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                                               FEDERAL COMMUNICATIONS COMMISSION
                     WASHINGTON, D.C. 20554
                                
                          July 1. 1987
                                
                                             IN REPLY REFER TO:
                                                   RAO Letter 7

Responsible Accounting Officers

Part 32, Uniform System of Accounts for Class A and Class B Carriers-
Questions and Answers

     Since the adoption of Part 32, we have had a number of requests for clarification of certain
aspects of the system. These inquiries were the topic of discussions at various meetings with
carriers, telephone associations, and other interested parties. We believe that the questions are
pertinent to the implementation of the new system and that a generally distributed list of these
questions along with the answers should give carriers a better understanding of the rules and ease
the transition to the new Part 32. These questions and answers are attached.

     This letter and the attachment are issued under Section 0.291 of the Commission's rules.
Applications for review under Section 1.115 of the Commission's rules must be filed within 30
days from the date indicated above (See Section 1.4(b)(4) of the Commission's rules).

     If you have any questions contact the Chief of the Accounting Systems Branch at 
(202) 418-0810.

                                   Sincerely,

                                   Clifford M. Rand
                                                                      Acting Chief,
                                                                      Accounting and Audits Division

Attachment                             Part 3 2
                    Uniform System of Accounts
                      Questions and Answers

1. Q.  How should carriers implement accounting for capital leases?

   A.  All leases of telephone plant which qualify as capital leases that are entered into on or
after January 1, 1988 should be recorded in Account 2681, Capital Leases, with the corresponding
liabilities recorded in Accounts 4060, Current Maturities-Capital Leases, and 4250, Obligations
Under Capital Leases, as appropriate. In those cases where the lease transfers ownership of the
property by the end of the lease term or the lease contains a bargain purchase option, amortization
shall be in a manner consistent with the carrier's normal depreciation policy for owned assets.

   Embedded leases qualifying as capital leases should be recorded in Account 2681 at their
original capital lease value, generally the present values of the minimum lease payments as
specified in Section 32.2681(a)(4). An amount representing the allowed accumulated amortization
will be recorded in Account 3410, Accumulated Amortization-Capitalized Leases. This amount
will be the difference between the periodic lease payments to January 1, 1988, and the interest
expense that would have been recorded had the lease been recorded as a capital lease since its
inception. The liability amount to be recorded in Account 4060 and Account 4250, as appropriate,
will be the net nook value of the capital leases. The net book value of the embedded lease will
then be amortized over the remaining life of the lease on a straight-line basis and the liability
reduced using the interest method.

2. Q.  How should carriers implement the interest method for the amortization of premiums
and discounts on long-term debt?

   A.  The interest method should be implemented prospectively on new debt issued on or
after January 1, 1988. Permission previously granted for the amortization of call premiums,
unamortized discounts or premiums, and other expenses will not be affected. In connection with
such amortizations, the Commission has before it at this writing a petition for rulemaking which
would make specific provision in Part 32 for requesting and granting approval to amortize to
future periods the call premiums, unamortized discounts or premiums, and other expenses
associated with refinancing transactions.

3. Q.  Since the Commission has not established a generally applicable standard for making
determinations of materiality, does this mean that every deviation from the system of accounts,
no matter how small, should be submitted for Commission review?

   A.  In CC Docket 84-469, and again in the Reconsideration Order in Docket 78-196, the
Commission reserved the right to make its own determination of materiality and declined to accept
the GAAP criteria or establish a generally applicable standard of its own. Since there is a
substantial difference between reserving the right to make a judgement and exercising it in every
case, neither order should be read as eliminating all management prerogatives. Both orders
presume the use of reasonable judgement by management which would be defensible in relation
to regulatory sensitivities, but reserve the Commission's regulatory right to reach a different
conclusion.  In those situations where there is a doubt, we expect that questions would be asked
in advance, just as they are in most cases today.

4. Q.  The new USOA provides accounts for jurisdictional differences.  How should
embedded jurisdictional differences be handled?

   A.  Embedded jurisdictional differences should be handled with a one time entry to a
subsidiary record category in Account 4550, Retained Earnings.

5.  Q.         To what extent is the matrix required for companies not subject to Part 43 reporting
requirements?

   A.  The general provision to maintain the expense matrix is found in Section 32.5999(f),
which requires that the expense matrix will be maintained by subsidiary record categories, as
appropriate to each account.  Regardless of the current reporting requirements under Part 43, all
carriers that are subject to Part 32 are expected to be able to produce summary data consistent with
the categories of the expense matrix. Reporting requirements based on the new Part 32, though
not prescribed yet, are likely to focus on details consistent with the matrix concept in Part 32.

