Post-Auction Television Repack Important Deadlines Near

A critically important post-auction television repack deadline is right around the corner. Specifically, July 12, 2017 is the deadline for all repacked and voluntarily relocating stations to file a construction permit application for their allotted facilities. This application is filed on FCC Form 2100 in the Licensing Management System. Many stations have already filed this form, but several hundred stations still need to do so. When filed, the FCC has been granting permits very quickly, sometimes by the next calendar day.

For repacked television stations, the Form 2100 is not the only filing that must be made by July 12, 2017. In addition, repacked stations must also complete and file a Form 399 reimbursement expenses estimate so the FCC can allocate funds for station channel change build outs.  Repacked stations entitled to reimbursement will ultimately have to prepare and file Form 1876 to set up a bank account that will receive reimbursement funds. A PDF-fillable form is available to repacked stations when they access their Form 399 in LMS (look for an icon at the top right of the page). The form can be downloaded to your computer to complete, as it will not be electronically filed but instead must be mailed or overnighted to a specific address provided by the FCC.

The Form 1876 process includes tedious details, apparently because money is involved. So there are a few precise steps that are critical. One such step is the requirement that the bank account be in the same name as the FRN holder (or else you need a bank letter explaining the difference). Another is that the licensee/FRN holder taxpayer identification number has to be listed on the Form 1876 and must be identical to the taxpayer identification number associated with the FRN (if not, you’re headed to the CORES help desk for a fix). The slightly good news with Form 1876 is that there is no set deadline for it to be filed, the only caveat being that you can’t get reimbursed for a repack expense until the form is filed and the bank account verified. But the FCC has recently sent reminders that Form 1876 is a necessary filing, encouraging stations to get them on file. In addition, they’ve issued a bit of a guide called “FCC Form 1876 – Getting it Right” that includes helpful hints like “please do not use white out anywhere on the Form 1876” and “please provide a bank letter or redacted bank statement that is less than four months old.”

Before you grind your teeth beyond repair, let us know if you need help. One friendly suggestion to pass along – open a new checking account at your bank, and use only that account to receive reimbursement dollars and pay reimbursement expenses. It will simplify internal accounting, and make things much simpler if the FCC decides to audit your reimbursement expenses (yes, they can do that).