Ownership reports
A biennial ownership report is due in each odd-numbered calendar year (2023, 2025, etc.), in a filing window from October 1 until November 30 of that year.  All stations report this data as of October 1, so that it the FCC can publish and analyze overall totals.  

A Non-Biennial Ownership report is required to be filed within 30 days of the consummation of an assignment or transfer, for the purpose of updating the station’s profile to include the new facility.  These are pull-down menus under ownership in the LMS (Licensing and Management System – see below).  The most current Ownership Report should be in the stations’ files.

License Renewal Applications                                                              Applications to renew your license must be filed every eight years.  The deadlines are spaced across the States and Territories, so that FCC staff can keep a manageable workflow from month to month.  Radio including AM, FM, LPFM, and FM Translators have a schedule of States that is separate from Television including TV, LPTV, Class A, and TV Translators.  In all cases for TV and radio, the application filing deadline is the first day of the fourth month ahead of the date that the license will expire if not renewed.  (A pending but not granted renewal application extends the license until the FCC acts on the application.) 

Some advance time and effort are needed before the renewal application deadline.  The applicant must already have on file: the most recent required EEO report and the most recent required Ownership Report. 

A late renewal application automatically exposes the station to a fine, and delays FCC staff granting the renewal.  The FCC does not notify the licensee that its license is coming up for renewal.

When applying for your renewal, you are required to give public notice of the filing of the application, using on-air announcements.  When these are completed, you are required to upload a certification to the on-line public information file that they have been completed.

Equal Employment Opportunity report                                                                An Equal Employment Opportunity (EEO) report must be filed prior to submitting a license renewal application. 
EEO reports are due mid-term (four years before the license renewal application is due), and prior to the filing of the renewal application.  For stations with five or more full time employees, the report must reflect and detail a pro-active EEO program.  For stations with fewer than five full-time employees, the filing is short and sweet.  A common misconception is that stations with fewer than five need not file any report at all.  This is false. 

Special Temporary Authority:                                                                                  If your station has had to reduce power or go silent for a period greater than ten days, you must file a Special Temporary Authority (STA) with the FCC, as soon as possible at https://www.fcc.gov/applying-special-temporary-authority

Political Files
NCE’s are prohibited by law from accepting political underwriting. If you are approached by a candidate, you must decline, but you still must document that this happened, placing the report under the Political File heading in the on-line public file.  

Underwritten Programs
Only those underwriters who support specific programs need to be reported.  General donation, grants, and station support do not need to be reported. However, some stations submit regular reports of all their underwriters anyway, for purposes of transparency. This category does not include underwriting for syndicated programs that do not fund your station.

Non-Biennial Ownership Reports / Transfers of Control:                                    

If your station’s board of directors has changed by more than 50% since your last since their last biennial or non- biennial report, an ownership report is required be filed with the FCC, within 30 days after this “transfer of control.” You must file Form 323-E                                      https://www.fcc.gov/media/ownership-report-commercial-broadcast-station-form-323                                  https://www.fcc.gov/sites/default/files/323e.pdf

Explanation:                                                                                                            When more than a majority of the board of directors change, the station is obligated to file an application that requests FCC approval of a “transfer of control.” This is not a function of the calendar, so the station must take the initiative to file an application that requests FCC approval.

You can determine whether an application is required by comparing the composition of the current board of directors with the last board of directors on record, approved by the FCC – i.e. the station’s last license renewal application or last transfer of control application approved by the FCC.

The application must be placed in the station’s Public File. After the application is granted, it can be replaced in the Public File with the FCC’s authorization that approves the transfer

Definition of Ownership:
(b) Ownership Interests. Ownership interest in or relationship to a Licensee that confers on its holder a certain degree of influence or control over the Licensee as defined in the Commission’s rules.

https://esupport.fcc.gov/help/form_603.htm?job=help_topic&id=form_603&page=help_about

 A pro forma assignment or transfer is one in which the form of ownership changes but actual control of the license remains with the same entity. Pro forma assignments and transfers may be approved under streamlined Forbearance procedures in the case of most telecommunications carriers (excluding licensees with installment payment or designated entity issues). These pro forma requests do not require prior FCC approval provided that the parties notify the FCC of the change within 30 days. Note that private licenses are not subject to forbearance. FCC approval is required for private pro forma transfers and assignments.

Adverse Adjudication Report
This is to report illegality or criminality. Each year prior to the deadline (see below), the station should survey its staff and board members to find out if any of the following has happened to them in the past year:

(A) An adverse finding was made, or final action was taken against the licensee or its board members or officers (or any other entity in which such individuals hold an attributable interest) by any court or administrative body in a civil or criminal proceeding, brought under the provisions of any law relating to: 1) Any felony; or 2) Broadcast related antitrust or unfair competition; or 3) Criminal fraud or fraud before a governmental unit; or 4) Discrimination.

(B) An adjudicated matter that would cause the denial of Federal benefits pursuant to Section 5301 of the Anti-Drug Abuse Act of 1988.

The adverse adjudication report does not need to be filed if there have been no relevant adverse findings.  If you are in the (fortunately rare) position of needing to file this report, get legal help in its preparation. 

The adverse adjudication report is due on the anniversary date of the deadline for filing the renewal application, Section 1.65(c) 0f FCC Rules. It details activities that occurred at any time in the preceding year. 

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