On an Order in MB Dockets 07-294 and 10-234, the FCC has announced the suspension of the filing deadline for biennial ownership reports that would be filed by full-power non-commercial educational (NCE) stations. This order only applies to biennial filings that are due on the anniversary of renewal dates. Other triggers to file an ownership report (such as within 30 days of the grant of an original construction permit or within 30 days of consummation of an assignment or transfer) are not affected by this order and still need to be filed.
Under new reporting requirements, NCE stations (and entities with attributable interests in NCE stations) will be required to file by December 1, 2017 using "Form 2100, Schedule 323-E". "Form 2100" is the FCC's Licensing and Management System (LMS). LMS is the next generation FCC broadcast licensing system that will replace the legacy Consolidated Database System (CDBS) that the FCC has been using 1999. Video services have already converted to LMS a few years ago. The key differences between CDBS and LMS is that broadcast applications of all types are filled out on a basic form and then "schedules" are added for specialized reasons. Similar to how taxes are filed with the Internal Revenue Service. LMS also works solely off of the FRN password so gone are the days of the separate CDBS password under a full LMS environment. We do note that the FCC has not announced any other radio filings other than the ownership reports will be going to LMS at this time.
We do note that under the current rules, LPFM stations are not required to file ownership reports (either biennial or after a trigger event). LPFM stations that experience a board of directors change that impacts over 50% of the voting membership must file for a transfer of control using Form 316 prior to the board change and once granted and the board change is made, a consummation notice is filed within 30 days of the board change.
For more information about the rules regarding Ownership Reports, see ยง73.3615.
