Ownership Reporting 2017 (now 2018)

Citing the need to finalize the new form and make it available for electronic filing for the first time in the License Management System, the FCC has announced a two-month extension of the deadline for all broadcast stations to file their 2017 Biennial Ownership Reports. As a result, reports that would have been due by December 1, 2017, are now due no later than March 2, 2018. The old filing schedule for noncommercial stations that was suspended a year ago will extend through March 2, 2018 as well (i.e., a noncom station with a report due on Jan 1 under the old schedule should wait until March 2^nd).

Despite the extension, all stations will still need to pay attention to and capture their ownership as of October 1, 2017. That’s because the biennial report – though extended into 2018 – will still have to report a station’s ownership information as it was on October 1, 2017. That’s the case even if a station’s ownership changes in the five months between that date and the new March 2, 2018 deadline.

The new form isn’t available for stations to review or become familiar with yet. But the FCC promises that when it is, a public notice will be issued and assistance provided to stations as needed. You won’t be able to start working on a draft of the form within LMS until December 1, 2017 though, which is when the FCC will “open” the window for filing the form. We are not clear yet on how “smart” the form will be, or whether it will populate information from previously filed forms in CDBS. These factors could make completing the form more difficult and time-consuming.

Notable aside: March 2^nd is the day after the March 1^st deadline for all broadcast stations to have completed a migration of their public file to the FCC’s online portal. So if you’ve not taken a step toward getting online with your station’s public file, now is a good time to start preparing.