Broadcast Station Reminder: Biennial Ownership Reports for Certain Noncommercial Broadcast Stations Due Feb. 1

Davis Wright Tremaine LLP

Affected Station Groups:

• Noncommercial Radio Stations in: Kansas, Nebraska, and Oklahoma

• Noncommercial TV Stations in: Arkansas, Louisiana, Mississippi, New Jersey, and New York

By Feb. 1, 2011, noncommercial radio stations in Kansas, Nebraska, and Oklahoma, and noncommercial television stations in Arkansas, Louisiana, Mississippi, New Jersey, and New York, must prepare and file electronically a Biennial Ownership Report with the Federal Communications Commission (FCC) using the current noncommercial FCC Form 323-E.

Please note, this filing date applies only to noncommercial radio and TV stations in the states listed above. The FCC has revised its rules regarding the reporting of ownership interests for commercial broadcast stations, as well as revised the commercial Ownership Report—Form 323. Accordingly, commercial stations now file Biennial Ownership Reports on one unified filing date.

Noncommercial stations, on the other hand, continue to follow the previous rules for the filing of Biennial Ownership Reports on FCC Form 323-E, which has not been revised. The FCC is currently conducting a rule making proceeding to potentially change some of the ownership reporting rules for noncommercial licensees, but meanwhile, noncommercial broadcast stations continue to follow the existing rules.

Please see full advisory below for more information.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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