There is already talk that the agency is poised to reject $3.3 billion sought by Dish’s small partners during the spectrum auction process early in the year.

A limit has also been placed on the amount of spectrum smaller entities can lease to non-controlling investors.

The Wall Street Journal reported last night that FCC staff has “concluded that the $13.3 billion in winning bids by two companies backed by Dish didn’t qualify for the small-business discounts because their bidding conduct violated the broad spirit of the auction’s rules” and that Wheeler has circulated a draft order to his fellow commissioners to rule on the matter.

Bloomberg reported Thursday that Dish Network has not presented the kind of offer Deutsche Telekom is looking for in terms of a Dish merger or wireless partnership with T-Mobile US.

AT&T spent $18.2 billion in AWS-3, the most of any company, while Verizon spent $10.4 billion. The new rules for auctions ban carriers from bidding through multiple smaller businesses and cap the discounts small businesses can receive at $150 million. The report casts doubt on whether Dish can ink an agreement with T-Mobile, thus cashing in on the spectrum Dish has accumulated during the past few years.

SNR Wireless and NorthStar Wireless both applied for the 25% small business discount on spectrum, or airwaves, when the government held its recent spectrum action.

The US Federal Communications Commission (FCC) tightened the rules to its designated entity initiative, following an alleged misuse of the system by United States broadcaster Dish Network earlier this year.

DISH declined to comment.