FCC Registration Number Reality Check

A few days ago, an order that the FCC adopted a year ago sparked a bit of a “panic” about broadcast licensees having to immediately update information associated with FCC registration numbers, or FRNs as they are called. The panic was unfounded, but we thought it might be a good idea to clarify a few things.

Several years ago, the FCC adopted a requirement that those doing business with the FCC – like broadcasters and those who own them – obtain a registration number that required submission of a name, social security or taxpayer id number, address, email and other information. The FRN had many purposes, from adding security to tracking ownership information. After broadcasters made noise about it, it became possible to obtain an FRN by only submitting the last four of your social security number (a Restricted Use FRN) and for non-profit entities, an auto-generated FRN (a Special Use FRN).  The FRN used to have a distinct password but the FCC later restricted use of the FRN to only those who registered and obtained a CORES username that was then associated with the FRN. By that association, a licensee can control who can access FCC systems or make filings in their name.

So, what was this “FRN panic” all about?  Well over a year ago, the FCC adopted an order about submissions into its Robocall Mitigation database, which requires phone service providers to use FRNs to make those submissions. Concerned about potential errors that were being introduced into that system, the FCC decided that updates to FRN information should be made within 10 days of any changes to that information. In doing so, it cited in a footnote to a 2017 decision where the FCC fined a broadcaster for failing to maintain required records (the base fine for which is $1,000).  With that Robocall order having become effective on February 5, broadcasters suddenly began receiving an avalanche of warnings from (well-meaning) third parties to quickly update their FRN information by February 15 or be fined $1,000 per day.  The scramble that resulted caused the FCC’s CORES system (which itself requires the email of a code in order to gain access) to completely shut down from the number of login attempts.

As was later clarified, the order itself was not directed at broadcasters, and it did not demand FRN updates within 10 days of the order’s effectiveness with the threat of a fine attached. So, there was that reason not to panic.  Then, there was this notice a day later from the Wireline Bureau making clear that the fines for failure to update FRN information were directed specifically at Robocall Mitigation database users.

But the order did address the accuracy of FRN information, and the importance of submitting accurate information to the FCC.  So, no sudden “sweep” of FRN records is occurring, and the FCC isn’t gunning for FRN holders or broadcasters.  But in time, we do recommend that broadcasters log in to CORES and check the current address, phone and email information for the company FRN and those owners or officers who also have FRNs.