Items of Note in 2020

I. Applications for Renewal of License: June 1, 2020 is the first filing deadline in the three-year long license renewal cycle for stations in the television services (full-power television, Class A, TV Translator, and LPTV). The renewal cycle for radio services (AM, FM, FM Translator, and LPFM), which began on June 1, 2019, continues into 2020. Stations will file their license renewal applications on FCC Form 2100, Schedule 303-S (“Form 303-S”) along with their Equal Opportunity Employment Reports on Form 2100, Schedule 396 (“Form 396”). The date by which the licensee must file a station’s application for license renewal depends on the state or territory of the station’s community of license. All licensees should familiarize themselves now with the dates associated with this important filing, including the dates on which pre-filing public notice announcements must air, the filing deadline itself (which is approximately four months before the date of license expiration), and the dates on which post-filing announcements must air.

II. Commercial and Noncommercial Biennial Ownership Reports: January 31, 2020 is the deadline by which licensees of commercial and noncommercial radio and television stations, as well as entities with attributable interests in such stations, must file their biennial ownership reports. Commercial stations will file FCC Form 2100, Schedule 323 (“Form 323”), and noncommercial stations will file FCC Form 2100, Schedule 323-E (“Form 323-E”). The filing deadline was extended from the original filing deadline of December 2, 2019 to allow the FCC to implement technical improvements to the Form 323/323-E report in the FCC’s Licensing and Management System (“LMS”). This cycle’s filing window opened November 1, 2019, and the information in all ownership reports must be accurate as of October 1, 2019.