The California CPUC TCR Application is the Section 1013 Telephone Corporation Registration package that non-facilities-based telephone corporations, interconnected VoIP resellers, NDIECs, and CLEC resellers must file with the California Public Utilities Commission before offering voice service in California. The current package is the 1013 Registration Form (rev. June 2025), and filing the wrong category, missing the $25,000 performance bond, or skipping a single appendix can stall your launch by six to nine months.
According to the CPUC Communications Division, more than one in three Section 1013 registration packages are kicked back on the first review for tariff, bond, or officer-disclosure defects, which is why filers benefit from a careful, line-by-line walkthrough before they touch the CPUC Electronic Filing System.
In this guide you will learn:
- 📞 What the CPUC TCR (Section 1013) Application is and who must file it
- 🗂️ Every document, ID number, and disclosure you need to gather first
- ✍️ A field-by-field walkthrough of every section, box, and appendix
- 👥 Three named-filer scenarios (VoIP, CLEC reseller, NDIEC) from start to finish
- ⚖️ Filing fees, the $25,000 performance bond, deadlines, and the most common rejection traps
What the Form Is and Who Must File It
The CPUC TCR Application — formally the Section 1013 Registration Form for Telephone Corporations — is the streamlined operating-authority package created under Public Utilities Code § 1013 for non-facilities-based carriers. It replaces the full Certificate of Public Convenience and Necessity (CPCN) process for resellers, NDIECs, and most non-facilities-based interconnected VoIP providers, and it is reviewed by the CPUC Communications Division. The form lives on the CPUC Licensing & Registration page and is updated periodically; the current revision date is June 2025, which you should confirm before filing.
You must file the TCR if you plan to offer intrastate voice service in California as a Non-Dominant Interexchange Carrier (NDIEC), a non-facilities-based Competitive Local Exchange Carrier (CLEC reseller), a non-facilities-based interconnected VoIP provider, or a Wireless Identification Registrant (WIR) reseller. Facilities-based providers cannot use the TCR; they must file a full CPCN application under P.U. Code § 1001. Under the CPUC’s 2025 VoIP Licensing Decision, the agency also distinguishes between Digital Voice Fixed (registration eligible) and Digital Voice Nomadic (separate Nomadic Registration) providers.
The plain-English explanation is that the TCR is the CPUC’s “registration lane” for carriers that resell someone else’s network. The consequence of using the wrong lane is real — if a facilities-based carrier sneaks in through the TCR, the Commission will reject the filing, refund the fee, and require a full CPCN, costing months of regulatory delay. Imagine a startup VoIP provider that bought switching equipment in San Jose and tries to register through the TCR; the Communications Division will catch the facilities ownership and force a CPCN refile. A common misconception is that the TCR is “automatic” once filed — it is not, and the Commission has up to 180 days to review the package under its administrative timelines.
Before You Start: Documents and Information You Need
Open every required exhibit before you start typing, because the CPUC Electronic Filing System will not let you save a partial 1013 package. The Communications Division expects every appendix in PDF/A format, combined into a single document along with the cover page and the sworn verification.
- Articles of Incorporation or Charter Document. Needed to confirm the exact legal name in Section 1; if missing, the application is rejected on completeness review.
- California Secretary of State Entity Number. Needed because the CPUC cross-checks foreign and domestic registration with the California Secretary of State business search.
- Registered Agent for Service of Process. Required by Section 2; without it, the Commission cannot serve future orders and the package is incomplete.
- Federal Employer Identification Number (FEIN). Needed for cross-reference with the FCC Form 499-A and California Department of Tax and Fee Administration filings.
- FCC Filer ID and most recent FCC Form 499-A. Required to match interstate revenue reporting; missing this delays the User Fee setup.
- $25,000 Performance Bond (Form PU 856-C). Required by D.13-09-035 and posted as Appendix E; filing without it triggers an automatic rejection.
- $250 Filing Fee. The current application fee under D.10-09-017; the older “$75 fee” myth still trips up first-time filers.
- Officer, Director, and 10%-Owner Resumes. Required by Appendix C; missing or thin resumes prompt a deficiency letter.
- Draft Tariff in General Order 96-B format. Required as Appendix F unless you elect the GO 96-B detariffing exemption.
- Service Territory Map. Required as Appendix B if you select “specific portions of the state only” in Section 4.
- Financial Statements (Audited or Reviewed). Demonstrate the $100,000 minimum cash/equivalents requirement under D.13-05-035.
