Click here for Adobe Acrobat version
Click here for Microsoft Word version

******************************************************** 
                      NOTICE
********************************************************

This document was converted from Microsoft Word.

Content from the original version of the document such as
headers, footers, footnotes, endnotes, graphics, and page numbers
will not show up in this text version.

All text attributes such as bold, italic, underlining, etc. from the
original document will not show up in this text version.

Features of the original document layout such as
columns, tables, line and letter spacing, pagination, and margins
will not be preserved in the text version.

If you need the complete document, download the
Microsoft Word or Adobe Acrobat version.

*****************************************************************



                                   Before the

                       Federal Communications Commission

                             Washington, D.C. 20554


                                         )                                
                                                                          
                                         )                                
     In the Matter of                        File No.: EB-10-TC-478       
                                         )                                
     National Employee Benefits Group        NAL/Acct. No.: 201232170005  
                                         )                                
     Apparent Liability for Forfeiture       FRN: 0021538509              
                                         )                                
                                                                          
                                         )                                


                  NOTICE OF APPARENT LIABILITY FOR FORFEITURE

   Adopted: February 28, 2012 Released: February 29, 2012

   By the Commission:

   I. INTRODUCTION

    1. In this Notice of Apparent Liability for Forfeiture (NAL), we find
       that National Employee Benefits Group  apparently willfully and
       repeatedly violated section 227(b)(1)(C) of the Communications Act of
       1934, as amended (the Communications Act or Act), and section
       64.1200(a)(3) of the Commission's rules, by sending 97 unsolicited
       advertisements, or "junk faxes," to the telephone facsimile machines
       of 79 consumers. Based on the facts and circumstances surrounding
       these apparent violations, we find that National Employee Benefits
       Group is apparently liable for a forfeiture in the amount of $603,000.
        

   II. BACKGROUND

    2. The Telephone Consumer Protection Act of 1991 (TCPA) was enacted by
       Congress to address problems of abusive telemarketing, including junk
       faxes. Unsolicited faxes often impose unwanted burdens on the called
       party, including costs of paper and ink, and making fax machines
       unavailable for legitimate business messages. Section 227(b)(1)(C) of
       the Act thus makes it "unlawful for any person within the United
       States, or any person outside the United States if the recipient is
       within the United States . . . to use any telephone facsimile machine,
       computer, or other device to send, to a telephone facsimile machine,
       an unsolicited advertisement...."

    3. On October 22, 2010, in response to a consumer complaint alleging that
       National Employee Benefits Group had faxed an unsolicited
       advertisement, the Enforcement Bureau (Bureau) issued a citation to
       National Employee Benefits Group pursuant to section 503(b)(5) of the
       Act. The Bureau cited National Employee Benefits Group for using a
       telephone facsimile machine, computer, or other device, to send an
       unsolicited advertisement for financial services to a telephone
       facsimile machine in violation of section 227(b)(1)(C) of the Act and
       section 64.1200(a)(3) of the Commission's rules. The citation informed
       National Employee Benefits Group that within 30 days of the date of
       the citation, it could either request an interview with Commission
       staff, or provide a written statement responding to the citation.
       National Employee Benefits Group did not respond.

    4. Despite the citation's warning that subsequent violations could result
       in the imposition of monetary forfeitures, we have received additional
       consumer complaints indicating that National Employee Benefits Group
       continued to send unsolicited facsimiles after the date of the
       citation.  This NAL  is based on complaints filed by 79 consumers
       establishing that National Employee Benefits Group continued to send
       97 unsolicited advertisements to telephone facsimile machines between
       March 1, 2011 and August 24, 2011.

