It’s official. The Media Bureau has announced that the new biennial Ownership Report (FCC Form 323) is due to be filed by December 15, 2009. Information in that form must be current as of November 1.
We have been tracking the long-running saga of the revised Form 323 for months now. If you’re not already up to speed on it, check out our posts here, here, here and here for background history. Most recently, we reported that the Office of Management and Budget had approved the revised form, and that all that was left was an announcement from the Commission, telling us all when the first reports would be due. That’s the announcement that has just been released this afternoon.
Unfortunately, there are apparently still some loose ends dangling around the new form. According to today’s announcement, the revised form will not be up and available on CDBS until sometime “on or about November 16”. That’s not quite as definite as one might like, but at least the apparent target date of November 16, if met, would provide almost 30 days during which 323s could be uploaded. The problem, though, is that every licensee of every commercial AM, FM, TV, LPTV and Class A TV station will be having to file a new Form 323 by December 15. There are more than 15,000 stations in that universe.
Plus, as we have reported, every person or entity with an attributable interest in each reporting licensee will have to have his/her/its own FCC Registration Number in order to properly complete Form 323. Our guess is that that means that a whole lot of folks will be having to sign up for new FRNs in the very near future.
Because of the very large number of forms that will all need to be completed, validated and submitted by December 15, the demands on CDBS’s resources are likely to be substantial (if not overwhelming). Obviously, the more available lead time, the better – which explains why even an anticipated 29-day opportunity strikes us as pretty close to the edge. But if 29 days is what we’re all getting, we’ll have to make the most of it.
Another loose end – In anticipation of the likelihood of a flood of questions flowing in once everybody gets a chance to start test-driving the new form (not to mention the “numerous inquiries” the Bureau has already received), the Bureau will be establishing a “website containing information regarding Form 323”. That website will include Frequently Asked Questions “with responses that will be updated continually throughout the biennial filing period”.
Unfortunately, that website apparently hasn’t been set up yet (despite the fact that, as noted, the Bureau says it has already received “numerous inquiries”), and today’s public notice does not provide an anticipated kick-off date for the site. Nevertheless, if you have Form 323-related questions that you would like addressed on the to-be-unveiled-at-some-point website, the Bureau invites you to send them to Form323@fcc.gov.
We will continue to post updates as information becomes available.