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
| Requirement | What Funds For Learning does |
|---|---|
| Consultant Registration Number | Every form we help prepare lists our CRN, so USAC and the FCC can see who assisted the applicant. |
| Competitive bidding | We 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. |
| Certifications | We prepare. The applicant’s authorized person reads, questions, and certifies. |
| Document retention | We keep engagement records for at least ten years after the last date of service, matching the program’s retention rule. |
| Program reviews and audits | We 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.