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New Ownership Forms This Week

And an interim solution for SSN requirements

The new commercial broadcast ownership form is about to be released; and the Federal Communications Commission also has issued an interim response to concerns regarding the use of social security numbers for the form.

FCC Form 323 will become available online tomorrow (Dec. 9) in the FCC’s CDBS electronic filing system. On that day at 2 p.m., the agency will hold an online workshop about the new form. The commission also created a special Web site about Form 323 that contains links to prior orders and notices and includes “Frequently Asked Questions.”

The revised form requires that individuals and entities reported on the document obtain and provide an FCC registration number, which requires a taxpayer id number. In order to provide that, individuals need to provide social security number and entities need to submit an employer ID.

Some entities, including the law firm Fletcher, Heald and Hildreth and the Minority Media Telecommunications Council, objected to the SSN requirements, calling them intrusive.

In response, the FCC said this week the new Form allows filers to obtain a “Special Use FRN” in cases where the filer cannot get an FCC registration number for any specific individual required to be reported on the document. The electronic form contains a mechanism for generating the interim Special Use FRN “solely for the purposes of completing the form.”

The commission said filers should use their “best efforts” to obtain FRNs from all attributable interest holders. Those who use the “Special Use FRN” option are still expected to eventually get a “fully compliant” FRN, which must be used in future biennial ownership report filings.

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