ORIGINAL

STATE OF INDIANA

| Commissioner | Yes | No | Not Participating |
|--------------|-----|----|-------------------|
| Zay | √ | | |
| Deig | √ | | |
| Swinger | √ | | |
| Veleta | √ | | |
| Ziegner | √ | | |

INDIANA UTILITY REGULATORY COMMISSION

IN THE MATTER OF THE APPLICATION OF ) CAUSE NO. 41052 ETC 103

TAG MOBILITY, LLC D/B/A TAG MOBILE )

FOR DESIGNATION AS AN ELIGIBLE ) APPROVED: MAR 11 2026

TELECOMMUNICATIONS CARRIER )

ORDER OF THE COMMISSION

Presiding Officers:

David E. Ziegner, Commissioner

Loraine L. Seyfried, Chief Administrative Law Judge

On August 18, 2025, TAG Mobility, LLC d/b/a TAG Mobile (“Petitioner,” or “TAG Mobile”) filed with the Indiana Utility Regulatory Commission (“Commission”) an Application for Designation as an Eligible Telecommunications Carrier (“Petition”), requesting designation as an eligible telecommunications carrier (“ETC”) pursuant to § 214(e)(2) of the Federal Communications Act of 1934, as amended (“Act”) to provide wireless services supported by the Federal Universal Service Fund’s (“USF”) Lifeline program.

On October 22, 2025, TAG Mobile pre-filed its direct testimony. On November 11, 2025, the Indiana Office of Utility Consumer Counselor filed a Notice of Intent Not to File Testimony.

On December 5, 2025, the Commission issued a docket entry requesting additional information from TAG Mobile, to which it responded on December 30, 2025. On December 30, 2025, Petitioner filed a Motion requesting leave to file the map of its proposed service territory in an alternative format, which was granted on January 5, 2026. On January 9, 2026, the Commission issued a second docket entry, to which Petitioner responded on January 15, 2026.

The Commission held an evidentiary hearing on January 7, 2026 at 10:30 a.m. in Room 224 of the PNC Center, 101 West Washington Street, Indianapolis, Indiana. Petitioner and the OUCC appeared by counsel and participated in the hearing, and the testimony and exhibits of Petitioner were admitted into the record without objection.

Based upon the applicable law and the evidence presented, the Commission finds:

1. Notice and Jurisdiction. Notice of the hearing in this Cause was given and published by the Commission as required by law. Pursuant to the Act and the rules of the Federal Communications Commission (“FCC”) at 47 C.F.R. §§ 54.201 and 54.203, the Commission is authorized to designate ETCs, thereby enabling those so designated to apply for federal USF support under 47 U.S.C. § 254 and in accordance with the Commission’s Orders in Cause Nos. 40785, 41052, and 42067. Pursuant to Ind. Code § 8-1-2.6-13 the Commission has jurisdiction over the designation of ETCs under 47 U.S.C. § 214. Therefore, the Commission has jurisdiction over Petitioner and the subject matter of this Cause.

1. Petitioner's Characteristics. TAG Mobile is a Texas limited liability company, organized on September 13, 2019, with its principal office located at 9920 Brooklet Dr., Houston, Texas. TAG Mobile was originally formed under the name TAG Mobile Bankruptcy Sale Entity LLC, its name was formally changed by certificate of amendment with the Texas Secretary of State on January 18, 2024. TAG Mobile is wholly owned by SoftelHoldings, LLC. TAG Mobile is a reseller of commercial mobile radio service ("CMRS") and provides prepaid wireless telecommunications services, including Lifeline services, to consumers by utilizing the underlying wireless networks of facilities-based providers. The Commission issued TAG Mobile a Certificate of Territorial Authority to provide CMRS and broadband services in the State of Indiana on June 26, 2025, in Cause No. 46228. Petitioner has been authorized by the Indiana Secretary of State to conduct business in Indiana. Petitioner is also a common carrier as defined by 47 C.F.R. § 20.9 and a telecommunications carrier as defined by 47 U.S.C. § 153.

