While radio license holders should make every effort to keep their contact information registered with the FCC up to date, they are not under threat of a $1,000-per-day penalty for failing to do so.
That is according to a public notice the commission issued Friday. The confusion stems from a robocall mitigation database proceeding it released the day prior.
In that proceeding, the commission announced that it had received approval to require every holder of an FCC Registration Number (FRN) to update their contact information within 10 business days of a change or face a $1,000-per-day fine.
This announcement alarmed broadcasters, as all corporate and individual owners of station licenses in the FCC’s LMS database are tied to FRNs.
The panic led to a surge in traffic on Friday that overwhelmed the FCC’s website as licensees rushed to verify their information, according to Scott Flick of Pillsbury’s Comm Law Center, who has been following the FRN-related developments.
Some licensees even interpreted the notice to mean that if they didn’t log in to update their FRN within 10 days of the FCC’s notice, regardless of whether or not any underlying change occurred to their contact information, they would face the forfeiture.
The FCC’s late Friday public notice walked back this interpretation. The commission clarified that the new, steeper base forfeitures — $10,000 for false information and $1,000 per day for failure to update — apply only to RMD filers, such as voice service providers.
“The robocall mitigation database report and order did not address or change any forfeiture amounts that may be associated with failures to update the CORES information by non-RMD filers,” the update read.
Flick called the update a “win.”
No bouncing emails
But despite the relief, the underlying requirement is still in effect. All entities with an FRN — including radio stations — must update their CORES contact information within 10 business days of any change, such as a change in address, email or contact person.
John Broomall of Christian Community Broadcasters told us that, while he always advises for his clients to keep contact information up to date, this is the first time he can recall such a focus on it from the commission.
But for Broomall, it’s a necessary practice.
“When a consultant such as myself emails clients to ‘keep their info current,’ and the emails bounce, that is a conundrum,” he surmised.
While broadcasters are safe from the new “robocall” penalties, maintaining accurate FRN data remains a regulatory necessity. As Flick noted, if these penalties can be levied against telecom providers for data lapses, it creates a potential pathway for broadcaster fines in the future.
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