- Sworn Verification (Attachment A). Signed under penalty of perjury by an officer; an unsworn package is treated as not filed.
Where to Get the Form and How to Access It
The official 1013 Registration Form is hosted on the CPUC’s Licensing and Registration page and downloads as a fillable Word document. Always pull a fresh copy the day you start drafting, because the Communications Division revises the package without formal notice; the current revision is June 2025, printed in the footer of the instructions.
You access the filing channel through the CPUC Electronic Filing System (EFS), which is the same docket portal used for advice letters and CPCN filings. Filers must register for an EFS account, list their firm or in-house contact, and upload the combined PDF/A package; paper filings are no longer accepted for new TCR registrations under the 2024 e-filing mandate. The cover page must be saved as PDF/A compliant, the application number must be left blank, and the ALJ Docket Office will assign a number once the package is accepted.
A common access mistake is downloading the older “Section 1013 PDF” floating on third-party blogs, which lacks the new foreign-ownership and cybersecurity-attestation boxes added in the June 2025 revision. The consequence is a mismatched form rejected at intake. Maria Lopez, a regulatory analyst at a Texas-based reseller, downloaded a 2021 PDF from a law-firm blog, filed it, and lost three weeks before re-uploading the current Word version. The misconception that “any version works as long as you sign it” is wrong; the CPUC explicitly requires the current revision to ensure all mandatory disclosures are present.
Step-by-Step: How to Fill Out the CPUC TCR (Section 1013) Application Line by Line
Cover Page
Cover Page — Application Number
The cover page asks for an application number at the top right. You do not enter anything here — the ALJ Docket Office issues the number (formatted A.26-05-XXX) only after the package is accepted into the CPUC system. Carlos Nguyen, filing for a new VoIP reseller, leaves this box blank and writes “To Be Assigned” only in the file naming convention. The nuance is that some filers paste the EFS confirmation ID here, which is wrong; that is an internal tracking number, not a docketed application number. The common mistake is typing a self-generated number, which causes the docket office to send the package back for re-filing. The misconception is that leaving it blank looks unprofessional — in fact, it is the only correct action.
Cover Page — Title of Proceeding
This field asks you to name the matter, typically Application of [Legal Name] (U-XXXX-C) for a Certificate to Provide Limited Facilities-Based and Resold Competitive Local Exchange and Interexchange Services. You copy the standard title from the CPUC instructions and substitute your legal name and U-number (if you already hold one for a different category). The nuance is that VoIP-only registrants use a slightly different title referencing “Non-Facilities-Based Interconnected VoIP Service” rather than CLEC. The common mistake is using a marketing name instead of the legal name, which causes a docket-mismatch and delays service-list creation. The misconception that the title is decorative is wrong; the title becomes the official caption used by the CPUC Daily Calendar.
Section 1 — Applicant Identification
Section 1 — Legal Name, Address, Telephone, Email
Section 1 asks for the applicant’s complete legal name exactly as it appears on the articles or certificate of incorporation, plus the business address, telephone, and email. You type the name in ALL CAPS or Title Case to match the charter, and you use a working corporate email — not a personal Gmail. Aisha Patel, registering Clear Signal Communications, LLC, types “CLEAR SIGNAL COMMUNICATIONS, LLC” exactly as it appears on her Delaware certificate. The nuance is that DBA/fictitious names go in Section 1.b., never in 1.a. The common mistake is using a marketing name like “ClearSignal” without the entity suffix; the CPUC will mismatch the California Secretary of State record and issue a deficiency letter. The misconception that punctuation does not matter is wrong — a missing comma between “LLC” and the name will trigger a name-mismatch hold.
Section 1.a. — Principal Place of Business
This field asks where the applicant actually operates from, which may differ from the address in Section 1. If it is the same, you must enter “Same as Above” — do not leave it blank, per the June 2025 instructions. The nuance is that virtual-office addresses are accepted only if mail is reliably forwarded, because the CPUC mails original orders. The common mistake is leaving the field blank, which the Communications Division treats as a missing answer and rejects. The misconception that a P.O. Box is acceptable is wrong; a physical street address is required so that process can be served.
