“As of” Date for 2019 Biennial Ownership Reports—Send Out Annual FCC Ownership Questionnaires to “Attributable Parties”.
Biennial Ownership Reports (FCC Form 323 for commercial stations and FCC Form 323-E for noncommercial stations) for 2019 are due to be filed electronically with the FCC by December 2, 2019. The Reports must be current as of October 1, 2019. To facilitate the biennial ownership reporting process, all broadcast licensees should collect responses to an Annual FCC Questionnaire from all officers, directors, and other “Attributable Parties.” The purpose of the Annual FCC Questionnaire is to satisfy the FCC’s requirement for licensees “to make diligent, good faith efforts to become knowledgeable” of any matters that should be reported to the FCC, and it makes the biennial reporting process easier. You may wish to contact your FCC counsel to assist you with the Biennial Ownership Reports and Annual FCC Questionnaires.