No, LPFM stations are not required to submit Ownership Reports using Form 323-E.
Biennial ownership reports serve as a tool for the FCC to monitor ownership diversity and media concentration. Full-service stations submit these reports between October 1 and December 1 of odd-numbered years. Non-biennial ownership reports are required from full-service stations following specific events, such as within 30 days of an original construction permit grant or within 30 days of completing an assignment of license or transfer of control.
It’s worth noting that LPFM stations are exempt from filing any Ownership Reports, specifically Form 323-E.
Please be aware that Form 323 (without the E) is designated for full-service commercial broadcast stations, while Form 323-E is intended for full-service noncommercial educational broadcast stations.
Reference: 47 CFR §73.801 (please note the absence of cross-reference to §73.3615).
News that stays inside the noncommercial rules
Underwriting rules make programming choices tricky for LPFM and NCE stations; a newscast is one that isn't. Nexus Radio News supplies hourly 1-, 3- and 5-minute network newscasts, breaking bulletins and local weather on a plain subscription for noncommercial stations (from $20 a month for LPFM, $40 for full-power NCE), with no spots to air, and free on barter for commercial stations that can. See the rates.
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