   III. DISCUSSION

          A. Apparent Violations of Section 227(b)(1)(C) of the Act and the
             Commission's Rules Restricting Unsolicited Facsimile
             Advertisements

    5. Each of the consumers listed in the Appendix has provided evidence
       that National Employee Benefits Group used a telephone facsimile
       machine, computer, or other device to send the consumer at least one
       unsolicited advertisement. The facsimile transmissions at issue
       advertise financial services. The faxes therefore fall within the
       definition of an "unsolicited advertisement." Further, according to
       the complaints, none of the consumers had an "established business
       relationship" with National Employee Benefits Group, which would have
       authorized the company to send the faxes to the consumer, and none of
       the complainants gave National Employee Benefits Group permission to
       send the facsimile transmissions. Based on the record before us, we
       conclude that National Employee Benefits Group apparently violated
       section 227(b)(1)(C) of the Act and section 64.1200(a)(3) of the
       Commission's rules by sending 97 unsolicited advertisements to 79
       consumers' facsimile machines.

     A. Proposed Forfeiture

    6. After we have first issued a citation to an entity, as we have in this
       case, section 503(b) of the Act authorizes the Commission to propose a
       forfeiture for each subsequent violation of the Act, or of any rule,
       regulation, or order issued by the Commission under the Act. Section
       503(b)(2)(E) mandates that, "[i]n determining the amount of such a
       forfeiture penalty, the Commission or its designee shall take into
       account the nature, circumstances, extent, and gravity of the
       violation and, with respect to the violator, the degree of
       culpability, any history of prior offenses, ability to pay, and such
       other matters as justice may require." Our forfeiture guidelines set
       forth the base amount for penalties for certain kinds of violations,
       and identify criteria, consistent with the section 503(b)(2)(E)
       factors, that may influence whether we adjust the base amount downward
       or upward. For example, we may adjust a penalty upward for
       "[e]gregious misconduct," an "[i]ntentional violation," or where the
       subject of an enforcement action has engaged in "[p]rior violations of
       any FCC requirements" or a "[r]epeated or continuous violation."
       Currently, the maximum penalty that the Commission may impose against
       an entity such as National Employee Benefits Group is $16,000 per
       violation.

    7. The Commission has generally considered $4,500 per unsolicited fax
       advertisement to be an appropriate base amount for violating the
       prohibition against sending them. In addition, where the consumer
       requests that the company stop sending facsimile messages, and the
       company continues to do so, the Commission has previously considered
       $10,000 per unsolicited fax advertisement the appropriate forfeiture
       for such egregious violations. Consistent with this approach, we apply
       the $4,500 base forfeiture to 94 of the apparent violations at issue
       in this NAL and a $10,000 forfeiture for three of the apparent
       violations in this NAL where the consumer received a facsimile from
       National Employee Benefits Group after specifically requesting that
       National Employee Benefits Group cease sending them. Based on the
       application of these standards, National Employee Benefits Group is
       apparently liable for a base forfeiture of $453,000.

    8. Recently, we have begun to impose upward adjustments for multiple,
       repeated violations of our junk fax rules. The amount of these upward
       adjustments has varied according to the number of violations at issue,
       and has ranged from $50,000 (40 violations) to $150,000 (approximately
       100 violations). Given that this case also involves approximately 100
       violations, we propose to apply a $150,000 upward adjustment, for a
       total proposed forfeiture of $603,000. ($453,000 + $150,000 =
       $603,000) As we explained in the prior case where we proposed a
       $150,000 upward adjustment against an entity that had engaged in a
       total of over 100 violations, the magnitude of this adjustment is
       based on the fact that "[a]ll of the apparent violations, except those
       that formed the basis of the original citation, occurred after the
       Bureau first warned [the company] that its conduct violated the
       law.... The penalty that we proposed must take into account, in the
       language of section 503(b)(2)(E), this `degree of culpability,' and
       `history of prior offenses,' and in the language of the forfeiture
       guidelines, such `intentional misconduct' and `prior violations of ...
       FCC requirements.'" This reasoning is equally applicable here.

   IV. CONCLUSION

    9. We have determined that National Employee Benefits Group apparently
       violated section 227(b)(1)(C) of the Act and section 64.1200(a)(3) of
       the Commission's rules, by using a telephone facsimile machine,
       computer, or other device to send 97 unsolicited advertisements to the
       79 consumers identified in the Appendix. We have further determined
       that National Employee Benefits Group is apparently liable for a
       forfeiture in the amount of $603,000.

