As of October 1, 2021, the Federal Communications Commission (FCC or Commission) has opened a window during which licensees of commercial and non-commercial full power television, Class A television, low power television, AM radio, and FM radio stations may file their requisite biennial ownership reports. These reports must be filed by December 1, 2021 and must reflect ownership of the licensee as of October 1, 2021.
In a Public Notice released earlier this year, the FCC’s Media Bureau reminded broadcasters that, as part of its review of license renewal applications, Bureau staff will be reviewing whether licensees have filed their 2019 and 2021 biennial ownership information and whether they have certified truthfully concerning compliance with the filing requirement. The Bureau explained that licensees that fail to file their biennial ownership reports could be subject to Commission staff action, including enforcement actions for falsely certifying compliance with the biennial ownership reporting obligation on their license renewal application.
To prepare for the filing window, broadcasters should review their most recent biennial or post-consummation ownership reports and identify:
We urge licensees to focus on their ownership reports early in this process – we find that those who wait until just before the December 1 deadline are often frustrated by slowness or other technical difficulties with the FCC’s online filing system.