In our postings last month, we shared the news that the deadline for responses to the Federal Communications Commission (“FCC”) mandatory ownership information collection (“Information Collection”) applicable to all holders of international Section 214 authority (“International 214 Holders”) has been set as January 22, 2024. We also circulated links to the guidance materials issued by the Office of International Affairs (“OIA”), including the December 13, 2023, Public Notice overview of the process, the detailed 24-page Handbook with a walk-through of responding to the information requests, and a link to the dedicated webpage established by OIA to gather all the related materials and information in one location. Responses are to be submitted through a newly created One-Time Information Filing System.

International 214 Holders that received a grant of authority from the FCC for a substantive (non pro forma) transaction, such as a transfer of control or an assignment, within the last three years may be eligible for an exemption and will want to examine the criteria for an exemption closely. International 214 Holders qualifying for the exemption will be able to file a considerably more streamlined response to the Information Collection requirement.

We remind International 214 Holders that before they can even begin to submit their responses, they must ensure that they have a current FRN (FCC Registration Number) associated in the International Communications Filing System, or ICFS, database with the specific international Section 214 authorization(s) for which responses are being submitted. Instructions for confirming this association are provided in both the Public Notice and the Handbook. Arranging new associations and/or correcting existing associations must be coordinated through FCC Staff. (The volume of requests for Staff assistance with the response process is likely to be high and parties should not delay in determining whether they will need such assistance and making the request.)

As discussed in our December 15, 2023, Advisory, we also remind parties needing to file responses that the One-Time Information Filing System appears potentially challenging in its logistical constraints. To minimize complications during the process, we recommend close review of the Public Notice and Handbook before submitting responses to the Information Collection.

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