Client Alert
FCC Suspends Biennial Ownership Report Filing Requirement
October 5, 2009
The FCC has suspended the requirement that all broadcast licensees file a new ownership report by November 1.
Prior procedures had required licensees to file biennial reports on every other anniversary of their renewal due date. The Commission had previously suspended that requirement in favor of a revised report to be due on November 1 of every odd-numbered year, reflecting information current as of that October 1. The Commission had also adopted a new form for the revised reports, requiring substantial additional information.
The Commission notes that its new form has not yet received required approval of the Office of Management and Budget and that too little time will remain for licensees to compile the additional necessary information prior to the November 1 deadline. Therefore, a new deadline will be announced to afford at least 30 days after OMB approval is obtained.
The Commission cautions that this suspended filing requirement only applies to biennial reports and that other ownership reporting requirements, such as following license assignments, transfers of control, or licensing of new stations, remain in effect using the old Form 323.
If you have any questions regarding the content of this Client Alert, please contact Peter Gutmann, or any member of the firm’s Communications Law Group.
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