by Jackie Fisher of Fletcher, Heald & Hildreth
It’s that time of (every other) year again – The FCC announced that the filing window has opened and Biennial Ownership reports are due Wednesday, December 1st, 2021.
Every odd-numbered year, the FCC collects information about the owners of commercial and noncommercial licensees of broadcast stations. The FCC collects this data to ensure that the Commission and the public are informed about who owns, operates, and controls broadcast stations, and to understand the demographic makeup of the broadcast industry. These reports are a snapshot of the industry as of October 1, 2021, meaning that the reports should not reflect changes after October 1st, 2021.
All Licensees of Full Power Television, Class A Television, Low Power Television, AM Radio, FM Radio, and the entities that own an interest in those stations must file an ownership report with the FCC. In other words, if an FM radio station is owned by a parent entity, both the licensee and the parent entity must report ownership data. This applies to both commercial and non-commercial stations.
To file an ownership report, licensees should use the Commission’s Licensing and Management System. Commercial stations file Form 323, while noncommercial stations file Form 323-E. If there are no changes in ownership from the previous filing in 2019, the form will allow you to reference your previous filing, autofill the report, review, and submit. If there are changes, licensees should plan ahead to make sure they have plenty of time to submit a new, accurate report. One step licensees and parent entities should take to ensure that they can complete their filings efficiently is to make sure that every individual with an attributable interest in their station or parent entity has an FCC Registration Number, or “FRN.” You can find the registration instructions here or register here.
The FCC has released a number of resources to assist filers of ownership reports, which can be found here.