   V. ORDERING CLAUSES

   10. Accordingly, IT IS ORDERED, pursuant to section 503(b) of the
       Communications Act of 1934, as amended, 47 U.S.C. S: 503(b), and
       section 1.80 of the Commission's rules, 47 C.F.R. S: 1.80, that
       National Employee Benefits Group is hereby NOTIFIED of its APPARENT
       LIABILITY FOR A FORFEITURE in the amount of $603,000 for willful and
       repeated violations of section 227(b)(1)(C) of the Communications Act,
       47 U.S.C. S: 227(b)(1)(C), and section 64.1200(a)(3) of the
       Commission's rules, 47 C.F.R. S: 64.1200(a)(3).

   11. IT IS FURTHER ORDERED THAT, pursuant to section 1.80 of the
       Commission's rules, within thirty (30) calendar days of the release
       date of this Notice of Apparent Liability for Forfeiture, National
       Employee Benefits Group SHALL PAY the full amount of the proposed
       forfeiture or SHALL FILE a written statement seeking reduction or
       cancellation of the proposed forfeiture.

   12. Payment of the forfeiture must be made by check or similar instrument,
       payable to the order of the Federal Communications Commission. The
       payment must include the NAL/Account Number and FRN referenced above.
       Payment by check or money order may be mailed to Federal
       Communications Commission, P.O. Box 979088, St. Louis, MO 63197-9000.
       Payment by overnight mail may be sent to U.S. Bank - Government
       Lockbox #979088, SL-MO-C2-GL, 1005 Convention Plaza, St. Louis, MO
       63101. Payment by wire transfer may be made to ABA Number 021030004,
       receiving bank TREAS/NYC, and account number 27000001. For payment by
       credit card, an FCC Form 159 (Remittance Advice) must be submitted.
        When completing the FCC Form 159, enter the NAL/Account number in
       block number 23A (call sign/other ID), and enter the letters "FORF" in
       block number 24A (payment type code). National Employee Benefits Group
       shall also send electronic notification on the date said payment is
       made to Johnny.Drake@fcc.gov. Requests for full payment under an
       installment plan should be sent to: Chief Financial Officer --
       Financial Operations, 445 12th Street, SW, Room 1-A625, Washington,
       D.C.  20554.   Please contact the Financial Operations Group Help Desk
       at 1-877-480-3201 or Email: ARINQUIRIES@fcc.gov with any questions
       regarding payment procedures.

   13. The response, if any, must be mailed both to: Marlene H. Dortch,
       Secretary, Federal Communications Commission, 445 12th Street, SW,
       Washington, DC 20554, ATTN: Enforcement Bureau - Telecommunications
       Consumers Division; and to Richard A. Hindman, Chief,
       Telecommunications Consumers Division, Enforcement Bureau, Federal
       Communications Commission, 445 12th Street, SW, Washington, DC 20554,
       and must include the NAL/Acct. No. referenced in the caption.
       Documents sent by overnight mail (other than United States Postal
       Service Express Mail) must be addressed to: Marlene H. Dortch,
       Secretary, Federal Communications Commission, Office of the Secretary,
       9300 East Hampton Drive, Capitol Heights, MD 20743. Hand or
       messenger-delivered mail should be directed, without envelopes, to
       Marlene H. Dortch, Secretary, Federal Communications Commission,
       Office of the Secretary, 445 12th Street, SW, Washington, DC 20554
       (deliveries accepted Monday through Friday 8:00 a.m. to 7:00 p.m.
       only). See www.fcc.gov/osec/guidelines.html for further instructions
       on FCC filing addresses.

   14. The Commission will not consider reducing or canceling a forfeiture in
       response to a claim of inability to pay unless the petitioner submits:
       (1) federal tax returns for the most recent three-year period; (2)
       financial statements prepared according to generally accepted
       accounting practices; or (3) some other reliable and objective
       documentation that accurately reflects the petitioner's current
       financial status. Any claim of inability to pay must specifically
       identify the basis for the claim by reference to the financial
       documentation submitted.