6. Q.  Is it necessary under the expense matrix requirements to maintain general ledger
subaccounts or is it permissible to use other records to satisfy the requirements ?

   A.  Where the matrix applies to an account, as designated by Notation 1 in the account
listing in Section 32.5999(h), it is expected that subject carriers will maintain their accounting
systems so that the specified matrix information will be readily identifiable and available to the
Commission.  (The Notation 1 in the account listing was provided to distinguish those accounts
to which the matrix applies from those to which it does not apply; the notation applies across to
both Class A and Class B carriers.) And, as with all accounting requirements under Part 32, the
general expectation is that a suitable audit trail will exist so that the data may be verified.

   For Class A carriers it is expected that requirements for ready identifiability, availability,
and verifiability may necessitate the maintenance of general ledger subaccounts. Some Class B
carriers may find as well that maintenance of subsidiary record categories in the form of
subaccounts is necessary for the timely production of reliable matrix data. However, the general
expectation is that some Class B carriers will be able to provide the matrix data without the
maintenance of subaccounts. That is, where Class B carriers determine that records available will
enable them to readily produce reliable summary data anticipated by the matrix, such will be
sufficient. A criterion for using this procedure for a Class B carrier will be the ability to produce
the required data on a routine basis consistent with any periodic reporting requirements that may
be specified or on an ad hoc basis within a reasonably short period of time using available records
.
7. Q.  Where are the investment and expenses for special purpose computers, in contrast to
those classified as general purpose computers, accounted for?

   A.  The distinction intended in the USOA between general purpose computers and all
others is a functional one with reference primarily to the use of the computer within the telephone
company and not with reference to manufacturer design. A computer may be designed as a general
purpose computer but not be used functionally within the telephone company for applications
considered to be general purpose. In such cases, the computers would be considered special
purpose and should be classified according to their function.

   It is indicated in Section 32.2124(d) that computers, their associated peripheral devices, and
their initial operating system software associated with switching, network signaling, network
operations or other specific telecommunications plant shall be classified to the appropriate
switching, network signaling, network expense, or other plant account. This applies to personal
computers, as well as to mainframes, and to general purpose by design, as well as to single
purpose computers designed and programmed to specification. Several examples may be useful:
the processor for a digital electronic switch will be classified with the switch to Account 2212,
Digital Electronic Switching; a personal computer that interfaces with circuit equipment for the
purpose of testing such equipment will be classified to Account 2232, Circuit Equipment; and,
a computer that is used for the monitoring and regulation of a building temperature will be
classified to Account 2121, Buildings. A computer used for general and administrative purposes
(e.g., formulation of company policy and strategy, administration of payroll and disbursements,
and other such corporate Operations) shall be classified as general purpose computer, whether
used exclusively for one such operation or for several, and recorded in Account 2124.

   Computer expenses, other than related depreciation, shall be classified to the appropriate
plant specific expense account, that is, the expense account that "mirrors the plant account the
computer giving rise to the expense is recorded in.

8.  Q.         What is the expense/capitalization policy for software for network operations?

   A.  The capitalization policy for all software is the same whether the software is for general
purpose computers classified to Account 2124, General Purpose Computers, or to other plant in
service accounts dedicated to network operations: the original cost of initial operating system
software shall be classified to the same account as the associated hardware whether acquired
separately or in conjunction with the associated hardware. (Section 32.2000(i)). The disposition
of all other software (i.e., that which is not considered initial operating system software) shall be
determined by management and shall be in conformance with generally accepted accounting
principles at the time such determination is made. Currently, this could result in the expensing or
the capitalization of software costs, depending upon an evaluation of all relevant circumstances.
With respect to subsequent additions and modifications, the Docket 78-196 Report and Order
indicates, in conformance within general practice, that such costs will be expended, barring
exceptional circumstances.
   