Section 1.b. — Fictitious Business Name (DBA)
This field asks for any DBA under which you intend to bill customers. You list every DBA exactly as registered with the relevant California county clerk, and you attach the Fictitious Business Name Statement as part of Appendix A. Marcus Reed lists “BlueLine Voice” as the DBA of BlueLine Holdings Corp., attaching his Los Angeles County FBN filing. The nuance is that an unregistered DBA in California exposes you to Business and Professions Code § 17910 penalties. The common mistake is listing a marketing tagline instead of a registered DBA, which the CPUC will strike. The misconception that DBAs are optional disclosures is wrong; failure to list a billing DBA is a consumer-protection violation under D.98-08-031.
Section 1.c. — Type of Entity
This field asks whether the applicant is a corporation, LLC, LP, or other entity. You check exactly one box and provide the state of formation. Janet Cho checks “Limited Liability Company” and writes “Delaware” beside it. The nuance is that foreign LLCs must also be qualified to transact business in California through the Secretary of State Form LLC-5. The common mistake is checking “Corporation” when the entity is actually an LLC, which voids the verification block. The misconception that a sole proprietorship can register is wrong — sole proprietors cannot hold a CPUC operating authority.
Section 1.f. — Foreign Ownership Interest
This field asks whether any owner of 10% or more is a foreign entity, requiring a Yes/No selection. If “Yes,” you must list the foreign entity, country of domicile, and percentage owned. Carlos Nguyen selects “Yes” because his Singapore-based parent owns 100% of the U.S. subsidiary, and he attaches a corporate-structure chart. The nuance is that the 2025 revision now requires identifying any owner subject to Section 214 of the Communications Act for foreign-carrier review. The common mistake is answering “No” because the foreign owner is “only” a passive investor, which is wrong — direct or indirect 10% interests count. The misconception that foreign ownership is automatically disqualifying is also wrong; the CPUC approves foreign-owned applicants every quarter, but only when fully disclosed.
Section 2 — Registered Agent for Service of Process
Section 2 — Agent Name, Address, and Telephone
Section 2 asks for the name, mailing address, and telephone of the applicant’s California registered agent. You list the agent exactly as filed with the Secretary of State, with a California street address. Aisha Patel lists “CT Corporation System, 330 N Brand Blvd, Glendale, CA 91203, (818) 649-9100.” The nuance is that the agent must be physically located in California; an out-of-state agent will be rejected. The common mistake is listing the company’s own address as the agent — only individuals or qualified corporate agents can serve. The misconception that you can change agents informally later is wrong; agent changes require a Tier 1 advice letter under General Order 96-B.
Section 3 — Contact for Regulatory Matters
Section 3 — Day-to-Day Regulatory Contact
This field asks for the named human who handles CPUC correspondence, including phone, email, and title. You list a person, not a role mailbox, because the CPUC sends time-sensitive deficiency letters. Marcus Reed lists himself as “Marcus Reed, Director of Regulatory Affairs, mreed@blueline.com, (213) 555-0144.” The nuance is that this person also receives the annual user fee invoices and surcharge instructions. The common mistake is listing outside counsel without an in-house backup, which causes missed deadlines if counsel changes firms. The misconception that the regulatory contact is the same as the ECARS contact is wrong — ECARS uses a separate registration.
Section 4 — Operating Authority Sought
Section 4 — Service Type and Territory
Section 4 asks you to check every type of service you propose to offer (NDIEC, CLEC reseller, interconnected VoIP, WIR reseller), the type of facilities (resold only, limited facilities-based), and the service territory (statewide, specific ILEC territories, or specific portions). You select all that apply, then attach Appendix B with maps if you choose specific portions. Carlos Nguyen checks “Non-Facilities-Based Interconnected VoIP” and “Statewide” because his cloud PBX serves all 58 counties. The nuance is that selecting both NDIEC and VoIP creates two utility-ID assignments, which doubles your annual user-fee minimum. The common mistake is over-checking categories “to be safe,” which inflates your bond requirement and surcharge base. The misconception that “statewide” includes tribal lands without separate notice is wrong — tribal carriers face additional FCC Tribal Lands coordination.
Section 5 — Technical and Managerial Qualifications
Section 5 — Officer, Director, and 10%-Owner Disclosures
This section asks for resumes of every officer, director, and 10%+ owner, attached as Appendix C, including all employment history and any government investigations, settlements, or monetary forfeitures under D.10-09-017. You provide a one- to two-page resume per person and a sworn statement covering investigations. Janet Cho attaches resumes for her CEO, CFO, and a 15% angel investor, plus a “no investigations” attestation. The nuance is that “all employment” means all, not just telecom-related — gaps are flags. The common mistake is omitting a passive 10% owner because they are not active, which the CPUC catches via cap-table review and treats as a material misrepresentation. The misconception that prior unrelated SEC inquiries do not need disclosure is wrong; everything material must be disclosed.