2. Relief Requested. TAG Mobile requests ETC designation pursuant to 47 U.S.C. § 241(e)(2) of the Act to solely provide wireless services supported by the USF Lifeline program.

3. Petitioner's Evidence. Ms. Octavia Clanton, Compliance Associate for TAG Mobile, testified regarding the FCC's requirements for designation as a Lifeline-only ETC. Ms. Clanton testified that TAG Mobile provides, or is registered to provide, CMRS and has been designated as a Lifeline-only ETC in twenty-six states. She stated that TAG Mobile provides prepaid wireless telecommunications services to consumers by using the wireless networks of underlying facilities-based carriers on a wholesale basis; at this time, primarily using AT&T Mobility LLC ("AT&T").

Ms. Clanton testified that TAG Mobile meets the requirements to be designated as an ETC. She explained that TAG Mobile seeks ETC designation solely to provide Lifeline services to qualifying Indiana households and is not seeking ETC designation for high-cost support purposes. Ms. Clanton testified that TAG Mobile is a common carrier that offers all supported services required by FCC rule 47 C.F.R. § 54.101(a), which consists of voice telephony service and broadband service.

Ms. Clanton testified that TAG Mobile will provide: (1) voice grade access to the public switched network or its functional equivalent through the purchase of wholesale CMRS services from its underlying carrier(s); (2) rate plans with unlimited minutes of use for local service at no additional charge; (3) access to 911 and E911 emergency services. She noted that toll limitation service is not required because TAG Mobile's service is not offered on a distance-sensitive basis and local and domestic long distance minutes are treated the same. Ms. Clanton further testified that TAG Mobile's broadband internet access service ("BIAS") will provide customers with "the capability to transmit data to and receive data from all or substantially all Internet endpoints, including any capabilities that are incidental to and enable the operation of the communications service, but excluding dial-up Internet access service," via resale of its underlying carrier(s) wireless services. Pet. Ex. 2 at 9.

Ms. Clanton testified that while FCC rules require ETCs to offer services, at least in part, over their own facilities, the FCC granted forbearance from enforcement of this facilities requirement for carriers seeking Lifeline-only ETC designation, subject to the FCC's approval of an

ETC's Compliance Plan. She noted that a copy of TAG Mobile's Amended Compliance Plan, which the FCC approved on September 21, 2022, was attached to the Petition as Exhibit D. Ms. Clanton testified that TAG Mobile commits to providing Lifeline service in Indiana in accordance with its Amended Compliance Plan and in compliance with applicable state and federal regulations, to the extent amendments thereto may supersede commitments made in the Amended Compliance Plan.

Ms. Clanton testified that TAG Mobile commits to comply with the service requirements applicable to the low-income support that it receives in accordance with 47 C.F.R. § 54.202(a)(1)(i), and that TAG Mobile's Lifeline-supported services will meet or exceed the minimum service standards set forth in 47 C.F.R. § 54.408, including as they change going forward. She noted that a five-year network improvement plan does not apply to Lifeline-only ETCs such as TAG Mobile per 47 C.F.R. § 54.202(a)(1)(ii).

In accordance with 47 C.F.R. § 54.202(a)(2), Ms. Clanton testified that through its agreement with its underlying carrier(s), TAG Mobile will provide to its customers the same ability to remain functional in emergency situations as is currently provided by the underlying carrier(s) to their own customers, including access to a reasonable amount of back-up power to ensure functionality without an external power source, the ability to reroute traffic around damaged facilities, and the capability of managing traffic spikes resulting from emergency situations. In accordance with 47 C.F.R. 54.202(a)(3), Ms. Clanton testified that TAG Mobile commits to comply with the Consumer Telecommunications and Internet Association ("CTIA") Consumer Code for Wireless Service and thus satisfies applicable consumer protection and service quality standards.

