June 1 Deadline for Noncommercial Broadcast Stations to File Biennial Ownership Report

Davis Wright Tremaine LLP
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Affected Station Groups:

Noncommercial Radio Stations in: Arizona, District of Columbia, Idaho, Maryland, Nevada, New Mexico, Utah, Virginia, West Virginia, and Wyoming

Noncommercial TV Stations in: Michigan and Ohio

By June 1, 2011, noncommercial radio stations in Arizona, District of Columbia, Idaho, Maryland, Nevada, New Mexico, Utah, Virginia, West Virginia and Wyoming, and noncommercial television stations in Michigan and Ohio, must prepare and file electronically a Biennial Ownership Report with the Federal Communications Commission (FCC) using the current noncommercial FCC Form 323-E..

Please note, this filing date applies only to noncommercial radio and TV stations in the states listed above. The FCC has revised its rules regarding the reporting of ownership interests for commercial broadcast stations, as well as revised the commercial Ownership Report—Form 323. Accordingly, commercial stations now file Biennial Ownership Reports on one unified filing date.

Noncommercial stations, on the other hand, continue to follow the previous rules for the filing of Biennial Ownership Reports on FCC Form 323-E, which has not been revised. The FCC is currently conducting a rule making proceeding to potentially change some of the ownership reporting rules for noncommercial licensees, but meanwhile, noncommercial broadcast stations continue to follow the existing rules.

Accordingly, as June 1, 2011, marks the two-year anniversary of the filing of a Biennial Ownership Report for noncommercial stations in the above-referenced services and states, those stations must now file a Biennial Ownership Report to update their ownership information or affirm the information currently on file. Ownership Reports are filed every other year to report on changes in the licensee's ownership and update the information requested by the form. Ownership information must be provided for all attributable owners of the licensee (see below).

Please see full publication below for more information.

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