   Expenses incurred in planning, developing, testing, implementing and maintaining data bases
and application systems for general purpose computers are to be recorded in Account 6724. This
is in contrast to the noncapitalizable expenditures for maintaining general purpose computers and
their operating system software which are classifiable to the plant specific account for general
purpose computers, Account 6124. The February 18, 1987, Memorandum Opinion and Order in
CC Docket 78-196 maintains the distinction of Accounts 6724 and 6124 for recording the
respective costs of maintaining data bases and application systems as contrasted with those for
maintaining general purpose computers and their operating systems. However, certain remarks
need further clarification to be more explanatory of the workings of these accounts in conjunction
with data processing activities which directly benefit other functions (as illustrated by the
assignment of data processing costs to Account 6623, Customer Services). The following is
offered as a clarifying interpretation of the assignment of various information management and
data processing costs related to customer billing:

   The costs for the input and output of data associated with the processing of bills,    whether
on service center computers or on computers used exclusively for billing purposes, are chargeable
to Account 6623, Customer Services.

   Any general purpose computer used in the billing function, regardless of size and amount
of time dedicated to billing, is to be recorded in Account 2124, General Purpose Computers. The
costs for maintaining these general purpose computers and their operating system software used
for billing customer accounts are to be recorded in Account 6124, General Purpose Computer
Expense.

   Where a general purpose computer utilized in the billing function is large, a computer
operator may be required to run the computer. Where such individuals are skilled in the operations
of computers as opposed to any aspect of the billing process or the process of merely updating or
otherwise manipulating data contained in the database, their time is chargeable to Account 6124.
Generally such individuals will be in the information management department and not the billing
department. Regardless, their time is chargeable to Account 6124. On the other hand, an
individual within the billing department who works at a computer--even full time--doing a billing
function would not usually charge time to General Purpose Computers but to Account 6623.
Likewise, the time for a service center employee who works full time or part time at a computer
doing a billing function (e.g., updating billing data) would charge time to Account 6623, either
directly or by the appropriate means established for charging service center work to user groups.

   The costs incurred in planning, developing, testing, implementing, and maintaining the data
bases and the applications systems for billing customer accounts are to be recorded in Account
6724, Information Management.  Database maintenance, however, does not include the input and
update of billing data and accounts receivable and the use of the outputs. Such maintenance of data
base records (i.e., billing records) would be charged to Account 6623.

In brief, then. expended software is recorded as follows:

   Associated with General Purpose Computers
   Operating system (other than initial)     Account 6124
   Other software (applications)        Account 6724

   Associated with Network Operations (e.g.. Switching)
   All software other than initial operating      Plant Specific Exp.
                                   (e.g., Account 6212, Digital Electronic)

   In the Report and Order released May 15, 1986, it was indicated that "in the case of COE
software the initial right to use fee or operating system shall be classified with the central office
equipment to which it predominantly relates." However, a special problem is associated with
network operations computers in that many network operations computers are special purpose by
design as well as by function. As a result, the distinction between the operating system and the
application system is not always clearly defined. Telephone's Dictionary (First Edition: June,
1982) defines "operating system" as, "software that controls the management and execution of
programs." On the other hand, an "application package" is defined as, "a computer-program
designed to perform a particular type of work." Such packages are usually tailored to specified
needs, such as, order processing, billing, inventory accounting, and data base management.
Carriers should use these definitions in distinguishing between operating systems and application
systems.

9. Q.  What account should be charged with the cost for portable Uninterruptible Power
Systems which are directly attached to microcomputers and which safeguard the micro equipment
from electric outages and wattage changes? And, is the classification for this equipment any
different under Part 32 compared with Part 31?

   A.  The equipment described would be considered to be part of the associated equipment
for the microcomputers. As such, they should be charged to the same account as the
microcomputers. Under Part 32, such a microcomputer may be classified to any of a number of
accounts depending on the functional use of the microcomputer.

   The basic principle of considering the system to be part of the equipment associated 
with the computer and classifying it accordingly would not be any different under Part 31.
However, the classification of any given piece of uninterruptible power equipment might be
somewhat different under Part 32 depending on the new classification, if applicable, of the
associated computer.

10.    Q.      Is depreciation on special purpose equipment dedicated to construction a proper direct
charge to construction?

   A.  Depreciation of vehicles will not be charged to construction. However, when a
construction job requires the purchase of special machines, the cost thereof, less the appraised or
salvage value at the time of release from the job, shall be included in the cost of construction as
provided in Sect ion 32.2000(c)(2)(ix).

11.    Q.      What is the process to obtain permission to use clearing accounts and what kind of
notification is expected?