Ms. Clanton further testified that TAG Mobile is financially and technically capable of providing Lifeline services as required by 47 C.F.R. § 54.202(a)(4). She further noted that TAG Mobile has access to the financial resources of its affiliate, Air Voice Wireless, LLC.

In its Petition and in accordance with 47 C.F.R. § 54.202(a)(5)-(6), TAG Mobile committed to the following: (i) that its Lifeline-supported voice services will meet or exceed the minimum service standards set forth in 47 C.F.R. § 54.408, including as such standards are updated going forward; (ii) its Lifeline-supported broadband services will also meet the minimum service standards set forth in 47 C.F.R. § 54.408 for mobile BIAS, including for service speed and data usage allowance, as such standards are updated going forward; and (iii) to the extent TAG Mobile provides devices for use with Lifeline-supported broadband service, such devices will meet the equipment requirements set forth in 47 C.F.R. § 54.408(f). Ms. Clanton provided additional details of TAG Mobile's proposed voice telephony and BIAS Lifeline service plans. She explained that TAG Mobile's current Lifeline service offering proposes to give eligible customers unlimited voice minutes, unlimited text messages, and 5 gigabytes ("GB") of data per month with full access to its Underlying Carriers' networks at a net cost of \$0.00 after application of Lifeline Support. In addition, all of TAG Mobile's plans will include nationwide domestic long-distance at no extra per-minute charge, free 411 directory assistance, and TAG Mobile will not assess any usage for access to its free customer service. Emergency (911) calls will be free, regardless of service activation or availability of minutes, and will not count against customer's airtime.

With regard to prevention of waste, fraud, and abuse of the program, Ms. Clanton testified that TAG Mobile complies with the requirements of the National Lifeline Accountability Database (“NLAD”) as set forth in 47 C.F.R. § 54.404 of the FCC’s rules. Ms. Clanton described TAG Mobile’s certification and verification procedures to make sure that its customers are eligible to receive Lifeline benefits, noting TAG Mobile’s commitment to rely on the National Lifeline Eligibility Verifier (“National Verifier”), once in place, to determine initial and ongoing eligibility of Indiana Lifeline subscribers. Ms. Clanton also described TAG Mobile’s activation and non-usage policy as set forth in FCC rules.

Ms. Clanton discussed TAG Mobile’s commitment and ability to comply with certain conditions imposed in various ETC designations of prepaid wireless carriers, including the filing of an information tariff, remitting applicable fees, and complying with applicable annual reporting requirements.

Ms. Clanton explained the public interest benefits of designating TAG Mobile as an ETC. She highlighted the benefits of increased competitive choice, the impact on the USF, and the unique advantages of TAG Mobile’s service offerings, which include larger local calling areas (as compared to traditional wireline carriers), the convenience and security afforded by mobile telephone service, the opportunity for customers to control cost by receiving a preset amount of monthly airtime and data at no net cost, the ability to purchase additional usage at flexible and affordable amounts in the event that included usage has been exhausted, and 911/E911 service. She noted that TAG Mobile’s prepaid wireless service is an especially attractive option for low-income consumers.

5. Information Request Responses. In response to requests from the Commission, Petitioner provided additional information to support its request for ETC designation, including a copy of its underlying agreement with AT&T, financial statements, a detailed service area map, information concerning Petitioner’s corporate business structure and affiliate relationships, and required certifications for plan offerings.

6. Commission Discussion and Findings. Universal service funds are provided in four areas: (1) funds to support service to high-cost areas; (2) provision of discounted telecommunications and internet access to eligible schools and libraries; (3) funds to assist low-income customers by provision of a monthly discount on telecommunications costs; and (4) provision of discounted service to rural health care providers. Comprehensive Review of Universal Service Fund Management, Administration and Oversight, 22 FCC Rcd. 16372, 16374 (2007).

Petitioner seeks designation in Indiana for the limited purpose of offering wireless Lifeline service to low-income customers. Petitioner’s application does not implicate the other three USF programs.

