Yeah, I'd definitely say these shell fcs fall under the first point you mention.Lodestone will have this info, it's how I found that my own server is flooded with dead/shell FC's.
That being said, "Setting up a Free Company for the explicit intention of purchasing a personal house in a Free Company ward is a violation of the ToS" and "Owning more than one service account for the purposes of circumventing the one per service account restriction on housing is a violation of the ToS, and will result in the permanent suspension of all service accounts involved".
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