On Friday, January 25, 2008, the FCC announced it is changing its "lockbox" bank location  for all fees required to be submitted to the Commission that are not submitted online by credit card payment. Effective immediately upon publication of the Order in the Federal Register (which could happen imminently), all application fees, filing fees, regulatory fees, and tariffs (and any accompanying paper applications, forms or filings) previously directed to the Commission’s lockbox bank in Pittsburgh, PA, must be delivered instead to the new lockbox bank in St. Louis, MO. Perhaps in recognition that immediate compliance with the change in delivery location would require daily monitoring of the Federal Register over (approximately) the next two months, the Order provides a forty-five (45) day "transition period" to begin the day of publication. During this period, any fee-based filings and fee or tariff payments submitted to the Pittsburgh location automatically will be forwarded to the St. Louis lockbox bank, and the date-stamp reflecting the date of receipt by the Pittsburgh lockbox bank will be deemed the official filing date.

The bank that will serve as the FCC’s collection agent is the US Bank at 1005 Convention Plaza in St. Louis. But anyone trying to file a fee should first review the FCC’s addressing protocol carefully – just slapping "US Bank, 1005 Convention Plaza, St. Louis" will NOT do the trick, and can result in the rejection of the submission. Each filing must reflect the FCC as the addressee, with a particular P.O. Box specified – and the box number will vary depending on the nature of the filing being submitted. The various box numbers may be found in the FCC’s order.

Practically speaking, the Order merely means that Fletcher, Heald & Hildreth will submit on behalf of our clients all affected FCC fees and fee-based applications or filings to the new lockbox location in St. Louis once the Order becomes effective. However, clients should be keenly aware that, while the 4-hour-away proximity of our office to the Pittsburgh lockbox permitted some last-minute "day-of" submissions by courier, the location change to St. Louis will eliminate our ability to provide same-day services. Upon effectiveness of the Order, fee payments from clients to be submitted to the FCC by FHH must be received at least a day before the due date to permit enough time for delivery to St. Louis. We will post a notification on our blog as well as include a notice in our newsletter when the change becomes effective.