Paul Moore
Midland Communications
This is an updated version of our earlier article covering the shenanigans of Federal Licensing, Inc. (“Federal Licensing”), and continues to serve as a warning to you and your customers who may receive this outfit’s "I’m here to save you" solicitations.
Previously, we issued warnings about materials sent to licensees from a supposed Modification Division, a Renewal/Modification Division, and a Publication Division, none of which, of course, have anything to do with the FCC, and in fact were created by Federal Licensing to resemble official government communications. Nay Nay! The FCC does not have a Modification Division, it does not have a Renewal/Modification Division, and it most certainly does not have a Publication Division. The FCC’s Gettysburg, Pennsylvania office building is located at 1270 Fairfield Road (on the left below). Federal Licensing’s location is down the street at 1588 Fairfield Road, which as you will note, appears to be a residence. It doesn’t look much like a federal government building to me, nor should it to your customers.
We also want to make it perfectly clear that solicitations you or your customers may receive from a Federal License Management’s “Office of Compliance Administration” which suggest that there is a requirement to respond to an “Administrative Update – Modification Notice” are from this separate and distinct entity, which is not affiliated in any way with Federal Licensing, Inc. Of course, there is no Office of Compliance Administration within the FCC, and no requirement to respond to Federal License Management’s attempts to solicit customers under the premise that the licensee may be “operating in non-compliance of CFR Title 47 Chapter 1, Subchapter D of Part 90 of FCC rules and regulations.” These references are confusing at best, and inaccurate at worst. Unsuspecting licensees are certainly not equipped to know the difference, if that was the intention. They are a mish-mash of the FCC Rules and the Code of Federal Regulations that lead you to no particular rule that arguably might have been violated.
Federal License Management’s “Office of Compliance Administration,” not to be confused with Federal Licensing’s Modification Division, recently moved to 175 Pine Street, Suite 104, Williamsport, Pennsylvania. They are no longer located at 1784 East Third, Suite 269, Williamsport, Pennsylvania, which was the address of a UPS store. (I will choose not to try to make sense of having a second-floor suite in a one-story strip mall. Maybe they processed applications on the roof!)
I don’t have any issues with organizations that are attempting to secure FCC licensing business. But we all should take issue with solicitation tactics that rely on inaccurate references to FCC rules that serve to ambush licensees who have better things to do than worry about renewals way in advance of when filings may even be accepted by the FCC, and refer to violations of unidentified rules.
To use Federal License Management’s own language, “We strongly encourage you to” advise your customers that if they receive a solicitation from either Federal Licensing, Inc., or Federal License Management, LLC – two separate and distinct entities that seem obligated to print in tiny print that they are a “Non-Governmental Agency” in their solicitations in order to keep the Federal Trade Commission (FTC) away – they should be cautious and ask questions from professionals who are truly aware of FCC’s rules.