ownership reports

The FCC on Thursday issued a Public Notice announcing that, at the end of the day on Nov. 27 the current versions of FCC Forms 323 and 323E will be retired. These forms will be replaced in the near future by a new version of the ownership report in the FCC’s LMS database. If you are currently working on an ownership report following the completion of a purchase of a station or other event triggering the need for such a report, you must file it on the old form by 11:59 ET on Nov. 27, or wait until the new form is available (if that will allow you to comply with the filing deadline for your report).

Just 29 days ago, the FCC’s Media Bureau issued an unusual decision denying petitions for reconsideration of an order adopted by the commissioners themselves, raising questions as to who’s in charge at the FCC.  The petitions were filed by noncommercial broadcasters over a long-running proceeding to update broadcast ownership reporting rules. On Thursday, a much different Media Bureau backtracked on that decision — t he FCC’s rules give it 30 days to change its mind — and decided that ruling on petitions seeking reconsideration of a commission-level order is a matter best left to the commissioners themselves.

The saga of the FCC’s quest to devise the Perfect Ownership Report slogs on. Back in January, the commission adopted a new approach to identifying individual attributable owners for tracking purposes across reports. While the new rules were published in the Federal Register four months later, they haven’t really taken effect across the board. And now comes word that four petitions for reconsideration of various aspects of the new rules have been filed.

Biennial Ownership Reports (FCC Form 323) for commercial radio and TV (including Class A and LPTV licensees) are due this fall and the Media Bureau just announced it will host an “information session” on the form on Sept. 22 from noon to 1:30 p.m. During the show, bureau staff will “present an overview of Form 323”, “conduct a filing demonstration,” and answer questions from the audience, both those presented in-person or by email. Nothing if not ambitious in its scope, the session is designed to “assist both novice and experienced filers.”

On Thursday, the FCC’s Media Bureau extended the deadline for filing biennial ownership reports to Dec. 2. The bureau explained that “some licensees and parent entities of multiple stations may be required to file numerous forms, and the extra time is intended to permit adequate time to prepare such filings.”

It’s still summer, but it’s never too early for commercial broadcasters to start thinking about the FCC’s Biennial Ownership Reports. Because 2015 is an “odd year,” ownership reports will be due on Nov. 2 (Nov. 1 is a Sunday). Broadcasters who have been through ownership reports before know that the drafting process is tedious and time consuming. As such, it’s a good idea to start planning early.