A. Common Carrier Status. The first requirement for ETC designation is status as a common carrier under federal law. A common carrier is generally defined by 47 U.S.C. § 153(11) as any person engaged as a common carrier on a for-hire basis in interstate telecommunications utilizing either wire or radio technology (except for radio broadcasters). As a

provider of wireless telecommunications services, we find that Petitioner is a “common carrier” for purposes of obtaining ETC designation under 47 U.S.C. § 214(e)(1).

B. Services Required to Be Offered. The evidence confirms that upon designation as an ETC in Indiana, Petitioner will provide all the services required of an ETC in the Lifeline Reform Order and Lifeline Modernization Order.1

i. Voice Telephony Service. Pursuant to 47 C.F.R. § 54.101(a), eligible voice telephony services must provide: (1) voice-grade access to the public switched telephone network or its functional equivalent; (2) minutes of use for local service provided at no additional charge to end users; (3) access to the emergency services provided by local government or other public safety organizations to the extent implemented; and (4) toll limitation services to qualifying low-income consumers. As set forth above, Ms. Clanton testified that Petitioner meets all four voice telephony service requirements. Petitioner is dependent on its underlying carrier to provide the required voice telephony services and provided documentation demonstrating that it has an agreement in place with a wireless carrier. Based on the foregoing, we find that Petitioner has satisfied this requirement.

ii. BIAS. Petitioner will provide the capability to transmit data to and receive data from all or substantially all Internet endpoints, including any capabilities that are incidental to and enable the operation of the communications service, but excluding dial-up Internet access service. Ms. Clanton noted that Petitioner provides BIAS via resale of its underlying carrier(s) wireless services, and the rates proposed by Petitioner contain a broadband component. Therefore, we find that Petitioner meets this requirement.

C. Lifeline Service Offering Requirements. 47 C.F.R. § 54.202(a) requires common carriers seeking designation as an ETC to submit information describing the terms and conditions of any voice telephony service plans offered to Lifeline subscribers, including details on the number of minutes provided as part of the plan, additional charges, if any, for toll calls, and rates for each such plan, as well as the terms and conditions of any BIAS plans offered to Lifeline subscribers, including details on the speeds offered, data usage allotments, additional charges for particular uses, if any, and rates for each such plan. Ms. Clanton provided evidence that Petitioner will offer eligible customers unlimited voice minutes, unlimited text messages and 5 GB of data per month. Lifeline customers will also have the ability to purchase additional airtime as needed. The record also reflects Petitioner’s commitment that its Lifeline-supported services will meet or exceed the minimum service standards set forth in 47 C.F.R. § 54.408, including as such standards are updated going forward. Thus, the evidence shows that Petitioner satisfies the Lifeline service offering requirements in 47 C.F.R. § 54.202(a).

D. Functionality in Emergency Situations. 47 C.F.R. § 54.202(a)(2) requires an ETC to “[d]emonstrate its ability to remain functional in emergency situations. . . .” Petitioner certified that it has the ability to remain functional in emergency situations through the capabilities

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1 Lifeline and Link Up Reform and Modernization, Report and Order and Further Notice of Proposed Rulemaking, FCC 12-11 (rel. Feb. 6, 2012) (“Lifeline Reform Order”) and Lifeline and Link Up Reform and Modernization, Third Report and Order, Further Report and Order, and Order on Reconsideration, FCC 16-38 (rel. Apr. 27, 2016) (“Lifeline Modernization Order”).

of its underlying wireless providers' networks, which includes access to a reasonable amount of back-up power, rerouting of traffic around damaged facilities, and the capability to manage traffic spikes resulting from emergency situations. Based on the foregoing, we find that Petitioner meets the requirement to remain functional in emergency situations.