Section 6 — Services to Be Provided
Section 6 — Specific Service Descriptions
Section 6 asks the applicant to identify the specific services it will sell — local exchange, intraLATA toll, interLATA toll, operator services, prepaid, interconnected VoIP, or others. You check each one and provide a short description. Aisha Patel checks “Resold Local Exchange,” “Resold IntraLATA Toll,” and “Interconnected VoIP,” then describes Clear Signal’s hosted PBX product in two sentences. The nuance is that prepaid services trigger separate consumer-disclosure rules under D.07-09-019. The common mistake is checking “Operator Services” for transferred 0+ traffic without realizing the OSP price-disclosure rules apply. The misconception that VoIP services skip 911/E911 obligations is wrong; California enforces 911 surcharges on every interconnected VoIP minute.
Section 7 — Financial Qualifications
Section 7 — Cash, Equivalents, and Financial Statements
This section asks the applicant to demonstrate at least $100,000 in cash or equivalents and to attach audited or reviewed financial statements as Appendix D. You include a balance sheet, income statement, and a sworn declaration that the cash threshold is currently met. Marcus Reed attaches a CPA-reviewed balance sheet showing $312,000 in operating cash for BlueLine Voice. The nuance is that startup applicants without audited financials may substitute a parent-company guarantee under D.13-05-035. The common mistake is submitting a bank screenshot instead of a CPA-prepared statement, which the Commission rejects as unverified. The misconception that revenue equals cash is wrong; the test is liquidity at the time of filing.
Section 8 — Performance Bond
Section 8 — $25,000 Bond and Form PU 856-C
Section 8 asks you to attest that the $25,000 performance bond is in place, with the executed Form PU 856-C attached as Appendix E. You sign the attestation, list the surety company and bond number, and attach the original surety-issued bond. Carlos Nguyen lists “Travelers Casualty & Surety, Bond #105-77-9921, $25,000.” The nuance is that NDIECs with prior-year intrastate revenue must post the greater of $25,000 or 10% of that revenue. The common mistake is filing a placeholder “we will get a bond after approval” letter, which is an automatic rejection because the bond must exist on the date of filing. The misconception that the bond is one-time is wrong; you must re-file the bond every year by March 31 via advice letter.
Section 9 — Compliance Attestations
Section 9 — Past Violations and Affiliations
This section asks whether the applicant or any officer/director has been the subject of a CPUC, FCC, FTC, or state AG enforcement action, and asks for affiliated CPUC-regulated entities. You answer Yes/No and provide details for any “Yes.” Janet Cho discloses a 2019 FCC consent decree for a sister company and attaches the underlying order. The nuance is that even closed matters with no admission of liability must be disclosed. The common mistake is treating “no fault” settlements as non-events, which the Commission treats as a material omission. The misconception that affiliate disclosure is limited to California is wrong; all affiliated regulated entities, in any state, must be listed.
Section 10 — Tariff Election
Section 10 — Detariffing Election Under GO 96-B
Section 10 asks whether the applicant elects the GO 96-B detariffing exemption available to certain non-dominant carriers and VoIP resellers. You select “True” to claim the exemption (binding you to the Consumer Protection Rules in D.98-08-031) or “Not True” to file a draft tariff as Appendix F. Aisha Patel selects “True” because Clear Signal will publish prices on its website rather than file a tariff. The nuance is that detariffed carriers must still post terms publicly and follow slamming/cramming rules. The common mistake is selecting “True” but failing to publish a price list, which is a consumer-protection violation. The misconception that detariffing means deregulation is wrong; CPUC enforcement authority remains intact.
Section 11 — California Environmental Quality Act (CEQA)
Section 11 — CEQA Statement
This section asks for a CEQA statement under Public Resources Code § 21000 confirming whether the proposed services will involve construction. Resellers and non-facilities-based VoIP providers state that the project is categorically exempt under CEQA Guidelines § 15301 (existing facilities). Marcus Reed writes one sentence: “BlueLine Voice will resell existing carrier services and undertake no construction; the project is categorically exempt under CEQA Guidelines § 15301.” The nuance is that even minor co-location can trigger CEQA review. The common mistake is leaving this section blank because “we don’t build anything,” which the Commission treats as missing analysis. The misconception that CEQA does not apply to telecom is wrong — every CPUC authorization is a CEQA “project” by default.
