The FCC today issued an Order suspending the upcoming January 11 deadline for the filing of new Form 323 Ownership Reports by all licensees of commercial broadcast stations. As we have written before, the approval of this form has been a tortured process, and left open many questions about the practicalities of completing the form, as well as in connection with certain policy issues raised by the form. Many broadcasters were, for instance, concerned about privacy issues with the provision of Social Security Numbers as is necessary to obtain a FCC Registration Number from each attributable principal as required by the new form. Others were concerned about more practical issues that would require the entry of multiple fields of information, in some cases repeated dozens or even hundreds of times for some multiple station owners. After receiving many protests about the burden imposed by the new form, and the short time that commercial licensees were given to prepare the report for submission (the form only becoming available earlier this month), the Commission today decided to suspend the filing deadline while it further revised the form to answer the many questions that have arisen.
So the January deadline has been lifted. When will the re-filing take place? It is uncertain now, as the Commission seemingly may need to make significant changes to the form to answer the many questions that have been raised (though the Order today addresses only the practical issues, not revisiting the issue of the Social Security Numbers). The Commission did say, however, that no filing will be required for at least 90 days after the revised form is made available – hopefully giving broadcasters plenty of time to work with any revised form that is adopted to resolve any new issues that may crop up. But for all of you who were planning on spending your holidays filling out ownership reports – you can now relax and enjoy the season’s festivities!