   15. IT IS FURTHER ORDERED that a copy of this Notice of Apparent Liability
       for Forfeiture shall be sent by Certified Mail Return Receipt
       Requested and First Class mail to National Employee Benefits Group,
       Attn: Tim Gibbons, President, 795 Folsom Street, 1st Floor, San
       Francisco, CA 94107; and National Employee Benefits Group, Attn: Tim
       Gibbons, President, 1560 Youd Road, Winton, CA 95388.

   FEDERAL COMMUNICATIONS COMMISSION

   Marlene H. Dortch

   Secretary

                                    APPENDIX

                   Complainants and Apparent Violation Dates


     Complainant received facsimile               Violation Date(s)          
     solicitations                                                           

     Armstrong, A.                                3/1/11                     

     Barrett, S.                                  6/21/11                    

     Berman, A.                                   3/2/11                     

     Beck, J.                                     5/10/11                    

     Becker, K.                                   6/15/11                    

     Bell, T.                                     5/24/11                    

     Benefield, R.                                5/23/11, 6/20/11           

     Botnick, B.                                  5/31/11                    

     Can, V.                                      7/18/11                    

     Cantrell, P.                                 6/21/11                    

     Chase, D.                                    3/16/11                    

     Chafey, T.                                   3/4/11                     

     Cheifetz, A.                                 3/2/11                     

     Coleman, M.                                  3/7/11                     

     Cooper, J.                                   7/19/11                    

     Copperman, H.                                3/5/11                     

     Dean, R.                                     4/18/11                    

     DeLong, J.                                   3/1/11, 4/19/11, 7/25/11,  
                                                  8/24/11                    

