An FCC spokesperson says the commission is expected to send its network neutrality rules to the Office of Management Budget for Paperwork Reduction Act vetting "very soon," which also means it hasn't sent them yet.
The rules were adopted in December 2010, but because they cause new reporting requirements, those were put out separately for comment by the FCC, which has been vetting those comments since April.
The rules cannot be challenged in court until they are published in the Federal Register, which can't come until OMB has put them out for comment for 30 days and decided they do not create undue paperwork burdens.
They do not go into effect until 60 days after that publication, however, so it will likely be October at the earliest before they would take effect.
Republicans have complained that the FCC appeared to be delaying court or congressional challenges with the attenuated process, but a spokesperson for the chairman said back in April that "the Order quite simply is going through the normal process for clearing Paperwork Reduction Act requirements before being published in the Federal Register."
The National Cable & Telecommunications Association has argued that the FCC has significantly underestimated the time and money it will take to comply with the transparency and complaint procedures it adopted in its Open Internet order.
OMB is vetting the paperwork-collection requirements to make sure they do not run afoul of Congress's Paperwork Reduction Act mandate to keep bureaucratic tree-killing to a minimum. NCTA has asked for changes in those requirements, which could delay that effective date even more.