If you wish to conduct business with the FCC, you must first register through the FCC’s Commission Registration System (“CORES”). To register, you must create a username and password. This username will uniquely identify you in the CORES system. You will also use this username to access CORES to update your FRN information and reset/update your FRN Password. CORES will now require FRNs to have an Administrator(s). This user(s) will manage which users have access to the FRN and what user role they will have. IF YOU CURRENTLY HAVE AN FCC LICENSE, YOU HAVE ALREADY REGISTERED.

A filer, licensee, certificate holder, or any entity sending payments to the FCC is considered to be doing business with the FCC and must, therefore, have a registered username and FRN.

(Petitioners or non-feeable complainants are not required to have a registered username and FRN.)

 In an effort to ensure security of FCC registration numbers, the FCC is changing  CORES in order to implement several user-specific identification requirements. In addition to enhancing security, the FCC believes that these changes will also make the FCC’s CORES system more user friendly.

 These changes will:

•  Implement a requirement for existing and new users to designate user-specific IDs (user names) for access to FCC Registration Numbers (FRNs) and related records.
•  Allow registrants to establish multiple user names for each FRN with different levels of access. In this regard, the first user establishing access to an FRN will have administrator privileges with the capability to limit the level of access to all other users.

(By default, the first user establishing access to an existing FRN will be granted administrative responsibilities over the account and will have the ability to limit the level of access for future users, if desired.) 

• Require users to provide a valid e-mail address for online access to the system.
•  Establish password-recovery security questions specific to each user.

 Some of the changes being implemented by the FCC were proposed almost five and a half years ago in its Notice of Proposed Rulemaking in MD Docket No. 10-234 (released December 7, 2010). Nonetheless, the FCC is making certain changes from the NPRM and others without notice and comment rulemaking since the changes are considered administrative in nature and not subject to the rulemaking process. The FCC believes that the changes are necessary to strengthen the security of its records (including social security numbers and federal Employer Identification Numbers) and make CORES more user friendly as well as strengthen the FCC’s ability to comply with various statutes and regulations governing debt collection activities and the collection of personal information.

The Commission will be implementing a pilot launch on April 29, 2016 for a four month period ending on August 31, 2016 in order to test its proposed system and obtain feedback from users of the CORES system. The pilot program will initially be targeted to users of the Commission’s Cable Operations and Licensing System (COALS) as well as business and governmental entities that have a significant number of registered FRNs associated with a single EIN as well as the top 100 Regulatory Fee payers by FRN. The pilot program initially will not be available for most. The FCC anticipates that the updated version of CORES will be available to the full FCC user community as of September 1, 2016  at https://www.fcc.gov/cores.The current version of CORES will remain available through September 30, 2016 at https://apps.fcc.gov/coresWeb/publicHome.do

Additional details about these modifications can be found on the CORES website at  https://apps.fcc.gov/cores/publicHome.do?help=true

Alarm service providers and equipment manufacturers should keep in mind FCC approval is required for most ownership changes.  If radio licenses are involved, prior FCC approval is generally required, although there may be ways to significantly reduce the usual 90 to 120 day approval time, using the FCC’s “conditional temporary licensing” mechanism (depending on the type of licenses involved).  For equipment manufacturers, the FCC generally must be notified of ownership changes that affect FCC equipment certifications within 60 days after the closing.  But some manufacturers also have radio licenses (such as demonstration licenses) that may require prior approval filings.

These entities should also keep in mind that many types of reorganizations, estate planning and tax savings activities and other transactions require prior FCC approval. Companies planning on such transactions should determine whether they must file an application for FCC approval, and obtain a grant, before closing the transaction.  Transactions requiring prior FCC approval include (but are not limited to):

• The distribution of stock to family members in connection with estate planning, tax and other business activities, if there are changes to the control levels discussed above; Any sale of a company that holds FCC licenses;
• Any sale, transfer or lease of an FCC license;
• A change in the form of organization from a corporation to an LLC, or vice versa, even though such changes are not regarded as a change in entity under state law.
• Any transfer of stock that results in a shareholder attaining a 50% or greater ownership level, or a shareholder relinquishing a 50% or greater ownership level;
• Any transfer of stock, partnership or LLC interests that would have a cumulative effect on 50% or more of the ownership.
• The creation of a holding company or trust to hold the stock of an FCC license holder;
• The creation of new classes of stockholders that affect the control structure of an FCC license holder.
• Certain minority ownership changes can require FCC approval (e.g., transfer of a minority stock interest, giving the recipient extraordinary voting rights or powers through officer or board position).
• The conversion of a corporate entity or partnership into another form of organization under state law – e.g., from corporation to LLC or partnership to LLP and vice versa.

–Contributed by CSAA Counsel John Prendergast (Blooston, Mordofsky, Dickens, Duffy, and Prendergast, Washington, DC)