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Federal Communications Commission DA 18-1266
Before the
Federal Communications Commission
Washington, DC 20554
In the Matter of )
)
Mobile Communications America, Inc. ) File No.: EB-IHD-18-00028100
) Acct. No.: 201932080006
Holding Various Authorizations in the Wireless ) FRN: 0026218487
Radio Services )
ORDER
Adopted: December 26, 2018 Released: December 26, 2018
By the Deputy Chief, Enforcement Bureau:
1. The Enforcement Bureau of the Federal Communications Commission (Commission) has
entered into a Consent Decree to resolve the Commission’s investigation into whether Mobile
Communications America, Inc. (Mobile Communications)1 violated Sections 310(d) and 301 of the
Communications Act, of 1934, as amended (Act),2 and Sections 1.948 and 1.903 of the Commission’s
rules (Rules),3 related to the transfer of control of wireless radio licenses prior to receiving Commission
approval, and its operation of wireless stations after their licenses had expired. These sections of the Act
and the Rules ensure that the transfer, assignment, and operation of wireless radio authorizations are
limited to instances where there has been a prior determination that such a transfer, assignment, and
4
operation is in the public’s “interest, convenience, and necessity.” To settle this matter, Mobile
Communications admits that it failed to obtain the necessary Commission approval prior to transfer of the
wireless licenses in question. Mobile Communications also agrees to implement a compliance plan and
to pay a settlement of $93,600 in redress.
2. After reviewing the terms of the Consent Decree and evaluating the facts before us, we
find that the public interest would be served by adopting the Consent Decree and terminating the
referenced investigation regarding Mobile Communications’ compliance with the Act,5 and Sections
1.948 and 1.903 of the Rules,6 pertaining to unauthorized transfers of control, assignment, and operation
of wireless radio licenses. In the absence of material new evidence relating to this matter, we do not set
for hearing the question of Mobile Communications’ basic qualifications to hold or obtain any
Commission license or authorization.7
1
Any entity that is a “Small Business Concern” as defined in the Small Business Act (Pub. L. 85-536, as amended)
may avail itself of rights set forth in that Act, including rights set forth in 15 U.S.C. § 657, “Oversight of Regulatory
Enforcement,” in addition to other rights set forth herein.
2
47 U.S.C. §§ 310(d), 301.
3
47 CFR §§ 1.948, 1.903.
4
Supra notes 2-3.
5
47 U.S.C. §§ 310(d), 301.
6 47 CFR §§ 1.948, 1.903.
7
See 47 CFR § 1.93(b).
Federal Communications Commission DA 18-1266
3. Accordingly, IT IS ORDERED that, pursuant to Section 4(i) of the Act8 and the
authority delegated by Sections 0.111 and 0.311 of the Rules,9 the attached Consent Decree IS
ADOPTED, and its terms incorporated by reference.
4. IT IS FURTHER ORDERED that the above-captioned matter IS TERMINATED.
5. IT IS FURTHER ORDERED that a copy of this Order and Consent Decree shall be
sent by first class mail and certified mail, return receipt requested, to Mark Blackman, Chief Executive
Officer, Mobile Communications, 100 Dunbar Street, Suite 304, Spartanburg, South Carolina 29306 and
Elizabeth Sachs, Esq., Lukas, Lafuria, Gutierrez & Sachs LLP, 8300 Greensboro Drive, Suite 1200,
Tysons, Virginia 22102.
FEDERAL COMMUNICATIONS COMMISSION
Phillip Rosario
Deputy Chief
Enforcement Bureau
8
47 U.S.C. § 154(i).
9
47 CFR §§ 0.111, 0.311.
2
Federal Communications Commission DA 18-1266
Before the
Federal Communications Commission
Washington, DC 20554
In the Matter of )
Mobile Communications America, Inc. ) File No.: EB-IHD-18-00028100
) Acct. No.: 201932080006
Holding Various Authorizations in the Wireless ) FRN: 0026218487
Radio Services )
)
)
CONSENT DECREE
1. The Enforcement Bureau of the Federal Communications Commission and Mobile
Communications America, Inc. (Mobile Communications or the Company),1
by their authorized
representatives, hereby enter into this Consent Decree for the purpose of terminating the Enforcement
Bureau’s investigation into whether the Company violated Section 310(d) of the Communications Act of
1934, as amended (Act),2 and Section 1.948 of the Commission’s rules (Rules),3 pertaining to
unauthorized transfers of control and assignments of licenses in connection with its acquisition of seven
commercial wireless companies and two subsidiary companies that held authorizations for wireless radio
services. The instant settlement also resolves questions about whether the Company violated Section 301
of the Act4 and Section 1.903 of the Rules,5 pertaining to unauthorized operation of wireless stations and
station equipment.