Attachment A — Sworn Verification
Attachment A — Officer Signature Under Penalty of Perjury
Attachment A is the sworn verification, signed by an officer under California Code of Civil Procedure § 2015.5. You print the officer’s name and title, sign, and date the verification. Carlos Nguyen signs as “Carlos Nguyen, Chief Executive Officer, executed in San Jose, California, on 05/26/2026.” The nuance is that the verification must be signed by an actual officer, not outside counsel. The common mistake is using DocuSign without the proper California declaration block, which the Commission may reject. The misconception that an unsigned verification can be cured later is wrong — the package is treated as not filed until verified.
Three Filled-Out Examples Using Real Scenarios
Scenario 1 — Carlos Nguyen, New Interconnected VoIP Reseller
Carlos is launching a cloud PBX product for California small businesses and registers a Delaware LLC with a Singapore parent.
| Form Section | What Carlos Enters |
|---|---|
| Section 1 — Legal Name | CN VOICE TECHNOLOGIES, LLC |
| Section 1.a. — Principal Place | 2150 N 1st St, Suite 400, San Jose, CA 95131 |
| Section 1.f. — Foreign Ownership | Yes — CN Holdings Pte. Ltd. (Singapore), 100% |
| Section 2 — Registered Agent | CT Corporation System, Glendale, CA |
| Section 4 — Operating Authority | Non-Facilities-Based Interconnected VoIP, Statewide |
| Section 6 — Services | Resold Interconnected VoIP, IntraLATA, InterLATA |
| Section 8 — Performance Bond | Travelers Surety, Bond #105-77-9921, $25,000 |
| Section 10 — Tariff Election | True (detariffed; price list published) |
| Attachment A — Verification | Carlos Nguyen, CEO, 05/26/2026 |
Scenario 2 — Aisha Patel, CLEC Reseller Expanding from Texas
Aisha runs Clear Signal Communications, an existing Texas CLEC reseller adding California to her footprint.
| Form Section | What Aisha Enters |
|---|---|
| Section 1 — Legal Name | CLEAR SIGNAL COMMUNICATIONS, LLC |
| Section 1.b. — DBA | Clear Signal Voice |
| Section 1.c. — Entity Type | Limited Liability Company, Texas |
| Section 4 — Operating Authority | Resold CLEC + NDIEC, all ILEC territories |
| Section 5 — Officers | Resumes for CEO, CFO, COO, plus 12% investor |
| Section 7 — Financials | CPA-reviewed balance sheet, $612K cash |
| Section 8 — Bond | Liberty Mutual, Bond #LM-44-8821, $25,000 |
| Section 10 — Tariff | Not True — draft tariff in GO 96-B format attached |
| Attachment A — Verification | Aisha Patel, President, 05/26/2026 |
Scenario 3 — Marcus Reed, NDIEC Reseller (Prepaid Long Distance)
Marcus operates BlueLine Voice, a prepaid long-distance reseller targeting California’s immigrant communities.
| Form Section | What Marcus Enters |
|---|---|
| Section 1 — Legal Name | BLUELINE HOLDINGS CORP. |
| Section 1.b. — DBA | BlueLine Voice |
| Section 4 — Operating Authority | NDIEC, Statewide, Resold Only |
| Section 6 — Services | Resold IntraLATA, InterLATA, Prepaid Calling |
| Section 7 — Financials | Reviewed statement, $312K cash |
| Section 8 — Bond | Hartford, Bond #HF-22-9090, $25,000 |
| Section 9 — Past Violations | None disclosed |
| Section 10 — Tariff | Not True — prepaid tariff under D.07-09-019 |
| Attachment A — Verification | Marcus Reed, President, 05/26/2026 |
How to File the Completed Form
You file the completed TCR package electronically through the CPUC Electronic Filing System, which is the only accepted channel for new Section 1013 registrations as of 2024. You combine the cover page, the 1013 form, every appendix, and Attachment A into a single PDF/A file and upload it under the “Application — Telephone Corporation Registration” filing type. Pay the $250 filing fee through the EFS payment portal using ACH or credit card; checks payable to the California Public Utilities Commission, 505 Van Ness Avenue, San Francisco, CA 94102 are accepted only for legacy paper amendments.