   A.  Permission to establish and use additional clearing accounts should be obtained from
the Chief, Accounting and Audits Division. The request should specify the account being
established, the nature of the expenses being included in it, and the necessity for the account. The
request should demonstrate that the use of the additional account would yield substantially the
same or more accurate results.

12.    Q.      The industry is interpreting Part 32 to allow direct engineering expenses to be charged
to Plant Specific Operations Expense accounts. What was the intention of establishing Account
6534, Plant Operations Administration Expense, and Account 6535, Engineering Expense?

   A.  Certain direct engineering costs and plant administration costs are directly chargeable
to Plant Operations Expense accounts (Accounts 6110 through 6441). Included are costs resulting
from activities, such as testing, inspecting, reporting on plant condition, performing routine work
to prevent trouble, rearranging and changing the location of plant not retired, replacing items of
plant other than retirement units, repairing material for reuse, restoring the condition of damaged
plant, and inspecting repairs. The direct labor and supervision immediate or first-level associated
with these activities, as well as the training to perform these activities, are chargeable to Plant
Operations Expense accounts. (See Section 32.5999(b)(3).) Direct engineering and plant
administration costs are directly chargeable to construction, also. However, the amounts recorded
in Accounts 6534 and 6535 are generally those which are not directly chargeable to Plant Specific
Expense Accounts since they encompass a range of activities beyond what will be classified in a
single account. The subject accounts have been provided, therefore, to collect the various indirect
costs associated with these broader based activities. The end-of-period balances in these accounts
are not to be cleared to Plant Operations Expense accounts, but appropriate clearance should be
made to construction as required in Section 32.2000(c)(xiii) and provided for in Section
32.5999(f)(5).
13.    Q.      Are clearances to Plant Nonspecific accounts used in any situations?

   A.  With respect to those accounts for which clearing provisions have been specified in Part
32, clearance to Plant Nonspecific accounts has not been contemplated. The requirements in
Section 32.5999(f)(5) indicate that for these accounts, the clearance subsidiary record category
is to include amounts transferred only to Construction or to other Plant Specific Operations
Expense accounts. Accordingly, clearance of any of the residual to Plant Nonspecific accounts
would require notification and approval of the Commission.

14.    Q.      What is the suggested clearing method for Account 6512, Provisioning; Account 6534,
Plant Operations Administration; Account 6535, Engineering Expense?

   A.  The requirements for Accounts 6534 and 6535 clearly specify that clearances from
these accounts to construction shall be made on the basis of direct labor hours. It is expected that
the allocation to construction of a portion of the total costs in these accounts based on a direct
labor hour ratio will provide a methodology that can be applied on an industry-wide basis,
establishing uniformity within the industry and a capitalization policy that is fair. The portion to
be cleared is the cost of indirect supervision and support related to construction as determined by
a ratio of direct labor hours of engineering craft/occupational forces or plant craft/occupational
forces charged to construction to, respectively, the total of direct labor hours of engineering
craft/occupational forces or plant craft/occupational forces for the period. The balance remaining
in the accounts after clearance, for the most part, will include the indirect supervision and support
associated with maintenance activities.

   Use of any other basis for clearing amounts from Accounts 6534 and 6535 to cost of
construction would require the filing of a request for waiver and approval of the Commission. Any
such waiver requests will require a strong showing that an alternative basis would more fairly
allocate costs of construction.

   Under Part 32, all administrative costs associated with the acquisition of materials and
supplies are recorded in Account 6726, Procurement, and those recorded in Account 6512,
Provisioning Expense include only non-administrative costs associated with the outlay made to
acquire goods and to store them and get them ready for use in construction or in
telecommunications operations. Thus, the costs accumulated in Account 6512 are only those
which, when identifiable, are generally inventoriable as the indirect cost of the material and
supplies with which they are associated. The instructions for Account 6512 require these costs to
be cleared to both cost of construction and/or to plant specific operations expense accounts by
adding a suitable loading charge to the cost of material and supplies. And, Section
32.2000(c)(2)(iii) requires that an equitable portion be included in the cost of materials and
supplies. Since no specific clearing basis is specified, it is expected that a systematic and rational
method shall be developed and applied consistently by carriers to associate the accumulated costs
with inventories of materials and supplies and/or with materials and supplies used in construction
or in telecommunications operations of the period. The amount left in Account 6512 should
represent the amounts which relate to the plant nonspecific, customer operations and corporate
operations expense account groups.