I. DEFINITIONS
2. For the purposes of this Consent Decree, the following definitions shall apply:
(a) “Act” means the Communications Act of 1934, as amended, 47 U.S.C. § 151 et seq.
(b) “Adopting Order” means an Order of the Enforcement Bureau adopting the terms of
this Consent Decree without change, addition, deletion, or modification
(c) “Commission” and “FCC” mean the Federal Communications Commission and all
of its bureaus and offices.
(d) “Communications Laws” means, collectively, the Act, the Rules, and the published
and promulgated orders and decisions of the Commission to which Mobile
Communications is subject by virtue of its business activities, including but not
limited to, the Wireless Radio Service Rules.
(e) “Compliance Plan” means the compliance obligations, program, and procedures
described in this Consent Decree at Paragraph 16.
1
Any entity that is a “Small Business Concern” as defined in the Small Business Act (Pub. L. 85-536, as amended)
may avail itself of rights set forth in that Act, including rights set forth in 15 U.S.C. § 657, “Oversight of Regulatory
Enforcement,” in addition to other rights set forth herein.
2
47 U.S.C. § 310(d).
3
47 CFR § 1.948.
4
47 U.S.C. § 301.
5
47 CFR § 1.903.
Federal Communications Commission DA 18-1266
(f) “Covered Employees” means all employees and agents of the Company who
perform, supervise, oversee, or manage the performance of duties that relate to
Mobile Communications’ responsibilities under the Communications Laws,
including Sections 310(d) and 301 of the Act and Sections 1.948 and 1.903 of the
Rules.
(g) “Effective Date” means the date on which the Bureau and Mobile Communications
have signed the Consent Decree.
(h) “Enforcement Bureau” or “Bureau” means the Enforcement Bureau of the Federal
Communications Commission.
(i) “Investigation” means the proceeding commenced by the Bureau in File No. EB-
IHD-18-00028100 to determine whether the Company violated provisions of the
Communications Laws relating to unauthorized transfer of wireless radio station
licenses and unauthorized operation of wireless stations and station equipment.
(j) “Mobile Communications” or “Company” means Mobile Communications America,
Inc., its subsidiaries, affiliates, predecessors-in-interest, and successors-in-interest.
(k) “Operating Procedures” means the standard, internal operating procedures and
compliance policies established by Mobile Communications to implement the
Compliance Plan.
(l) “Parties” means Mobile Communications and the Bureau, each of which is a
“Party.”
(m) “Rules” means the Commission’s regulations found in Title 47 of the Code of
Federal Regulations.
(n) “Unauthorized Operations Rules” means Section 47 U.S.C. § 301 of the Act6
and
Section 1.903 of the Rules,7 pertaining to unauthorized transfers of control and
assignments of wireless radio licenses.
8
(o) “Unauthorized Transfer Rules” means Section 310(d) of the Act and Section 1.948
of the Rules,9 pertaining to unauthorized transfers of control and assignments of
licenses.
(p) “Wireless Bureau” means the Wireless Telecommunications Bureau of the
Commission.
(q) “Wireless Radio Services” means those wireless radio services defined in Section
1.907 of the Rules.10
II. BACKGROUND
3. Section 310(d) of the Act provides that “[n]o construction permit or station license, or any
rights thereunder, shall be transferred, assigned, or disposed of in any manner, voluntarily or
involuntarily, directly or indirectly, or by transfer of control of any corporation holding such permit or
license, to any person except upon application to the Commission and upon finding by the Commission
6
47 U.S.C. § 301.
7 47 CFR § 1.903.
8 47 U.S.C. § 310(d).
9 47 CFR § 1.948.
10 47 CFR § 1.907.