You should also email a courtesy copy to CDcompliance@cpuc.ca.gov per the VoIP Providers page, particularly for VoIP-only registrants whose filings the Communications Division pre-screens. Expected processing time is 120 to 180 days to a final resolution, with an early Communications Division “completeness review” within 30 days. Keep your EFS confirmation email and the Docket Office acceptance notice as proof of filing — these become your defense if a third party later challenges your operating authority.
Mail-in filing is reserved for confidential exhibits (financial statements with motions to seal) which can be lodged under Rule 11.4 of the CPUC Rules of Practice and Procedure. Fax filings are not accepted. In-person filings are accepted only at the Docket Office at 505 Van Ness Avenue, weekdays 8 a.m. to noon and 1 p.m. to 5 p.m., and only when the EFS is unavailable.
What Happens After You File
After acceptance, the ALJ Docket Office assigns an application number (e.g., A.26-05-014) and publishes the filing on the Daily Calendar. The Communications Division then conducts a 30-day completeness review; if the package is deficient, you receive a deficiency letter listing every missing or unclear item, and you have 30 days to cure or face dismissal without prejudice.
If complete, the application moves to substantive review and is typically resolved by a Resolution adopted at a Commission Voting Meeting, granting the operating authority and assigning a U-number (formatted U-XXXX-C for CLEC/NDIEC or U-XXXX-VOIP). Your U-number is your permanent CPUC identifier for tariffs, advice letters, and the annual User Fee currently set at 0.18% of gross intrastate revenue with a $100 minimum. From that point forward you must file the FCC 499-A and California intrastate revenue reports, remit the California High Cost Fund-A and B surcharges, and renew the performance bond every March 31 by Tier 1 advice letter.
Mistakes to Avoid When Filling Out the Form
- Filing the wrong category (TCR instead of CPCN). The Commission rejects facilities-based filings on the wrong track and forces a refile.
- Leaving Section 1.a. blank. Treated as missing data and bounced on completeness review.
- Listing a marketing name in Section 1. Causes a Secretary of State name-mismatch hold.
- Using a P.O. Box instead of a street address. Process cannot be served, and the package is rejected.
- Ignoring foreign-ownership disclosure. Considered a material misrepresentation and grounds for dismissal.
- Filing without a fully executed performance bond. Automatic rejection under D.13-09-035.
- Omitting officer resumes. Triggers a deficiency letter and a 30-day cure clock.
- Submitting unaudited bank screenshots. The Commission rejects unverified financials.
- Skipping the CEQA statement. Treated as missing analysis, even for resellers.
- Forgetting Attachment A. An unverified package is treated as not filed at all.
- Paying $75 instead of $250. The fee was raised over a decade ago; underpayment delays acceptance.
- Using a 2021-era PDF. Missing fields trigger a form-version rejection.
Dos and Don’ts
- Do download the form fresh from the CPUC Licensing page the day you start drafting, because the form is updated without formal notice.
- Do combine every exhibit into one PDF/A document, since EFS rejects multi-file packages.
- Do post the $25,000 performance bond before filing, because backdating is not allowed.
- Do disclose every officer, director, and 10%-owner, because cap-table review will catch omissions.
- Do keep your EFS confirmation, since it is your only proof of timely filing.
- Do calendar the March 31 annual bond renewal, or your authority can be suspended.
- Don’t copy a competitor’s tariff verbatim, because GO 96-B requires applicant-specific terms.
- Don’t check every operating-authority box “to be safe,” since each adds bond and surcharge exposure.
- Don’t sign Attachment A as outside counsel, because only an officer can verify.
- Don’t ignore deficiency letters, because the 30-day cure clock runs whether you respond or not.
- Don’t assume detariffing means no enforcement, since D.98-08-031 consumer rules still apply.
- Don’t launch service before the resolution is adopted, because pre-authorization revenue can trigger restitution and 10% interest under the 2025 VoIP Decision.
