FCC Record, Volume 28, No. 1, Pages 1 to 975, January 2 - January 31, 2013 Page: 83
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set forth the information that must be included in the domestic and international transfer of control
3. "Non-substantial" (or "pro forma"d') transfers of a carrier's lines or of Section 214
authority do not require Commission approval prior to consummation.6 A carrier that consummates a pro
forma international Section 214 transaction, however, must provide notice of that transaction to the
Commission no later than 30 days after consummation.' This notification requirement generally does not
extend to pro forma domestic Section 214 transactions.8
4. StanaCard, a Delaware limited liability company, is a resale provider primarily of prepaid
international telecommunications services.' On February 1, 2010, the Commission's International Bureau
(IB) granted international Section 214 authority to StanaCard.'o At that time, the Company also obtained
blanket domestic Section 214 authority by operation of the Rules."
5. On January 27, 2012, StanaCard self-disclosed to the Enforcement Bureau (Bureau) that
it apparently had: (a) failed to timely notify the Commission of aproforma transfer of control of
international Section 214 authority during 2010 and (b) had not obtained Commission approval before
consummating a substantial transfer of control of domestic and international Section 214 authority during
2010.'2 In response, the Bureau launched an investigation.
6. Prior to October 23, 2010, Michael Choupak held an 88.88 percent membership interest
(8000 out of a total of 9000 Class A Units) in StanaCard and was its managing member.'3 On October 23,
2010, Mr. Choupak transferred half of that membership interest (44.44 percent or 4000 Class A Units) to
Anastasia Koroleva.14 Mr. Choupak retained a 44.44 percent membership interest in StanaCard and
5 See 47 C.F.R. 63.04, 63.18.
6 See 47 C.F.R. 63.03(d); 63.24(f).
7 47 C.F.R. 63.24(f).
8 47 C.F.R. 63.03(d)(1). Notification must be given of pro forma transfers of control of domestic Section 214
authority that are consummated as part of a bankruptcy proceeding. See 47 C.F.R. 63.03(d)(2).
9 See StanaCard, LLC, Joint International and Domestic Application for Consent to the Transfer of Control, Attach.
I at 5, WC Docket No. 12-18, IBFS File No. ITC-T/C-20120116-00003 (filed Jan. 16, 2012) (Joint
Domestic/International Sec. 214 Application); Domestic Section 214 Application Filed for the Transfer of Control of
StanaCard, LLC; Streamlined Pleading Cycle Established, WC Docket No. 12-18, Public Notice, 27 FCC Rcd 427
(Wireline Comp. Bur. 2012).
'o International Authorizations Granted, Public Notice, 25 FCC Rcd 1860 (Int. Bur. 2010).
" 47 C.F.R. 63.01; see also Section 402 Implementation Order, supra note 3.
'2 Letter from Cheng-yi Liu, Law Offices of Thomas K. Crowe, P.C., Counsel to StanaCard, LLC, to Robert
Krinsky, Attorney Advisor, Investigations and Hearings Div., FCC Enforcement Bureau (filed Jan. 27, 2012) (on
file in EB-12-IH-0076).
" See Joint Domestic/International Sec. 214 Application at 3; StanaCard, LLC, Notification of the Pro Forma
Transfer of Control of International Section 214 Authority, IBFS File No. ITC-T/C-2012021 5-00051 at 1, 3 (filed
Feb. 15, 2012) (StanaCard Pro Forma Int'I Sec. 214 Application).
4 See StanaCard Pro Forma Int 'I Sec. 214 Application at Attach. 1 (Answer to Question 13).
Federal Communications Commission
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United States. Federal Communications Commission. FCC Record, Volume 28, No. 1, Pages 1 to 975, January 2 - January 31, 2013, book, January 2013; Washington D.C.. (https://digital.library.unt.edu/ark:/67531/metadc171173/m1/98/: accessed July 23, 2019), University of North Texas Libraries, Digital Library, https://digital.library.unt.edu; crediting UNT Libraries Government Documents Department.