2
Federal Communications Commission DA 18-1266
11
that the public interest, convenience, and necessity will be served thereby.” Section 1.948 of the Rules
similarly requires Commission consent prior to the transfer of control or assignment of a wireless radio
license.12
4. According to Mobile Communications, the Company is a privately held Delaware
corporation, created for the purpose of acquiring the stock of Mobile Communications of Hall, LLC, and
Mobile Communications of DeKalb, Inc., as well as other radio sales and service organizations on an
ongoing basis.13
Mobile Communications currently operates and has offices in seven states in the
Southeast, and all offices report to, and are managed from, the company’s headquarters in Spartanburg,
South Carolina.14
5. On August 23, 2013, Mobile Communications began executing a series of stock or other asset
transactions to acquire entities that then held, among other things, FCC wireless radio licenses.15 The
required Commission consent for transfer of those licenses, however, was not obtained prior to
completing such acquisitions.16
6. In early 2018, Mobile Communications became aware that it had consummated stock or asset
17
transactions involving wireless radio licenses without obtaining the required prior FCC approval. The
Company engaged communications counsel to facilitate an inventory of its licensed and operating
facilities and identify non-compliant transactions and the FCC authorizations involved.18 During that
review, the Company also determined that two of the licenses involved had expired for approximately one
year and three and one-half months, respectively.19 Additionally, the Company also discovered that it had
completed a pro forma assignment of certain wireless radio assets without obtaining the required prior
Commission approval.20
7. In April of 2018, Mobile Communications filed a waiver request with the Wireless Bureau,
which thereafter referred the matter to the Enforcement Bureau for investigation.21 Mobile
Communications also filed curative applications seeking Commission consent, nunc pro tunc, to cover the
transfers of control of the wireless radio licenses and authorizations conveyed to Mobile
Communications.22 Mobile Communications stated in the application filings that its “failure to have
11 47 U.S.C. § 310(d).
12 47 CFR § 1.948.
13 See Letter from Elizabeth Sachs, Counsel for Mobile Communications, to Gary Oshinsky, Attorney Advisor,
Investigations and Hearings Division, Enforcement Bureau, FCC (July 13, 2018) (on file in File No. EB-IHD-18-
00028100) (Mobile Communications Letter).
14 Id. at unnumbered page 2.
15 Id. Those transactions occurred between August 2013 and July 2017, and the FCC licenses involved were for
facilities in the 150-174 MHz (“VHF”) or 450-470 MHz (“UHF”) band, subject to either Part 90 (Private Land
Mobile Radio Services) or Part 22, Subpart E (Public Mobile Services), of the FCC rules. See id., Attachment A.
16 See Application for Transfer of Control, ULS License No. 0008173582, et al., Request for Waiver Unauthorized
Transfer of Control/Assignments/Pro Forma Assignments (April 25, 2018) (Waiver Request).
http://appsint.fcc.gov/UlsEntry/attachments/attachmentViewRD.jsp?applType=search&fileKey=1384996574&attac
hmentKey=20350116&attachmentInd=applAttach.
17 Mobile Communications Letter at unnumbered page 2.
18 Id.
19 Mobile Communications Letter, Attachment A.
20
Id.
21
See Waiver Request at unnumbered page 1.
22
Id. These filings were completed in April of 2018, and some of the applications remain pending.
3
Federal Communications Commission DA 18-1266
followed the necessary FCC processes in these [transfers] is not attributable to indifference to
Commission requirements, but to a less than complete understanding of FCC licensing requirements and a
lack of appropriate regulatory oversight during a period of unexpectedly rapid growth.”23 The Company
also represented that it “deeply regrets these errors and has already taken steps to ensure that they will not
be repeated.”24
8. The Enforcement Bureau’s Investigation revealed that Mobile Communications completed
seven substantial and two pro forma transfers of control,25concerning more than 50 separate licenses
without first obtaining prior Commission consent. These transactions comprised two initial stock
acquisitions and further transactions involving additional wireless businesses acquired by Mobile
Communications or its subsidiaries, and for which the Company thereafter filed applications and
associated waiver requests seeking the Commission’s nunc pro tunc approval.26 In most of those cases,
the applications qualified for conditional licensing under FCC Rule Section 90.159.27 For those that did
not qualify for conditional licensing, Mobile Communications submitted applications28 for Special
Temporary Authority.29
9. Mobile Communications represents that it has adopted internal procedures designed to
prevent future FCC rule violations.30
The Company explains that it has developed a defined process for
conducting due diligence on all potential acquisitions in order to identify possible compliance issues.31
The Company also represents that it has centralized its FCC licensing procedures and developed a
Compliance Manual for distribution to all employees that have any involvement in FCC licensing issues,
including the area of customer equipment.32 Neither the Company nor the Commission has received, or is
