber toll free (800, 888, etc) 1 1 11 11 c. Calling card or other billing arrangement (Country-beyond or Country-direct) 1 4 11 14 B. And transits the U.S. point served 1. Billed by U.S. carrier: Calling card or other billing arrangement (country-beyond or country-direct) 1 4 11 14 2. Billed by foreign carrier a. Foreign carrier settles with country of termination directly or through cascade arrangement 3 3 n.a. n.a. b. Reoriginated by U.S. carrier and treated as U.S. carrier traffic for settlement purposes (i) originating leg (regardless of how terminated) exclude 6 exclude 16 (ii) terminating leg - terminated via facilities-based or facilities-resale circuits 1 5 11 15 (iii) terminating leg - terminated via pure resale of another carrier's The terminating leg of this traffic is included with the carrier's other switched service pure resale traffic in the public version of the data. Minutes, messages and receipts from the foreign carrier must be reported on a world total basis in the carrier's proprietary filing using billing code 35. Private Line Services Facilities-Based Facilites-Resale public proprietary public proprietary All circuits from U.S. point to theoretical midpoint of circuit 1 1 11 11 See Notes to Table of Billing Codes attached. Non-Traditional Settlement Arrangements ** 4