A week and a half ago we were advised by a senior Media Bureau staffer that licensees who would ordinarily have to file biennial ownership reports (FCC Form 323) on June 1 and August 1 would still have to do so this year, even though the Commission has already decided that everybody is going to have file such reports on November 1. (The staffer indicated that the Commission had not decided how to deal with folks owing reports on October 1.)
Stop the presses – that information, which we duly reported, is (in Ron Ziegler’s felicitous turn-of-phrase) no longer operative.
In a public notice released around 6:00 p.m. on a Friday, the Commission has officially announced that it is suspending the Form 323 reporting requirement between now and November 1. In other words, if you had a report due on June 1, August 1 or October 1, you’re off the hook.
Of course, as we have also reported here, the new ownership reporting rules – including the universal November 1 filing deadline – have technically not yet become effective, and won’t become effective until OMB approval is obtained. Recognizing that that could create a problem come November, if the new rules haven’t kicked in yet, today’s public notice specifically provides that, if the new Form 323 has not yet been approved by November, then everybody who would ordinarily have had to file an ownership report between now and then will have to file on November, but using the current Form 323.