23 Waiver Request at unnumbered page 1.
24 See id.
25 A substantial transfer of control is, inter alia, a transaction whereby controlling interest in the licensee shifts to a
party whose qualifications have not yet been ascertained by the Commission. See Questions and Answers
Regarding Private Wireless Licensees’ Obligations Under Section 310(d) of the Communications Act of 1934,F act
Sheet (Sept. 19, 2000), 2000 WL 1340584, at *2. By contrast, a pro forma transaction involves a non-substantial
change in ownership of the license or the licensee entity where the controlling interest is not acquired or lost. See id.
at *3.
26 Waiver Request at unnumbered page 1.
27 47 CFR § 90.159(c) (“An applicant…seeking the assignment of authorization or transfer of control of a license for
an existing station below 470 MHz or in the 929-930 MHz band (other than a commercial mobile radio service
applicant or licensee on these bands) may operate the proposed station during the pendency of the application for a
period not to exceed one hundred eighty (180) days upon the filing of a properly completed formal Form 601
application that complies with § 90.127 of this part”). See, e.g., Oregon Pacific Railroad Company, Memorandum
Opinion and Order, 16 FCC Rcd 2972, 2972, para. 3, n.5 (EB 2001).
28 See Mobile Communications Letter, Attachments.
29 Under 47 CFR § 1.931(a)(1), special temporary authority to operate a station without a license may be granted
“[i]n circumstances requiring immediate or temporary use of station in the Wireless Telecommunications Services
[and where] carriers . . . request special temporary authority (STA) to operate new or modified equipment.” Id. See,
e.g., Township of Mount Olive, New Jersey, Order, DA 18-1167, 2018 WL 6017702 *2, para. 6 (PSHSB Nov. 15,
2018) (if a licensee “needs to operate while its application [for licenses] is being prepared and coordinated, it may
file requests for special temporary authority pursuant to Section 1.931 of the Commission’s rules”).
30 E-mail from Elizabeth Sachs, Counsel for Mobile Communications, to Gary Oshinsky, Attorney Advisor,
Investigations and Hearings Division, Enforcement Bureau, FCC (June 12, 2017, 14:28 EDT) (on file in EB-IHD-
18-00028100).
31 Mobile Communications Letter at unnumbered page 3.
32 See Mobile Communications Letter, Attachments.
4
Federal Communications Commission DA 18-1266
aware of, any third-party complaints regarding Mobile Communications’ unauthorized transfers of
control.33 In addition, Mobile Communications acknowledges that the scope of its FCC-based regulatory
34
noncompliance, as described above, was significant. To resolve the Bureau’s Investigation, the Parties
find it advantageous to enter into this Consent Decree to ensure Mobile Communications’ future
compliance with all applicable Communications Laws.
III. TERMS OF AGREEMENT
10. Adopting Order. The provisions of this Consent Decree shall be incorporated by the Bureau
in an Adopting Order without change, addition, deletion, or modification.
11. Jurisdiction. The Company agrees that the Bureau has jurisdiction over it and the matters
contained in this Consent Decree and that the Bureau has the authority to enter into and adopt this
Consent Decree.
12. Effective Date. The Parties agree that this Consent Decree shall become effective on the
Effective Date as defined herein. As of the Effective Date, the Parties agree that this Consent Decree
shall have the same force and effect as any other order of the Commission.
13. Termination of Investigation. In express reliance on the covenants and representations in
this Consent Decree and to avoid further expenditure of public resources, the Bureau agrees to terminate
the Investigation. In consideration for the termination of the Investigation, the Company agrees to the
terms, conditions, and procedures contained herein. The Bureau further agrees that, in the absence of new
material evidence, it will not use the facts developed in the Investigation through the Effective Date, or
the existence of this Consent Decree, to institute on its own motion any new proceeding, formal or
informal, or take any action on its own motion against the Company concerning the matters that were the
subject of the Investigation. The Bureau also agrees that, in the absence of new material evidence, it will
not use the facts developed in the Investigation through the Effective Date, or the existence of this
Consent Decree, to institute on its own motion any proceeding, formal or informal, or take any action on
its own motion against the Company with respect to the Company’s basic qualifications, including its
character qualifications, to be a Commission licensee or hold Commission licenses or authorizations.35
14. Admission of Liability. Mobile Communications admits, for the purpose of this Consent
Decree and for Commission civil enforcement purposes, and in express reliance on the provisions of
Paragraph 13 herein, that its actions described in Paragraphs 5 through 9 of this Consent Decree violated
the Unauthorized Transfer Rules and the Unauthorized Operations Rules.
