 either cost-of-service ratemaking or price caps. Retail rates often include a wide variety of specialized waivers and reflect a wide range of internal cross subsidies, through statewide rate averaging and through differential pricing of business and residential services. The fact that prices are not always set in a way that reflects cost within a single jurisdiction raises the possibility of arbitrage even within retail access. Wholesale access is typically based on retail rates less any avoided costs, such as marketing, billing, and collection. The fact that these rates are based on rates incorporating implicit cross subsidies again leaves wholesale access vulnerable to regulatory arbitrage. Further inefficiency may result from difficulties in determining precisely which retailing costs are avoided when another provider invokes wholesale access. Platform access rates vary depending on the nature of the complementary ser- vice being provided. Long-distance providers pay access charges that have histori- cally exceeded actual cost in order to allow long distance service to cross-subsidize local service. Although the FCC is in the process of reforming the access charge regime to provide access charges closer to cost, long-distance providers are required to pay into the universal service fund, whereas information service providers are not. The Regulation of Local Telephone Networks Unbundled access rates are calculated in a different manner. The statute requires that UNE access rates be "based on the cost (determined without reference to a rate-of-return or other rate-based proceeding) of providing the interconnection or network element" (47 U.S.C. § 252(d)(1)(A)(i)). The FCC implemented this requirement through TELRIC, which is based on the forward-looking incremen- tal costs of a hypothetical network providing service through the most efficient technology at the locations of the existing wire centers. Finally, interconnection access is governed by the reciprocal compensation provisions of the 1996 Act, which mand