E. Consumer Protection and Service Quality. 47 C.F.R. § 54.202(a)(3) requires an ETC to "[d]emonstrate that it will satisfy applicable consumer protection and service quality standards." A commitment by Petitioner to comply with the CTIA Consumer Code for Wireless Service will satisfy this requirement. Petitioner certified that it will comply with the CTIA Consumer Code for Wireless Service and thus meets this requirement.

F. Financial and Technical Capability. 47 C.F.R. § 54.202(a)(4) requires an ETC to "[d]emonstrate that it is financially and technically capable of providing the Lifeline service in compliance with subpart E." In addition, 47 C.F.R. 54.201(h) states that a "state commission shall not designate a common carrier as an [ETC] for purposes of receiving support only under subpart E [Lifeline] of this part unless the carrier seeking such designation has demonstrated that it is financially and technically capable of providing the supported Lifeline service in compliance with subpart E of this part." The FCC has indicated that relevant considerations for such a showing include whether the applicant previously offered services to non-Lifeline consumers, how long it has been in business, whether the applicant intends to rely exclusively on USF disbursements to operate, whether the applicant receives or will receive revenue from other sources, and whether it has been subject to enforcement action or ETC revocation proceedings in any state.2

Ms. Clanton testified that although Petitioner has been in business under its current ownership since January 2023, TAG Mobile is led by an experienced executive team with over 24 years of experience in the telecommunications industry, including five years leading Lifeline program participants and TAG Mobile's affiliates, Air Voice Wireless, LLC and Cintex Wireless LLC. Petitioner also submitted financial statements for Air Voice Wireless, LLC, and Ms. Clanton testified that Petitioner has access to the financial resources of Air Voice Wireless, LLC. Mr. Do submitted an affidavit stating that he is the common ultimate owner of both companies. Based on the evidence in the record, the Commission is satisfied that Petitioner possesses the financial and technical ability to provide Lifeline services.

G. Advertising Requirements. Petitioner has demonstrated that it will advertise the availability of the supported services, and the corresponding rates and charges, in a manner designed to inform the general public within its designated service area. This advertising will occur through a combination of media of general distribution, using mediums for outreach, such as social media platforms and its website. Petitioner has demonstrated that it will comply with the requirements of the Lifeline Reform Order, including the requirements that advertisements display disclosures described in that Order and in 47 C.F.R. § 54.405. Based on the foregoing, we find the evidence shows that Petitioner will comply with all applicable advertising requirements.

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2 Lifeline Reform Order, ¶ 388.

H. Petitioner's Designated ETC Service Area. The FCC's rules define "service area" as a "geographic area established by a state commission for the purpose of determining universal service obligations and support mechanisms." 47 C.F.R. § 54.207(a). The Commission's General Administrative Order 2019-5, Appendix A, Section 6 requires applicants to specify the designated service area for which ETC designation is sought by providing appropriate maps in a zipped shapefile or geospatial format and a list of non-rural ILEC territories and rural ILEC study areas that they propose to serve.

In its Petition, TAG Mobile submitted maps indicating the coverage areas of its underlying wireless carrier, AT&T, and a list of zip codes for the service area. Subsequently, Petitioner requested, and was granted, leave to file a map in alternative format, specifically in .jpeg file format, because submission of a shapefile posed a hardship. However, Petitioner did not provide a map in the alternative format. Petitioner requests designation as an ETC that is statewide in scope, to allow Petitioner to provide Lifeline service wherever its underlying, facilities-based providers have wireless coverage. Accordingly, we find that Petitioner is authorized to provide telecommunications service throughout the State of Indiana within the network coverage area of its underlying wireless providers. Within 30 days of issuance of this Order, Petitioner shall also file its service area map in .jpeg format.

I. Facilities-Ownership. Petitioner is not a facilities-based CMRS provider but will be reselling the services of underlying facilities-based wireless carriers. Federal rules prohibit pure resellers from being designated as ETCs; however, the FCC has granted wireless resellers who seek ETC designation for the limited purpose of providing Lifeline services forbearance from the facilities requirement of 47 U.S.C. § 214(e)(1)(A) if the reseller files a compliance plan that is approved by the FCC and complies with certain 911 requirements.3 TAG Mobile provided a copy of its FCC-approved Amended Compliance Plan. Pet. Exh. 1, Attach. D. Based on the foregoing, we find that it is unnecessary to require facilities ownership.