15. Compliance Officer. Within thirty (30) calendar days after the Effective Date, to the extent
it has not already done so under its current compliance procedures, the Company shall designate a senior
corporate manager with the requisite corporate and organizational authority to serve as a Compliance
Officer and to discharge the duties set forth below. The person designated as the Compliance Officer
shall be responsible for developing, implementing, and administering the Compliance Plan and ensuring
that the Company complies with the terms and conditions of the Compliance Plan and this Consent
Decree. In addition to the general knowledge of the Communications Laws necessary to discharge his or
her duties under this Consent Decree, the Compliance Officer shall have specific knowledge of the
Unauthorized Transfer Rules and Unauthorized Operations Rules prior to assuming his or her duties.
16. Compliance Plan. For purposes of settling the matters set forth herein, the Company agrees
that it shall continue to maintain its existing compliance procedures. In addition, within ninety (90)
calendar days after the Effective Date, the Company shall develop and implement the measures described
below, if not already in place, to ensure future compliance with the Communications Laws and with the
33 Id.
34 Waiver Request at unnumbered page 1.
35 See 47 CFR § 1.93(b).
5
Federal Communications Commission DA 18-1266
terms and conditions of this Consent Decree. With respect to the Unauthorized Transfer Rules and
Unauthorized Operations Rules, including with regard to transfers of control and assignments of wireless
licenses as the result of corporate acquisitions or asset transfers, the Company will implement, at a
minimum, the following procedures:
(a) Operating Procedures. Within sixty (60) calendar days after the Effective Date,
the Company shall establish Operating Procedures that all Covered Employees shall
follow to help ensure the Company’s compliance with The Unauthorized Transfer
Rules and Unauthorized Operations Rules. The Company’s Operating Procedures
shall include internal procedures and policies specifically designed to ensure that the
Company complies with the Unauthorized Transfer Rules and Unauthorized
Operations Rules. The Company shall also develop a Compliance Checklist that
describes the steps that a Covered Employee must follow to ensure compliance with
the Unauthorized Transfer Rules and Unauthorized Operations Rules.
(b) Compliance Manual. Within ninety (90) calendar days after the Effective Date, the
Compliance Officer shall develop and distribute a Compliance Manual to all
Covered Employees. The Compliance Manual shall explain the Communications
Laws that apply to the Company, including the Unauthorized Transfer Rules and
Unauthorized Operations Rules, and shall set forth the Operating Procedures that
Covered Employees shall follow to help ensure the Company’s compliance with the
Unauthorized Transfer Rules and Unauthorized Operations Rules. The Company
shall periodically review and revise the Compliance Manual as necessary to ensure
that the information set forth therein remains current and accurate. The Company
shall distribute any revisions to the Compliance Manual promptly to all Covered
Employees.
(c) Compliance Training Program. Within ninety (90) calendar days after the
Effective Date, the Company shall establish and implement a Compliance Training
Program on compliance with the Communications Laws, including the
Unauthorized Transfer Rules and Unauthorized Operations Rules, and the Operating
Procedures. As part of the Compliance Training Program, Covered Employees shall
be advised of the Company’s obligation to report any noncompliance with the
Communications Laws, including the Unauthorized Transfer Rules and
Unauthorized Operations Rules, under Paragraph 17 of this Consent Decree, and
shall be instructed on how to disclose noncompliance to the Compliance Officer.
All Covered Employees shall be trained pursuant to the Compliance Training
Program within one hundred twenty (120) calendar days after the Effective Date
except that any person who becomes a Covered Employee at any time after the
initial Compliance Training Program shall be trained within thirty (30) calendar
days after the date such person becomes a Covered Employee. The Company shall
repeat compliance training on an annual basis and shall periodically review and
revise the Compliance Training Program as necessary to ensure that it remains
current and complete and to enhance its effectiveness.
