Media Bureau Issues Reminder on Biennial Ownership Reports

The FCC’s Media Bureau has taken notice of license renewal applications reporting issues or delays in station biennial ownership report filings for the prior license term.  We’ve directly heard from the FCC staff on more than one occasion that late or missing biennial ownership reporting has now gotten the attention of the Acting Chair’s office and has delayed the processing of renewal applications that either report or have biennial ownership report issues. We think that is what prompted the Media Bureau’s recent reminder about broadcaster obligations to file biennial ownership reports.  Here’s an important excerpt from that reminder:

We remind licensees that, as part of its review of license renewal applications, Bureau staff will be reviewing whether licensees have filed their 2019 and 2021 biennial ownership information and whether they have certified truthfully concerning compliance with the filing requirement.  Commission staff may pursue actions against licensees that fail to file their biennial ownership reports, including enforcement actions against any that make a false certification of FCC Form 2100, Schedule 303-S regarding the filing of such reports.

Sounds kind of ominous, doesn’t it?  As is often the case, the Media Bureau sometimes decides to “warn” broadcasters before taking enforcement actions.  This “reminder” may be such a warning.  We’ll add one here – if your station’s ownership reports were not timely filed during the last license term, answer the renewal ownership report certification “no” and attach an explanation.  Honesty wins the day at the FCC.

The normal deadline for all stations to file their biennial ownership reports is December 1^st in odd-numbered years.  In 2019, the FCC extended the deadline until January 31, 2020.  For the reports due in 2021, we do not anticipate an extension.  Biennial ownership reports must include information current as of October 1 of the filing year, and typically, the FCC enables the form menu to include that date and enables preparation and filing of the form beginning on October 1st.  Set your calendar.