15.    Q.      What is the purpose of Account 5003, Cellular Mobile Revenue?

   A.  While cellular mobile service is not tariffed on the federal level, some state tariffs still
apply. Account 5003 has been provided to accommodate regulation of this item on a state level.

16.    Q.      What account is to be used to record the revenues from one-time and monthly charges
associated with exchange services provided to pay/coinless telephones operated by others?

   A.  Account 5010, Public Telephone Revenue, includes message revenue and other revenue
derived from public and semi-public telephone services (except the billed or guaranteed portion
of semi-public services which go to Account 5001, Basic Area Revenue). In addition to the
revenue derived from the provision of exchange services provided to pay/coinless telephones, this
account should also include the revenue from one-time and monthly charges associated with
exchange services provided to pay/coinless telephones operated by others, such as select-a-carrier,
interexchange carrier-operated public exchange, credit card coinless, and customer-owned public
exchanges.  However, one-time and monthly charges derived from central office related service
connection and termination charges should be charged to Account 5060, Other Local Exchange
Revenue.

17.    Q.      Is Account 5050, Customer Premises Revenue, used only in states that require that
CPE be offered on a tariffed basis?

   A.  Account 5050 is used primarily for items which are not tariffed on the federal level but
which remain tariffed for state regulatory purposes. However, there are exceptions to this general
application, the most significant of which is that it is to be used for revenues associated with
equipment for the handicapped which is also tariffed at the federal level.

18.    Q.      What constitutes the construction start date for purposes of determining short-term vs.
long-term construction work in progress?

   A.  The costs of any preliminary surveys, plans, investigations, etc., made to determine
the feasibility of a project are charged to Account 1439, Deferred Charges. These amounts remain
classified as deferred charges until approval to commence physical construction of the project has
been given by an authorized company official, and, thereupon, a signed work order is prepared.
At this point, the project is considered to be under construction and the preliminary costs are
transferred to Account 2003, Telecommunications Plant Under Construction--Short Term, or
Account 2004, Telecommunications Plant Under Construction--Long Term, as applicable.

19.    Q.      What is the appropriate expense account for the amortization of extraordinary
retirements?

   A.  Such amounts are to be distributed to the depreciation expense accounts. The
instructions for depreciation accounting specify that upon direction or approval of the
Commission, the unprovided for loss of service value of depreciable assets shall be credited to
Account 3100, Accumulated Depreciation, and charged to Account 1438, Deferred Maintenance
and Retirements. Such amounts are to be distributed from Account 1438 to Account 6561,
Depreciation Expense-Telecommunications Plant in Service, or to Account 6562, Depreciation
Expense-Property Held for Future Telecommunications Use, over the period that the Commission
approves or directs. (32.2000(g)(5).)

20.    Q.      Would maintenance of major office equipment dedicated for use in Customer Services
or Corporate Operations be included in Account 6123, Office Equipment Expense, or the
appropriate function?

   A.  The cost of maintaining office equipment, as with all equipment in general, would be
charged to the plant specific expense account that "mirrors" the plant account in which the
equipment being maintained is recorded. Thus, if the equipment being maintained is in the office
equipment account, Account 2123, the maintenance expense will be charged to Account 6123.

21.    Q.      In many cases, the network interface and protector are physically separate from each
other. The wire or cable between these two items is currently charged to Account 605 and remains
on the regulated books. As long as a company continues to provide wiring between the network
interface device and the protector (e.g., network terminating wire), instructions are needed in Part
32 for recording these expenses. What is the proper account(s) to record the cost of this activity?

   A.  The cost for this activity is chargeable to Account 6362, Other Terminal Equipment
Expense.

22.    Q.      In cases where word processing centers or other similar support service centers are a
part of the organization, is Account 6728, Other General Office, appropriate?

   A.  Account 6728 is to include cost of support services only when the costs have not been
provided for elsewhere in the USOA and cannot be reasonably and equitably assigned to the
activities supported. Word processing center costs and other such office support activities are
properly chargeable to specific functional accounts, primarily to the activities in the Customer
Operations Expense and the Corporate Operations Expense groups (Accounts 6610 through 6727),
rather than to Account 6728. Such costs are usual to the activities described by the accounts in
these groups, and there is, therefore, provision for such costs in these accounts. This is in
contrast, for instance, with food service centers which provide general support but do not
comprise an activity normally performed in other functional areas and, therefore, are not properly
chargeable to other accounts.