17. Reporting Noncompliance. The Company shall report to the Commission any
noncompliance with the Communications Laws, the Unauthorized Transfer Rules, the Unauthorized
Operations Rules, and with the terms and conditions of this Consent Decree within fifteen (15) calendar
days after discovery of such noncompliance. Such reports shall include a detailed explanation of: (i) each
instance of noncompliance; (ii) the steps that the Company has taken or will take to address such
noncompliance; (iii) the schedule on which such remedial actions will be taken; and (iv) the steps that the
Company has taken or will take to prevent the recurrence of any such noncompliance. All reports of
noncompliance shall be submitted to the Chief, Investigations & Hearings Division, Enforcement Bureau,
Federal Communications Commission, Room 4-C330, 445 12th Street, SW, Washington, DC 20554, with
6
Federal Communications Commission DA 18-1266
a copy submitted electronically to Jeffrey J. Gee at Jeffrey.Gee@fcc.gov
, Christopher J. Sova at
Christopher.Sova@fcc.gov, and Gary Oshinsky at Gary.Oshinsky@fcc.gov.
18. Compliance Reports. The Company shall file Compliance Reports with the Commission
one hundred twenty (120) calendar days after the Effective Date, twelve (12) months after the Effective
Date, twenty-four (24) months after the Effective Date, and thirty-six (36) months after the Effective
Date.
(a) Each Compliance Report shall include a detailed description of the Company’s
efforts during the relevant period to comply with the terms and conditions of this
Consent Decree, the Communications Laws, the Unauthorized Transfer Rules, and
the Unauthorized Operations Rules. In addition, each Compliance Report shall
include a certification by the Compliance Officer, as an agent of and on behalf of the
Company, stating that the Compliance Officer has personal knowledge that the
Company: (i) has established and implemented the Compliance Plan; (ii) has
utilized the Operating Procedures since the implementation of the Compliance Plan;
and (iii) is not aware of any instances of noncompliance with the terms and
conditions of this Consent Decree, including the reporting obligations set forth in
Paragraph 17 of this Consent Decree.
(b) The Compliance Officer’s certification shall be accompanied by a statement
explaining the basis for such certification and shall comply with Section 1.16 of the
Rules and be subscribed to as true under penalty of perjury in substantially the form
set forth therein.36
(c) If the Compliance Officer cannot provide the requisite certification, the Compliance
Officer, as an agent of and on behalf of the Company, shall provide the Commission
with a detailed explanation of the reason(s) why and describe fully: (i) each instance
of noncompliance; (ii) the steps that the Company has taken or will take to address
such noncompliance, including the schedule on which proposed remedial actions
will be taken; and (iii) the steps that the Company has taken or will take to prevent
the recurrence of any such noncompliance, including the schedule on which such
preventive action will be taken.
(d) All Compliance Reports shall be submitted to the Chief, Investigations & Hearings
Division, Enforcement Bureau, Federal Communications Commission, Room 4-
-C330, 445 12th Street, SW, Washington, DC 20554, with a copy submitted
electronically to Jeffrey J. Gee at Jeffrey.Gee@fcc.gov
, Christopher J. Sova at
Christopher.Sova@fcc.gov, and Gary Oshinsky at Gary.Oshinsky@fcc.gov.
19. Termination Date. Unless stated otherwise, the requirements set forth in Paragraphs 15
through 18 of this Consent Decree shall expire thirty-six (36) months after the Effective Date.
20. Civil Penalty. The Company will pay a civil payment to the United States Treasury in the
amount of Ninety-Three Thousand Six-Hundred Dollars ($93,600) within thirty (30) calendar days after
the Effective Date. The Company shall send electronic notification of payment to Jeffrey J. Gee at
Jeffrey.Gee@fcc.gov, Christopher J. Sova at Christopher.Sova@fcc.gov, and Gary Oshinsky at
Gary.Oshinsky@fcc.gov on the date said payment is made. The payment must be made by check or
similar instrument, wire transfer, or credit card, and must include the NAL/Account Number and FRN
referenced above. Regardless of the form of payment, a completed FCC Form 159 (Remittance Advice)
must be submitted.37 When completing the FCC Form 159, enter the Account Number in block number
36 47 CFR § 1.16.
37 An FCC Form 159 and detailed instructions for completing the form may be obtained at
.
http://www.fcc.gov/Forms/Form159/159.pdf
7
Federal Communications Commission DA 18-1266
23A (call sign/other ID) and enter the letters “FORF” in block number 24A (payment type code). Below
are additional instructions that should be followed based on the form of payment selected:
Payment by check or money order must be made payable to the order of the Federal