FCC Registrations Require Monitoring to Ensure Accuracy and Avoid Penalties

Much concern has arisen over the past week about a new FCC requirement that all entities and individuals who have FCC Registration Numbers (FRNs) must update their FRN information in the CORES database within 10 business days of a change, or face possible penalties. The anxiety arising from this requirement is disproportionate to the actual impact of the rule change.

The FCC has always required that FRN information “must be kept current” in the CORES database, and registrants found to have inaccurate information in their registrations have always been subject to potential monetary forfeitures. The base penalty for such a violation is $1,000. The only new aspect of the updated rule is that FRN holders are required to update their information within ten business days of a change in the relevant information – entity name and type, contact person, address, telephone number, email address, and/or tax ID number.

Accordingly, if all your FRN registration information is up to date, there is nothing you are required to do at this time to avoid penalties. If you are unsure of the status of your FRN information, now is a good time to check it and make any necessary updates.

You should also consider regular monitoring of all FRNs over which your company has control to confirm on a regular basis that they remain accurate. A simple spreadsheet can identify employees across your business and contact information that is part of the FCC database, and can be easily reviewed and updated when there are changes in company personnel, telephone numbers, email addresses, operational locations or other information.

As a practical matter, the accuracy of FRN contact information is most likely to become an issue as a direct result of FCC outreach efforts (for example, regarding potential rule violations, licensing issues, or interference complaints) that end up going unanswered because the licensee is not aware of them.

For more information about the FCC’s requirement to update FRN information, or for assistance updating your FRN information, please contact Rebecca Jacobs Goldman or Scott Pippin.