23.    Q.      What accounts should be used for the various types of insurance (as per list shown in
answer)?

   A.  Except for those insurance costs which are chargeable to construction (see Section
32.2000(c)(xi)), insurance costs are to be recorded in an appropriate expense account subject to
the matrix or in Account 6728. Where the insurance expense is related to corporate or commercial
operations, or requires arbitrary allocation, or is not otherwise relatable to a plant specific expense
area, it is chargeable to Account 6728. The following may be helpful in providing some
guidance-by-example for the classification of the various insurance charges possible.

*Fire-Warehouse               Subject to the matrix: Charges for building
                         coverage should be made to Account 6121, Land and
                         Building Expenses, and charges for contents coverage
                         will generally be made to Account 6512, Provisioning.
   Office                     Subject to the matrix: Charges for office buildings
                         should be made to Account 6121; office contents
                         should be charged primarily to Accounts 6122, 6123,
                         and 6124.
   Garages               Subject to the matrix: Charges for garage buildings
                         should be made to Account 6121; charges for contents
                         coverage should generally be made to Account 6115,
                         Garage Work Equipment Expense.
   COE                   Subject to the matrix: Charges should be made to the
                         appropriate central office equipment account
                         (Accounts 6210 through 6232) as determined by the
                         asset classification.
   Computers             Subject to the matrix: Charges for the coverage on
                         computers should be made to the expense account that
                         mirrors the asset account in which the computer is
                         recorded.
*General Liability            General Liability insurance takes several forms. Each
                         form, however, usually combines coverage for      
                              exposures derived from the many activities of the
                         enterprise, as well as the totality of its assets--unless such 
                         activities or assets are more appropriately covered under 
                         another form of coverage.  Considering the general nature 
                         of such coverage, it is appropriately included in 
                         Account  6728.

*Business                     While the various tangible assets of the company may give 
                           Interruption           rise to the exposure for business interruption losses, the
                         asset at risk is, in effect, the company's gross earnings. 
                         There is, of course, no provision for this asset in the
                         accounts, and, therefore, this type of insurance is not
                         otherwise provided for, except in Account 6728.
 

*Vehicle Damage               Subject to the matrix, primarily in Accounts 6112, 6113, 
                         and 6114.

                              *Vehicle Liability            While this coverage protects all assets of the company from
                              impairment through third party claims, nevertheless, the risk
                              of loss is so exclusively relatable to the assets giving rise to
                              the exposure that the  charge for such insurance is properly
                              made to the mirror expense accounts for such
                              assets--primarily Accounts 6112, 6113, and 6114.

*Boiler & Machinery      Boiler & Machinery coverage usually combines several 
                         coverages, including hazard protection for the assets 
                         involved, liability coverage, and business interruption 
                         coverage, as well as provides an inspection service for 
                         the equipment involved.  As with vehicle liability, the 
                                                  risk of loss is uniquely associated with the assets giving
                         rise to the exposure that the charges for all of the boiler
                         and machinery coverages are properly made to the mirror
                         expense account for the equipment--generally Account
                         6121, Land and Building Expenses.

24.    Q.      Is a new Form M format available?

   A.  No. The development of a new Form M is underway in the context of a broad
effort to define overall Common Carrier Bureau data needs and reporting requirements.

25.    Q.      What is the status of the FCC's review of capital to expense shift submissions?

   A.  A report that includes the results of the review of capital to expense shifts was sent
to the Commission on April 15, 1987, titled ,"Accounting and Audits Division Report on
Telephone Industry Depreciation, Tax and Capital/Expense Policy.  Copies are available from
International Transcription Services, Inc., (202) 857-3800.

26.    Q.      What is the status of the Item Lists and Retirement Units Lists?

   A.  A "Responsible Accounting Officer'' letter (RAO Letter 3) containing the Item
Lists was distributed on January 15, 1987. Some modifications to the lists are likely as a result
of comments received. Revised lists will be made available as soon as possible.

   All fully subject carriers will be required to submit Retirement Unit lists for approval
before January 1, 1988. An official request for this submission will be sent to responsible
accounting officers soon.

27.    Q.      In CC Docket 86-111, a requirement was made prescribing separate subaccounts for
each nonregulated revenue item recorded in Account 7991, Other Nonregulated Revenues. Did
the Commission mean these to be subsidiary record categories, and will an erratum be issued
to reference subsidiary record categories ?

   A.  The intent was to prescribe subsidiary record categories.  This will be referenced as
perfecting changes are made to Part X.