Earlier this month we reported (in connection with the release of the Report and Order (R&O) relative to modifications to Form 323, the Broadcast Ownership Report) that the FCC has decided to have all broadcasters file their biennial Ownership Reports on November 1, starting this coming November. The uniform filing date replaces the previous, staggered, approach in which each licensee filed on the anniversary date of its renewal application.

As we noted, the R&O is silent as to biennial reports that are due between now and November – i.e., on June 1, August 1 and October 1. Our initial assumption was that the FCC’s silence should be viewed as an indication that those intervening reports would still need to be filed, even though they will then be re-filed less than six months (max) later. But you know what happens when you assume anything – so we took the bull by the horns and contacted the Commission to check on this. 

The answer? We have been advised by a Media Bureau representative that, sure enough, biennial Ownership Reports currently due to be filed by June 1 and August 1 will still have to be filed on or before those dates. We are also told that the Commission is still considering whether to suspend the requirement for reports due to be filed by October 1. 

But all is not lost. Apparently some thought is being given to waiving the filing fees for the November 1 report for those that file in June and August.  Who says the Commission doesn’t have a heart?