The new biennial report, Form 323, is finally going to be available Wednesday 12/9/09, and the FCC expects them to be filled out – but it is cutting some temporary slack in the social security number requirement.
The sticking point on the form is that it requires everybody with an attributable interest in a license to have an FCC Registration Number (FRN), and in order to get one, the FCC requires a social security number (or tax ID number). That has raised formal objections since many do not like to give that number out, and the request for it is considered unjustified, plus it came, allegedly, without proper notification and public input.
The FCC is creating a mechanism that will assign individuals a temporary limited-use FRN, just for the purpose of getting the form filled out. The FCC expects that eventually, a full-purpose FRN is acquired by all who need it, under the existing rules.
Instructions on getting the special use FRN are available under “Frequently Asked Questions” at website www.fcc.gov/form323.
Here is the full FCC statement on FRNs: “We expect all filers to use their best efforts to obtain all SSNs or TINs needed to obtain a fully compliant FRN and to file a complete Form 323. We remind individuals who must be reported on the form that they have the option of obtaining their own FRN directly from the CORES system, obviating the need to disclose their SSNs to anyone other than the Commission. We encourage individuals to provide FRNs to filers to alleviate any concerns they may have about disclosing their SSNs to filing entities. We note that Special Use FRNs are an interim measure to ease the transition to use of the revised form. Use of the Special Use FRN does not relieve a filer of its ultimate duty to obtain a fully compliant FRN. We expect filers using Special Use FRNs to update their filed ownership reports with fully compliant FRNs when these are obtained.”
The Media Bureau will hold a workshop on filling out the form that very day at 2PM Eastern, in the FCC meeting room.
The forms are due to be returned to the FCC by 1/11/10.
RBR-TVBR observation: Advocates for licensee diversity will be pleased to see pertinent data collection proceed more or less on schedule. That does not necessarily mean that the SSN battle is over, even if complainants remain piqued merely by the perceived procedural breech. Stay tuned.