In addition, the Commission's GAO 2019-5, in Appendix A, Section 8.b. requires wireless resellers seeking ETC designation to provide the name of the facilities-based wireless carrier(s) whose services they are reselling. Since wireless resellers do not have their own facilities enabling them to provide supported services, they are required to demonstrate they have an agreement with a carrier or carriers in Indiana that will cover the proposed designated service area. Petitioner demonstrated it has an agreement in place to provide supported services in AT&T's network coverage area. Petitioner may, therefore, provide supported services in AT&T's network coverage area. Mr. Hung Henry Do, Petitioner's Chief Executive Officer, verified that AT&T has approved TAG Mobile as an authorized affiliated Sub-Reseller under the carrier agreement entered into with HTH Communications, LLC, which is also controlled by Mr. Do and under common ownership with Petitioner. Pet. Exh. 4.

J. Public Interest Consideration. As noted above and in accordance with 47 C.F.R. § 54.202(b), the designation of Petitioner as an ETC requires a public interest analysis. In the absence of statutory strictures for evaluating the public interest, the FCC has recommended that ETC designations be analyzed "in a manner that is consistent with the purposes of the Act itself, including the fundamental goals of preserving and advancing universal service; ensuring the

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3 Lifeline Reform Order, ¶ 368

availability of quality telecommunication services at just, reasonable, and affordable rates; and promoting the deployment of advanced telecommunications and information services to all regions of the nation, including rural and high-cost areas.”4

i. Use of Lifeline Funding. The record indicates that Petitioner will use funds from the federal Lifeline program to provide supported services to Lifeline customers. Petitioner has met its burden of proof for the Lifeline program. We find that Petitioner’s plans are consistent with current FCC regulations on the use of such funds.

ii. Impact on Federal USF. We have previously recognized that the FCC has undertaken various steps to address the growth in high-cost universal support disbursements. See e.g., Perry-Spencer Communications, Inc., Cause No. 41052 ETC 53 (IURC July 24, 2008). Notably, however, Petitioner is not seeking access to funding from the federal USF to provide service to high-cost areas. Lifeline support is provided on a customer-specific basis, and only after a carrier has acquired and begun to serve an eligible customer does the carrier receive Lifeline support for that customer. By tying support to actual service of a customer, the Lifeline program ensures that USF support only funds the carrier that serves the customer. However, we also recognize that costs for the low-income portion of the USF are increasing. While it is in the public interest that Lifeline eligible customers get connected to affordable telecommunications service, preventing misuse of the Lifeline program is necessary to control unproductive growth of the fund and increased USF surcharges for all Indiana telecommunications customers.

iii. Consumer Protection. As discussed above, the evidence reflects Petitioner’s commitment to abide by the CTIA Consumer Code of Conduct and applicable consumer protection requirements.

iv. Creamskimming. “Creamskimming” is a practice by which a communications service provider attempts to provide service only to low-cost customers while disregarding less profitable customers. On April 15, 2013, the FCC released an order granting forbearance from the requirements in 47 U.S.C. § 214(e)(5) and 47 U.S.C. § 54.207(b) that the service of an ETC conform to the service area of rural local exchange carriers serving the same area. Telecommunications Carriers Eligible for Support, 28 FCC Rcd. 4859 (2012). This FCC order applies to telecommunication carriers that seek limited designation as an ETC to participate only in the Lifeline program. Thus, a creamskimming analysis is not necessary for this Petition.

v. Increased Consumer Choice. Petitioner offers Lifeline plans similar to several other Lifeline-only ETCs previously designated in Indiana and will provide customers with another choice for such services. Petitioner stated that it offers different mobile devices and has different marketing strategies compared to its affiliate, Air Voice Wireless, LLC, and therefore Petitioner’s designation as an ETC would help expand the awareness of Lifeline services to qualifying consumers not targeted by Air Voice Wireless, LLC. Based on the record, we find that Petitioner’s designation as an ETC meets the requisite public interest consideration.