     Eliopoulos, S.                               4/25/11                    

     Field, D.                                    5/9/11                     

     Fletcher, D.                                 5/31/11                    

     Gelbard, A.                                  7/18/11                    

     Graham, S.                                   7/18/11                    

     Grout, S.                                    3/23/11                    

     Gubnitsky, M.                                3/23/11, 4/11/11           

     Hartglass, L.                                3/2/11                     

     Haskell, J.                                  4/25/11                    

     Heddy, R.                                    6/1/11                     

     Higgins, D.                                  6/16/11                    

     Highcove, J.                                 3/8/11, 4/21/11, 5/31/11   

     Hudkins, J.                                  4/19/11, 5/26/11, 7/25/11  

     Humphreys, D.                                6/15/11                    

     Jensen, G.                                   3/28/11, 6/3/11            

     Johnson, W.                                  5/16/11                    

     Ko, A.                                       5/9/11                     

     Korver, A.                                   3/23/11                    

     Kressman, D.                                 6/9/11                     

     Kunin, M.                                    5/11/11                    

     Lavado, H.                                   3/4/11, 6/27/11            

     Longo, R.                                    3/16/11, 6/9/11            

     MacIntyre, A.                                4/27/11, 8/2/11            

     McCarthy, T.                                 3/9/11                     

     McCracken, A.                                3/16/11                    

     McFate, P.                                   3/28/11                    

     Montgomery, R.                               6/30/11                    

     Newberg, B.                                  4/28/11, 6/14/11, 8/8/11   

     Ogle, J.                                     6/27/11                    

     Oliveira, B.                                 6/21/11                    

     Orlaski, S.                                  5/9/11                     

     Ostroff, E.                                  5/12/11                    

     Page, B.                                     3/4/11, 5/16/11            

     Pappas, H.                                   7/18/11                    

     Peoples, L.                                  4/18/11, 6/1/11            

     Rader, M.                                    6/14/11                    

     Richard, R.                                  4/11/11                    

     Robbins, V.                                  6/1/11                     

     Russell, B.                                  6/30/11                    

     Schaffer, M.                                 3/8/11                     

     Schroeder, J.                                5/24/11                    

     Sosnowitz, B.                                5/12/11                    

     Sherman, M.                                  3/2/11, 6/20/11            

     Smith, W.                                    3/4/11                     

     Stainbrook, C. (Premium Industrial Parts)    3/21/11                    

     Swearingen, V.                               3/16/11                    

     Tanenbaum, M.                                5/23/11                    

     Toglia, P.                                   3/31/11                    

     Turner, A.                                   6/6/11                     

     Traves, S.                                   5/26/11                    

     Walker, S.                                   7/19/11                    

     Walter, B.                                   7/21/11                    

     Williams, G.                                 9/22/11                    

     Wismer, R.                                   3/16/11                    

     Woods, A.                                    6/3/11                     

     Worthington, B.                              8/3/11                     

     Zelik, J.                                    4/5/11                     

     Zieten, P.                                   3/2/11                     



     Complainant received facsimile solicitations after   Violation Date(s)  
     requesting no more be sent                                              

     Cho, S.                                              7/13/11            

     Izumi, J.                                            7/25/11            

     Jacobs, L.                                           5/23/11            


   According to publicly available information, Tim Gibbons is listed as the
   president and contact person of National Employee Benefits Group.  All
   references in this NAL to National Employee Benefits Group also encompass
   the foregoing individual, as well as the corporate entity itself. 
   Moreover, we note that National Employee Benefits Group appears to be
   related to Benchmark Mortgage, in that Benchmark Mortgage manages and
   oversees the financial programs and portfolios of the National Employee
   Benefits Group, and both entities share Mr. Gibbons as a point of contact,
   as well as the same physical address.  See The Employee Benefits Group:
   Important Notice to All Homeowners, Benchmarkmortgagebank.com,
   http://www.benchmarkmortgagebank.com/national_employee_benefits_group
   (last visited Jan. 23, 2012).

   See  47 U.S.C. S: 227(b)(1)(C); 47 C.F.R. S: 64.1200(a)(3). See also 
   Rules and Regulations Implementing the Telephone Consumer Protection Act
   of 1991, Report and  Order and Third Order on Reconsideration, 21 FCC Rcd
   3787 (2006).

   Telephone Consumer Protection Act of 1991, Pub. L. No. 102-243, 105 Stat.
   2394 (1991) (codified at 47 U.S.C. S: 227). See also Junk Fax Prevention
   Act of 2005, Pub. L. No. 109-21, 119 Stat. 359 (2005).

   47 U.S.C. S: 227(b)(1)(C). The prohibition is subject to certain
   exceptions, such as if the sender has an "established business
   relationship" (EBR) with the recipient, and the sender obtained the
   facsimile number from the recipient through voluntary communication in the
   context of an EBR, or from a directory, advertisement, or website on which
   the recipient voluntarily made its facsimile number available for public
   distribution. In addition, the unsolicited ad must notify the recipient of
   how to opt out of receiving future such ads, subject to certain
   requirements. The Commission has adopted implementing rules. See 47 C.F.R.
   S: 64.1200(a)(3).

   See 47 U.S.C. S: 503(b)(5) (authorizing the Commission to issue citations
   to persons who do not hold a license, permit, certificate or other
   authorization issued by the Commission, or who are not applicants for any
   of those listed instrumentalities, for violations of the Act, the
   Commission's rules, or the Commission's orders).

   Citation from Kurt A. Schroeder, Deputy Chief, Telecommunications
   Consumers Division, Enforcement Bureau, File No. EB-10-TC-478, issued to
   National Employee Benefits Group on October 22, 2010.

   Our records indicate that National Employee Benefits Group acknowledged
   receipt of the citation, as evidenced by a signed United States Postal
   Service return receipt, Article Number 7008 0500 0000 9339 3528.

   See Appendix for a listing of the consumer complaints against National
   Employee Benefits Group requesting Commission action.

   We note that evidence of additional instances of unlawful conduct by
   National Employee Benefits Group may form the basis of subsequent
   enforcement action.

