FCC Registration Number (FRN) Holders Take Note: Update Records Within 10 Days or Face $1000 Per Day Fine

In a little noticed FCC rule change that went into effect on February 5, any entity that has an FCC Registration Number (FRN) faces a $1,000 per day penalty for the failure to update its registration information in the FCC’s Commission Registration System (CORES) within 10 business days of a change in its information. This change is a potential “gotcha” for virtually any entity that does business with the FCC, well beyond typical regulated telecom and broadcast entities.

For example, equipment authorization holders, licensees of private radio systems used for internal communications, providers of IP-based voice capabilities that may include reporting or Universal Service contribution requirements, all have FRNs, regardless of whether or not communications are a core part of their business.  

One area of particular risk is where one or more FRNs are obtained for an enterprise through a third-party equipment or service vendor that interfaces directly with the FCC, and the registration information is not actively managed by the registrant. Such required updates include any change to a registrant’s entity name, entity type, contact name and title, address, email address, and taxpayer identifying number (TIN), all which must be updated within 10 business days online via CORES, with a form filing option also available. Previously, the FCC rules required only that CORES registrants keep their information current, without any prescribed deadline for making updates.

Please reach out to any member of Womble Bond Dickinson’s Communications, Technology and Media Team to discuss any questions.

*****