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4 2005 FCC ETC Order, 20 FCC Red. at 6389-6390.

vi. Affordable Rates. We must also consider whether designation as an ETC will “ensur[e] the availability of quality telecommunications services at just, reasonable, and affordable rates[.]” 2005 FCC ETC Order at 6388. Petitioner’s current Lifeline service offering proposes to give eligible customers unlimited voice minutes, unlimited text messages, and 5 GB of data per month. Lifeline customers will have the ability to purchase additional airtime as needed. Further, the benefits of Petitioner’s Lifeline plans will increase when necessary to comply with the FCC’s minimum service standards.

vii. Advantages and Disadvantages of the Offering. The record shows that Petitioner’s Lifeline service offering will expand available, accessible service options for additional Lifeline-eligible Indiana households. Accordingly, we find that Petitioner has satisfied this criterion of our public interest inquiry.

viii. Additional Public Interest Analysis. ETC designation confers both benefits and burdens upon the petitioning telecommunications service provider. Because the designation gives the provider the right to apply for federal universal service funds, it is essential that the provider comply with its obligations to contribute to public interest funds and not have a competitive advantage over other Indiana telecommunications carriers by avoiding such obligations. We find that it would not be competitively neutral to designate an ETC, permit it to collect public funds, but not require it to contribute its fair share to the public interest funds from which its network and its customers benefit. Petitioner has testified to its willingness to comply with Indiana laws and policies regarding the public interest funds for which the Commission has administrative oversight, including the public utility fee pursuant to Ind. Code ch. 8-1-6, the InTRAC fee pursuant to Ind. Code ch. 8-1-2.8, and the Indiana USF pursuant to the Commission’s Order in Commission Investigation of Universal Service Reform, Cause No. 42144 (IURC March 17, 2004). Based on the foregoing public interest analysis, we conclude that designating Petitioner as an ETC will promote the public interest and further the goals of the Act.

1. Regulatory Oversight. The Commission has previously recognized certain specific regulatory requirements that competitive wireless ETC applicants must satisfy to secure and maintain their ETC status in Indiana.5 Such regulatory requirements stem from the FCC’s mandate that state commissions certify that federal USF support is being used “only for the provision, maintenance, and upgrading of facilities and services for which the support is intended,” consistent with 47 U.S.C. § 254(e). In order for this Commission to satisfy its ETC certification requirements to the FCC, ETC applicants are required to file a tariff with the Commission. The record reflects Petitioner’s intention to comply with the Commission’s Lifeline tariff filing requirement. Accordingly, we find that Petitioner’s terms and conditions of service should be incorporated into its Lifeline tariff for Indiana and filed with the Commission’s Communications Division for review prior to Petitioner making its universal service offering available to eligible consumers in Indiana.

In previous ETC designations of prepaid wireless Lifeline providers, the Commission (and the FCC) imposed a condition that the ETC deal directly with the customer as an additional safeguard to prevent waste, fraud, and abuse of the Lifeline program. Petitioner committed to dealing with each customer directly and requiring each customer to self-certify under penalty of

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5 See NPCR, Inc., Cause No. 41052 ETC 43 (IURC March 17, 2004).

perjury that they are the only member of a household receiving a Lifeline benefit and that they do not receive the Lifeline benefit for any other phone. Petitioner indicated it will check its internal database and the NLAD or applicable state database to avoid duplicate Lifeline benefits for a single Lifeline household. Petitioner indicated it will require Lifeline customers to provide copies of documentation demonstrating that they are eligible for Lifeline based upon participation in one of the qualifying low-income programs or based upon income. Petitioner will abide by the applicable regulations of the FCC and the Commission regarding certification and verification of customer eligibility.