Pros and Cons of Filing on Your Own vs. With Help
| Filing Pro Se | Filing With Telecom Counsel |
|---|---|
| Saves $8,000 to $25,000 in legal fees | Catches Section 1.f. and Section 9 traps before filing |
| Forces founders to learn the regulatory framework | Drafts a GO 96-B-compliant tariff in days, not weeks |
| Works for very small VoIP resellers with simple cap tables | Negotiates deficiency letters directly with Communications Division |
| Faster turnaround if the founder is a former regulator | Manages performance bond and surety relationships |
| Direct relationship with Communications Division | Anticipates the 2025 Digital Voice Nomadic vs. Fixed split |
Pros of filing pro se include cost savings, deep founder knowledge, and direct CPUC relationships, but the cons are severe — the average pro se applicant takes 50% longer to reach a final resolution, and one missed disclosure can cost the entire $250 fee plus six months. Pros of using counsel include speed, fewer deficiency letters, and confident handling of Section 1.f. foreign-ownership and Section 9 affiliate questions; the cons are cost and the risk of counsel filing a generic package without learning the applicant’s specific business model.
Key Entities, Statutes, and Decisions
The key statute is P.U. Code § 1013, which authorizes the streamlined registration process; the key implementing decisions are D.10-09-017 (raised the fee to $250 and the bond to $25,000), D.13-05-035 (VoIP registration framework), D.98-08-031 (consumer protection rules), and the 2025 VoIP Licensing Decision splitting Digital Voice Fixed from Digital Voice Nomadic. The Communications Division reviews the package, the ALJ Docket Office accepts and dockets it, and the full Commission votes on the final resolution. Federal law touches the form through the FCC Form 499-A revenue reporting requirement and Section 214 of the Communications Act for foreign-carrier review.
FAQs
Is the CPUC TCR the same as a CPCN?
No. The TCR is the streamlined Section 1013 registration for non-facilities-based carriers; the CPCN is the full Section 1001 application for facilities-based carriers and is significantly more burdensome.
Do nomadic VoIP providers file the TCR?
No. Under the 2025 VoIP Licensing Decision, Digital Voice Nomadic providers must file a separate Nomadic Registration form, not the Section 1013 package used by Digital Voice Fixed providers.
Can I write my P.O. Box in Section 1.a.?
No. The principal-place-of-business field requires a physical street address so that process can be served, and a P.O. Box answer triggers a completeness rejection.
Do I write my DBA or my legal name in Section 1?
Yes — write the legal name exactly as on your charter in Section 1, and place every DBA in Section 1.b. with the supporting Fictitious Business Name filing attached.
Is the filing fee still $75?
No. The fee has been $250 since D.10-09-017 raised it from $75; underpayment delays acceptance.
Do I need the performance bond before I file?
Yes. The executed Form PU 856-C bond for $25,000 must be in place on the filing date and attached as Appendix E, because the Commission will not accept a “bond to follow” letter.
Must I disclose a 10% passive investor in Section 5?
Yes. Every owner of 10% or more must be listed with a resume and investigation attestation, regardless of whether the ownership is active or passive.
Can outside counsel sign Attachment A for me?
No. Only an officer of the applicant may sign the sworn verification under penalty of perjury; counsel-signed verifications are rejected.
Should I check “True” or “Not True” in Section 10?
Yes — most non-dominant resellers select True to claim the GO 96-B detariffing exemption, but you must then publish your prices and follow D.98-08-031 consumer rules.
Can I start serving customers once I file?
No. You must wait for the final Commission resolution granting your authority and assigning your U-number; pre-authorization service can trigger restitution and 10% annual interest.
Do I need to file a tariff if I select “True” in Section 10?
No. Selecting “True” elects out of tariffing, but you must publish a public price list and comply with the consumer-protection rules in D.98-08-031.
How long does the CPUC take to approve a TCR?
No single timeline applies, but most filings resolve in 120 to 180 days, with a 30-day completeness review followed by substantive review and a Commission vote.
Do I have to renew anything after approval?
Yes. You must renew the performance bond every March 31 via Tier 1 advice letter, file annual intrastate revenue reports, and remit the User Fee and California public-purpose surcharges.
Is the TCR the right form for a wholesale-only carrier?
Yes, if the wholesale-only carrier is non-facilities-based and offers any intrastate voice service in California; facilities-based wholesalers still need a CPCN under Section 1001.
Related reading
- How to Fill Out California Form SI-200 (w/Examples) + FAQs
- How to Fill Out California CPUC Form 1 (w/Examples) + FAQs
- How to Fill Out California CPUC TCP Application (w/Examples) + FAQs
- How to Fill Out California CPUC Carrier Identification Number Application + FAQs
- How to Fill Out California CPUC Highway Carrier Insurance Form (w/Examples) + FAQs
- How to Fill Out California CPUC Form A (w/Examples) + FAQs
- How to Fill Out California Form 100 (w/Examples) + FAQs