   See 47 U.S.C. S: 227(a)(5); 47 C.F.R. S: 64.1200(f)(13). The term
   "unsolicited advertisement" means "any material advertising the commercial
   availability or quality of any property, goods, or services, which is
   transmitted to any person without that person's prior express invitation
   or permission, in writing or otherwise." Id.

   See 47 C.F.R. S: 64.1200(a)(3)(i).

   47 U.S.C. S: 503(b)(5).

   47 U.S.C. S: 503(b)(2)(E).

   47 C.F.R. S: 1.80(b)(4) note. The absence of a particular type of
   violation from the forfeiture guidelines must "not be taken to mean that
   the violation is unimportant or nonexistent," and "the Commission retains
   discretion to impose forfeitures for other violations." Commission's
   Forfeiture Policy Statement, Report & Order, 12 FCC Rcd 17087, 17110
   (1997).

   47 C.F.R. S: 1.80(b)(4) note.

   47 U.S.C. S: 503(b)(2)(C). Section 503(b)(2)(C) provides for forfeitures
   of up to $10,000 for each violation by an entity such as National Employee
   Benefits Group. See 47 U.S.C. S: 503(b)(2)(C). In accordance with the
   inflation adjustment requirements contained in the Debt Collection
   Improvement Act of 1996, Pub. L. 104-134, Sec. 31001, 110 Stat. 1321, the
   Commission implemented an increase of the maximum statutory forfeiture
   under section 503(b)(2)(C) first to $11,000 and more recently to $16,000.
   See 47 C.F.R. S:1.80(b)(3). See also Amendment of Section 1.80(b) of the
   Commission's Rules, Adjustment of Forfeiture Maxima to Reflect Inflation,
   23 FCC Rcd 9845 (2008) (amendment of section 1.80(b) to reflect an
   increase in the maximum forfeiture for this type of violator to $16,000).

   See  Get-Aways, Inc., Notice of Apparent Liability for Forfeiture, 15 FCC
   Rcd 1805 (1999); Get-Aways, Inc., Forfeiture Order, 15 FCC Rcd 4843
   (2000). See also US Notary, Inc., Notice of Apparent Liability for
   Forfeiture, 15 FCC Rcd 16999 (2000); US Notary, Inc., Forfeiture Order, 16
   FCC Rcd 18398 (2001); Tri-Star Marketing, Inc., Notice of Apparent
   Liability For Forfeiture, 15 FCC Rcd 11295 (2000); Tri-Star Marketing,
   Inc., Forfeiture Order, 15 FCC Rcd 23198 (2000).

   See Carolina Liquidators, Inc., Notice of Apparent Liability for
   Forfeiture, 15 FCC Rcd 16,837, 16,842 (2000); 21st Century Fax(es) Ltd.,
   AKA 20th Century Fax(es), 15 FCC Rcd 24,406, 24,411 (2000).

   See Laser Technologies, Notice of Apparent Liability for Forfeiture, 26
   FCC Rcd 10792 (2011).

   Presidential Who's Who, Notice of Apparent Liability for Forfeiture, 26
   FCC Rcd 8989 (2011) (Presidential Who's Who NAL). Since beginning to
   adjust the forfeiture upward for multiple, repeated violations of our junk
   fax rules, we have also proposed an adjustment of $75,000 for 62
   violations. The Street Map Company, Notice of Apparent Liability for
   Forfeiture, 26 FCC Rcd 8318 (2011).

   The upward adjustment of $150,000 amounts to approximately $1,595 for each
   of the 94 apparent violations at issue in this NAL that are not already
   subject to upward adjustment (i.e., all of the violations except the three
   for which we assess a $10,000 penalty). The combination of the base
   forfeiture and the upward adjustment for each of the 94 violations is
   therefore approximately $6,095.

   Presidential Who's Who NAL, 26 FCC Rcd at 8994.

   47 C.F.R. S: 1.80.

   (...continued from previous page)

                                                              (continued....)

   Federal Communications Commission FCC 12-24

                                       2

   Federal Communications Commission FCC 12-24