Too much risk, no real benefit seen in required submission of social security numbers
The murky situation surrounding the FCC’s effort to deploy its revised Ownership Report (FCC Form 323) just got murkier with the filing of a letter from the Minority Media and Telecommunications Council (MMTC) on November 18. In its letter, MMTC lets the FCC know, in no uncertain terms, that the new form’s mandatory inclusion of individuals’ FRNs “would represent an unnecessary invasion of personal privacy.”
And that’s just in the first paragraph.
The MMTC letter is particularly significant because MMTC is seen by many as a – and, by some, the – preeminent representative of minority interests before the Commission. The new Form 323 is intended to provide the Commission with a clearer picture of minority and female ownership in the broadcast industry, presumably so that the Commission might be able to justify more aggressive “affirmative action” policies aimed at increasing minority/female ownership. But if even the MMTC believes the revised form goes Too Far in requiring private information, the Commission may be inclined to rethink its revised reporting approach.
MMTC’s letter includes some suggested alternatives which the Commission could, and probably should, explore. But with the December 15 reporting deadline looming less than four weeks away, it’s unclear how the Commission might do so . . . without, that is, abandoning that December 15 date. Of course, had the Commission announced its proposed revisions publicly last June and given us all an opportunity to comment on them (like the Commission is ordinarily expected to), this last-minute uncertainty could have been avoided.
Check back to www.commlawblog.com for updates on this evolving situation.