Finally, we find that Petitioner shall provide the Commission a copy of its annual certifications and Lifeline recertification results pursuant to 47 C.F.R. § 54.416 (i.e. FCC Form 555), as well as a copy of its annual report filed pursuant to 47 C.F.R. § 54.422 (i.e. FCC Form 481).

8. Additional Conditions Imposed on Petitioner's Designation as an ETC. In accordance with the Commission's findings above, Petitioner shall be subject to the following conditions:

• a. Petitioner shall provide a service area map in .jpeg format within 60 days of the issuance of this Order.
• b. Approval shall be subject to Petitioner's Amended Compliance Plan approved by the FCC, and in compliance with applicable state and federal regulations, to the extent amendments thereto may supersede commitments made in the Amended Compliance Plan.
• c. Consistent with 47 C.F.R. § 54.407(c)(1), Petitioner will only receive universal service support once a subscriber activates service. Petitioner will deactivate an account in accordance with federal regulations regarding non-usage, and shall report annually the number of subscribers de-enrolled for non-usage under 47 C.F.R. § 54.405(e)(3). This de-enrollment information must be reported by month and must be submitted to the Commission at the time an ETC submits its annual certification report pursuant to 47 C.F.R. § 54.416.
• d. Prior to providing Lifeline service, Petitioner shall file under this Cause an informational tariff and notify the Commission of changes in its terms, conditions, or free minute allocations in the form of a new tariff.
• e. Petitioner shall provide its Lifeline customers with 911 and E911 access regardless of activation status and availability of prepaid minutes as of the date it provides Lifeline services in Indiana. Petitioner shall provide its Lifeline customers with E911 compliant handsets and will replace, at no charge, any noncompliant headsets of existing customers.
• f. Petitioner shall establish safeguards and comply with as required by 47 C.F.R. § 54.405 to prevent customers from receiving multiple Lifeline subsidies at the same address.

Petitioner will abide by the FCC's Lifeline Reform Order by explaining to customers in plain, easily comprehensible language that they are not permitted to receive more than one Lifeline subsidy.

• g. Petitioner shall require each customer to self-certify under penalty of perjury that they are the only member of the household receiving the Lifeline discount and that they do not receive the discount for any other phone. Petitioner will rely on the National Verifier for determination of eligibility.
• h. Pursuant to 47 C.F.R. § 54.410, Petitioner shall annually require each Lifeline customer to confirm continued eligibility through the National Verifier. Petitioner will provide the Commission with a copy of its Lifeline recertification results that it files annually with the Universal Service Administrative Company pursuant to 47 C.F.R. § 54.416.
• i. Petitioner shall contribute to the InTRAC fund consistent with Commission requirements and Ind. Code ch. 8-1-2.8.
• j. Petitioner shall pay applicable fees, such as the public utility fee, InTRAC fee, IUSF fee, wireless emergency E911 fee, and any other applicable fees.

IT IS THEREFORE ORDERED BY THE INDIANA UTILITY REGULATORY COMMISSION that:

• 1. TAG Mobile's Petition for designation as an ETC for the limited purpose of offering Lifeline service to qualified households, for the service area identified in Petitioner's evidence, is granted.
• 2. Petitioner's request for authority to apply for or receive universal service funds from the Lifeline program pursuant to 47 U.S.C. § 254 is granted, subject to Petitioner's compliance with the terms, conditions, and reporting requirements of this Order and other applicable laws.
• 3. This Order shall be effective on and after the date of its approval.

ZAY, DIEG, SWINGER, VELETA AND ZIEGNER CONCUR:

APPROVED: MAR 11 2026

I hereby certify that the above is a true

and correct copy of the Order as approved.

Regina K.

Joyner Digitally signed by

Regina K. Joyner

Date: 2026.03.11

10:29:55 -04'00' _____ on behalf of

Dana Kosco

Secretary of the Commission