Earlier today, the Federal Communications Commission’s (FCC) Office of International Affairs (OIA) released a Public Notice announcing the opening of a one-time information collection filing window for all companies holding an International Section 214 Authorization (FCC 214 License or 214 Authorization) to provide the FCC with updated foreign ownership information.  As our firm previously advised in April and again in late October, the MANDATORY information filing requirement emanated from the Evolving Risks Order and NPRM adopted by the FCC on April 20, 2023.

Key Details:

• Filing Window: The electronic filing window is open from December 8, 2023, to January 22, 2024.
• Filing System: 214 Authorization Holders are required to file responses in the One-Time Information Collection Online Filing System by 11:59 pm Eastern Time (ET) on January 22, 2024.

Consequences of Non-Compliance: The FCC is considering potential measures, including authorization cancellations and forfeitures, for those who fail to respond in a timely and complete manner.

FCC Registration Number (FRN) Requirement: All 214 Authorization Holders must have an FCC Registration Number (FRN) to file their responses in the online system.

Exemption: Even if a 214 Authorization Holder qualifies for an exemption, filing a response is mandatory. The exemption requires disclosing aggregated citizenship or place(s) of organization of Reportable Foreign Interest Holders. 

Surrender Option: According to the FCC notice, 214 Authorization Holders no longer using their authorization(s) are encouraged to surrender before the filing deadline.

CALL TO ACTION!  WE CAN HELP!

We understand the complexity of these requirements and are here to provide assistance. If you have any questions or concerns or would like assistance complying with the One-Time Foreign Ownership Information Submission — either substantively (legal considerations) or administratively (accessing and utilizing FCC filing systems), please do not hesitate to contact your assigned attorney.  Alternatively, you may simply reach out to Jacqueline Fisher at jaf@commlawgroup.com.  

You will be directed to a uniquely qualified team of legal and compliance professionals that has been assembled by our firm in anticipation of this important, and potentially complicated, submission. Our firm – working together with its affiliated outsourced compliance and consulting services firm, The Commpliance Group — is standing by to assist with any legal considerations associated with the mandatory filing (particularly if there are any sensitivities or potential risks).