Today the FCC released a Notice of Apparent Liability (“NAL”) that has been issued to Budget PrePay and which proposes a fine of $3.7 million for allegedly requesting support for ineligible Lifeline subscribers.  This announcement follows three other rounds of NALs: five issued on September 30 (proposing $14.4 million in fines) three issued on November 1 (proposing almost $33 million in fines), and three issued on December 12, 2013 (proposing $44 million in fines). Budget will have 30 days to respond or, alternatively, pay the proposed fines.  This brings the total amount of proposed fines against Lifeline ETCs to around $94 million in the past 6 months.  Many of the cited ETCs have engaged with FCC staff, including TracFone, which filed a summary of a meeting in which the company asserted that its overall rate of alleged duplicates was a tiny 0.03% of its customer base and that approximately 21% of the subscribers at issue were incorrectly flagged by the Enforcement Bureau as duplicates.  Nearly all the other ETCs that have received NALs, including Budget, appear to have similarly small rates of alleged duplicates.