biennial ownership report

On the surface, September appears to have few scheduled regulatory filing dates and deadlines.  But it is period in which many broadcasters will be busy with deadlines that occur in early October and into the rest of the Fall.  TV stations should be finishing their decision-making on must-carry/retransmission consent elections, which need to be in their public files by October 2 (as the 1st is a holiday).  In preparation for the early November filing window for new LPFM stations (see our article here), potential applicants should be determining if a station can technically “fit” in their area without prohibited shortspacings to other stations; if one can be located in their area, they need to locate a transmitter site; and they need to take all the steps other steps needed to be ready to file their application in the early November window.  One of the first regulatory dates of note in September is the freeze on FM translator modification applications that goes into effect on September 1 in anticipation of the LPFM window.  The freeze will be in effect at least through the end of the LPFM filing window on November 8. 

September will also bring the date for the filing of annual regulatory fees by commercial stations.  We recently noted that the FCC earlier this month released its Report and Order setting the amount of the annual regulatory fees that broadcasters must pay, but the Commission has not yet followed up on that Order by issuing a Public Notice setting the dates for payment.  As these payments must be made before the federal government’s October 1 start of the new fiscal year, we expect that Public Notice any day.  We also expect that, as in the past, the FCC’s Media Bureau will release a fee filing guide for the broadcast services.  Licensees should continue to monitor this item closely so that they are ready to pay those fees in a window that will open in September, as the failure to timely pay regulatory fees will result in substantial penalties.

Continue Reading September Regulatory Dates for Broadcasters – Regulatory Fees, HD Radio Power Increase Comments, EAS Filings, and Preparation for Many October Deadlines  

Here are some of the regulatory developments of significance to broadcasters from the past week, with links to where you can go to find more information as to how these actions may affect your operations.

  • Around this time of year, the FCC typically issues a Public Notice reminding TV broadcasters, cable operators, satellite television services,

While there are certainly policy issues throughout the media industry, it is often the small, routine issues that trip up broadcasters.  In the last week, there have been two public notices worth noting – one announcing the final transition of broadcast applications to the LMS database, and a second reminding broadcasters that Biennial Ownership Reports

Here are some of the regulatory developments of significance to broadcasters from the last week, with links to where you can go to find more information as to how these actions may affect your operations.

  • FEMA officials announced at the NAB Show that there will be no national EAS test in 2022. FEMA is planning

Here are some of the regulatory developments of significance to broadcasters from the last week, with links to where you can go to find more information as to how these actions may affect your operations.

  • The FCC adopted two items of interest to broadcasters that were on the agenda for its January 27 Open Meeting.

The FCC sent out a flurry of reminders to broadcasters who did not file their Biennial Ownership Reports by the December 1, 2021 deadline.  As we wrote in our reminder in November, these reports were to be filed by licensees of all full-power radio and TV stations (commercial and noncommercial), as well as by

While Thanksgiving is in the rearview mirror and the holiday season is upon us, broadcasters cannot ignore the regulatory world until the new year, as much is going on in December.  Below are some of the several important regulatory dates and deadlines in the coming month that you may need to deal with before the celebrations begin.

By December 1, all licensees of commercial and noncommercial full power TV, Class A TV, low power TV, AM radio, and FM radio stations must submit an ownership report that details the licensee’s ownership structure as of October 1, 2021.  The FCC has warned that there will be penalties for stations that do not file these reports.  Licensees with ownership structures that include parent entities must also file a report for each of those entities.  An informational session run by FCC staff is archived, here, and answers to frequently asked questions are available, here.  See our blog post covering ownership reporting, here.
Continue Reading December Regulatory Dates for Broadcasters: Ownership Reports, License Renewal Filings, EEO Filings and Reporting, Ancillary or Supplementary Service Fees, Political Advertising Reports, and More

On December 1 of this year, Biennial Ownership Reports are due to be filed at the FCC by all full-power radio and TV stations, commercial and noncommercial, as well as from Class A TV and LPTV operators.  These reports are due every two years.  While the last two biennial reports that had been due in December 2019 and in December 2017 had their deadlines extended to early the next year because of issues with the FCC forms that were at that point still being refined, no such issues are expected this year. In fact, a month ago when the window opened for filing these reports, the FCC released a Public Notice reminding broadcasters of the filing deadline, emphasizing its importance, and issuing this warning that there may well be fines or other penalties for stations that do not timely file this required report:

Consistent with the importance of this information, Commission staff intends to pursue enforcement actions against licensees that fail to file their biennial ownership reports in a timely or complete manner. 

Why does the Commission collect this information?  Biennial ownership information not only keeps track for the public of who owns broadcast properties, but it also allows the Commission to track broadcast ownership.  In recent years, the reports ask for the gender and race/ethnicity of owners of stations (and control parties of noncommercial stations), and the Commission plans to use this information to track industry ownership trends.  This was an issue in the most recent change in the broadcast ownership rules, where the Third Circuit, before being overturned by the Supreme Court, had wanted the FCC to determine the impact of past changes in its ownership rules on minority and female ownership – and the FCC fought back, claiming that it did not have that information (see our article here).  These reports are one way in which such information is supposed to be provided by the FCC.
Continue Reading Less than a Month to Go – Reminder to Broadcasters to File Biennial Ownership Reports by December 1 or Potentially Face Penalties

Here are some of the regulatory developments of significance to broadcasters from the last week, with links to where you can go to find more information as to how these actions may affect your operations.

  • The Copyright Office initiated a study of the rights of publishers, to explore ways to assist local journalism. The notice

Here are some of the regulatory developments of significance to broadcasters from the last week, with links to where you can go to find more information as to how these actions may affect your operations.

  • ViacomCBS and its subsidiary Pluto TV agreed to pay $3.5 million and enter into a consent decree with the FCC