The changes in the FCC’s rules for Biennial Ownership Reports on FCC Form 323 were today published in the Federal Register. That publication starts the 30 day clock for petitions for reconsideration or requests for appeal of that decision. We summarized the changes in the requirements here – changes that include putting noncommercial stations on the same schedule as commercial stations (filing on December 1 of odd-numbered years) and requiring that all licensees obtain, for every person or entity with an attributable interest, an FCC Registration Number (an “FRN”). To get an FRN, the licensee must either submit the Social Security number (“SSN”) of the person with an attributable interest (or the Taxpayer ID number if the interest holder is not an individual) or the last four digits of the SSN plus other identifying information (their full name, residence address and date of birth). The requirement for an FRN has triggered concern among many broadcasters, particularly those where licenses are held by a college or university.
Why? Some licensees fear that, even though the personal information necessary to get an FRN will not be made public, the submission of that information to the FCC may still somehow compromise the security or privacy of individuals with attributable interests. While the FCC assured licensees in its order that these concerns are overblown as the Commission says that it maintains information with a high level of security, there are still doubters. Nevertheless, the FCC has required that the FRN be obtained for all attributable interest holders, and threatened to take enforcement action against interest holders who refuse to comply. The FCC also identified for whom the information needs to be provided.
Continue Reading Appeal Date Set for Changes in FCC Rules for Biennial Ownership Reports – Why Many College and University Licensees are Concerned