From our “The Job’s Never Over ’Til The Paperwork’s Done” file
Here’s a tip for anyone who’s buying a station the assets of which include a tower subject to FCC registration.
When ownership of an antenna structure which is subject to FCC registration changes hands, the new owner must update the tower’s Antenna Structure Registration (ASR) to reflect that change. The update does not occur automatically when notice of consummation of the assignment of the station’s license if filed with the FCC. Moreover, the Commission has made clear that responsibility for insuring that the notification is made falls on the buyer, not the seller. Since the ASR information is in a separate FCC database, it needs to be updated separately. Way back in our March, 2004 Memo to Clients, readers were reminded of this relatively obscure requirement.
We mention this here because a couple of licensees apparently didn’t get the memo: both were the subject of recent forfeiture orders – to the tune of $3,000 each – for failing to update their ASR tower ownership. (You can read those orders here and here.)
So, apparently, you can either remember to update the FCC’s records, or you can run the risk of having to fork over $3,000. Your call.
Updating ownership information is a relatively simple on-line chore – one which certainly seems to be easier than writing a $3K check to Uncle Sam. You go to the FCC’s ASR homepage, login (you’ll need your FRN and FRN password for that), and work your way through a number of screens. We’ll get you started: (1) The first choice you have to make is simple: pick “Manage Your ASR Numbers”; (2) at the next screen, select the option for “OC – Ownership Change”, and then click “continue”. You’ll encounter several more screens after that. You’ll need the FRN of the tower’s seller (since the tower’s registration presumably is listed under the seller’s ID), and it will be helpful to have the registration number(s) of the tower(s) changing hands. The later screens may not be as obviously user-friendly as, say, your favorite ATM, but not to worry – you should get the hang of it in short order.
And remember, by taking care of this little chore, you’re insuring yourself against a potential $3,000 disappointment.