FundsForLearning.com — Your E-rate Guides

Standard of Conduct

How we keep our independence.

Funds For Learning is paid by the applicants we serve, and by no one else. This standard sets out what that means in practice and how to hold us to it.

LAST REVIEWED SEPTEMBER 2026 · APPLIES TO ALL FUNDS FOR LEARNING STAFF AND CONTRACTORS

Who this applies to

Every Guide, analyst, and employee of Funds For Learning, LLC, and every contractor who works on a client engagement. It covers our consulting services, E-rate Manager®, our research, and what we say in public about the E-rate program.

Our commitments

  • We work for applicants. Schools, libraries, and consortia are our only clients for compliance services.
  • We sell no E-rate eligible products or services and hold no Service Provider Identification Number (SPIN).
  • We accept no payment, referral fee, or commission from a service provider that is tied to its sales to applicants.
  • We tell clients what the rules require, including when the answer costs them a funding request.
  • We keep client information confidential and use E-rate Manager® data only as our agreements allow.

What we do not do

  • We do not prepare or submit bids on behalf of a service provider.
  • We do not recommend a vendor. Clients evaluate bids against their own criteria, with the price of eligible services weighted most.
  • We do not certify forms. The applicant’s authorized person reviews and certifies every filing.
  • We do not accept gifts from service providers, and we advise clients to follow the FCC gift rules without exception.

How the FCC’s consultant rules apply to us

RequirementWhat Funds For Learning does
Consultant Registration NumberEvery form we help prepare lists our CRN, so USAC and the FCC can see who assisted the applicant.
Competitive biddingWe draft the Form 470 and the bid calendar. We do not contact bidders during the 28-day window, and we document the applicant’s evaluation.
CertificationsWe prepare. The applicant’s authorized person reads, questions, and certifies.
Document retentionWe keep engagement records for at least ten years after the last date of service, matching the program’s retention rule.
Program reviews and auditsWe answer reviewer questions with the client and never on the client’s behalf without written authorization.
If a recommendation would benefit us and not you, we do not make it.

Conflicts of interest

Employees disclose any financial interest in a company that sells to E-rate applicants, and any family relationship with a service provider’s sales staff. A disclosed conflict removes that person from the affected engagement. We publish this standard so clients can check our work against it.

Ask a Guide how an engagement is structured

How to raise a concern

If you believe we have fallen short of this standard, tell us. Call (405) 341-4140 or write to info@fundsforlearning.com. A member of our leadership team, not the Guide on your engagement, will respond within five business days.

Independent by design

Funds For Learning sells no E-rate eligible services, holds no SPIN, and accepts no payments from service providers tied to their sales to applicants. Our only interest is our clients' funding.

Our Standard of Conduct