It’s still summer, but it’s never too early for commercial broadcasters to start thinking about Biennial Ownership Reports. Because 2015 is an “odd year,” Ownership Reports will be due on November 2, 2015 (the 1st is a Sunday). (NCE stations are required to file Biennial Ownership Reports every two years on the station’s renewal anniversary date or, with the proper notice to the FCC, on the renewal anniversary date of a commonly owned station.) Broadcasters who have been through Ownership Reports before know that the drafting process is tedious and time consuming. As such, it’s a good idea to start planning early.
Ownership Reports are currently filed in CDBS on FCC form 323. As the FCC continues its transition from CDBS to the new Licensing and Management System (LMS), however, it’s likely 2015 Biennial Ownership Reports will be filed in LMS using form 2100 and a designated schedule. Fortunately (or not) there shouldn’t be any substantive differences between the schedule and form 323. A separate form 323/schedule must be filed for each “level” of a company’s ownership structure (for example, separate 323s/schedules must be filed for the licensee of a TV or radio station, the parent of the licensee, the parent’s parent, etc.). Individuals and entities with an “attributable interest” in the entity for which the form/schedule is filed must be reported. Individuals with an attributable interest must disclose their name, FRN, gender, ethnicity and race. If any attributable individual or entity has an attributable interest in another broadcast station or certain newspapers outside the “ownership chain” for which the Report is filed, that too must be reported.
The Commission has also started to think about Ownership Reports. On July 30, 2015, the Commission announced that it will host an all-day public workshop on Wednesday, September 9, 2015 to “discuss access to, and use of, the FCC’s commercial broadcast ownership data.” The workshop will be targeted at public interest organizations and members of the public interested in mining ownership data. As such, the workshop will address topics such as data that the FCC collects; how members of the public can access those data; and mechanisms for querying, studying, and visualizing the data, including in combination with data available from non-FCC sources. Because much of the content will be technical in nature, the Commission encourages attendees to bring their own laptops. The workshop will be held in the Commission Meeting Room at FCC Headquarters, 445 12th Street, SW, Washington DC, 20554. The workshop will also be broadcast live on the Internet at www.fcc.gov/live.