The FCC just released a new appeal decision, destined to be called the Richmond County decision, and it is more cause for celebration for applicants. Unlike many recent decisions, this is more than a waiver; the FCC has actually overruled the SLD.
The SLD has created a "two-signature/two-date" rule for contracts, saying that each party must sign and date a contract for it to be valid. Why? Because buried in a list of documents that the FCC requires applicants to keep, they said applicants should keep contracts "signed and dated by both parties." From that line, the SLD deduced that all contracts must be dated by both parties, regardless of state contract law.
Yesterday, the FCC said a contract with two signatures and one date is OK. Huzzah!
What the FCC should have said is that any contract which satisfies the law in the state where it was signed is a valid contract, but one step at a time.
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