RBR+TVBR Investigates: Does a Deal Dollar Re-do Need FCC Notification?


Thanks to the COVID-19 pandemic, asset purchase agreements filed with the FCC prior to March 16 — in particular those for radio stations — may have led the buyer and seller to revise the final purchase price of payment terms associated with any deal that closed after the end of the first quarter of 2020.

Do the sellers of a broadcast media property have an obligation to notify the FCC if they close a sale for a demonstrably lower, or different, price than what was listed in the original APA the FCC granted?

It’s a question presented to RBR+TVBR by a reader, and we shared it with several esteemed Washington, D.C. communications attorneys. Two responded.

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