February 24, 2011 - 12:00 am
FCC license holders and others doing business with the Commission are likely to be already familiar with the Commission’s Registration System, also known as “CORES,” which primarily is used by registrants to obtain an identifying number called an FCC Registration Number, or “FRN.” These unique ten-digit number sequences allow registrants to submit or file applications to the Commission, as well as remit payments, and are used by all Commission systems to easily identify individuals and companies when they interact with the agency. They also serve an important role by aiding the Commission’s compliance with the Debt Collection Improvement Act of 1996, which was enacted by Congress to address concerns that debts owed to the Federal government were not being properly collected.
On December 6, 2010, the Commission released a Notice of Proposed Rulemaking (“NPRM”) proposing modifications intended to make CORES more feature-friendly and improve the Commission’s ability to comply with various statutes that govern debt collection and the collection of personal information by the federal government. One of the primary goals of this proceeding is to improve the interface with CORES so that you can use the system in a more efficient and effective manner. Some of the proposed modifications to CORES are summarized below, but the full text of the NPRM can be found on the Commission’s web site. Note that comments to the proposals raised in the NPRM must be submitted on or before March 3, 2011, while reply comments must be submitted no later than March 18, 2011.
I’d like to also mention that on March 10, 2011, we’ll be holding a forum with staff and the public to explore legal and technical challenges associated with the proposed modifications that were raised in the NPRM. The workshop will be held in the FCC’s Commission Meeting Room at our headquarters in Washington, D.C., beginning at 10:00 a.m. Mary Beth Richards, Special Counsel to the Chairman for FCC Reform, will present opening remarks, and I’ll be moderating the forum. If interested, you’re encouraged to attend the forum or to follow along over the Internet from the FCC’s web page at www.fcc.gov/live. For more information, please refer to the Commission’s Public Notice announcing the public forum, which was released on February 15 and can be found on the front page of the Commission’s website.
Here are highlights of some of the proposals raised in the NPRM:
A Single FRN: Since the creation of CORES, companies have been able to obtain multiple FRNs so they could better internally manage their dealings with the agency. As a result, however, it has been difficult for the Commission to identify all the FRNs that are held by the same entity and tie them together in order to examine the entity’s entire course of dealing with the agency. Thus, the NPRM proposes to limit each registered entity to a single FRN, possibly through multiple sub-accounts that are linked together electronically. If enacted, this would have numerous benefits, both to our regulatees and the agency itself. For example, limiting each registrant to a single FRN will enhance our ability to inform them of past due regulatory fees and impending license renewal deadlines, through e-mail or on-line notification messages. Furthermore, it would enable the Commission to roll out a series of new features for CORES, including a company-centric “dashboard” that filers would see upon login, through which they’d have the ability to review the progress on their filings, fees that are due, the history of files they’ve submitted, as well as other important information. Such features could only be made possible by limiting entities to a single company-wide identifier. The NPRM also proposes to limit individual filers to a single FRN as well.
The NPRM describes some methods that we’re considering to limit registrants to a single FRN while retaining flexibility to organize their filings and other dealings with the Commission among logical business lines of their choosing, such as creating sub-accounts under a common FRN, and seeks comment on some of the technical and managerial challenges for each idea—take a look and let us know what you think.
Multiple Registrants with Multiple Points of Contact: Currently, CORES does not permit FRN holders to identify anyone other than themselves as the point of contact for their FRN, which may limit the FRN’s usefulness, because the listed person is not always the appropriate individual to resolve a particular issue or to provide necessary information to the agency. For this reason, the NPRM proposes that FRN holders should have the ability to voluntarily provide additional points of contact for their FRNs for specific pre-designated issues, such as “Accounting,” “Billing,” “Licensing,” “Legal Issues,” etc.
Elimination of Certain TIN Exception Reasons: Some individuals and entities aren’t required to provide their taxpayer ID when registering in CORES for various reasons. Over time, we’ve begun to believe that some of these exceptions are unnecessary, and the NPRM proposes to eliminate some of them. If you’re one of the few individuals or companies that have taken advantage of one of these exceptions, we recommend that you review the NPRM to see if you’d be affected by any of these proposals.
Registrant E-mail Addresses: When CORES was first designed approximately ten years ago, the use of e-mail wasn’t nearly as prevalent as it is now. As a result, entities and individuals were given the opportunity to voluntarily provide an e-mail address when completing the CORES registration process to obtain an FRN. Given the significant increase in the use of and dependence on e-mail in the years since CORES first became operational, however, the NPRM proposes that all FRN holders now be required to provide an e-mail address upon registration, which would simplify the process for us to maintain contact with registrants when a regulatory matter requires attention. Don’t worry—your e-mail address would remain private and hidden from public view.
Using CORES to Alert FRN Holders About Financial or Other Administrative Issues: CORES currently lacks the capability to alert FRN holders about known financial or other administrative-related issues regarding their standing at the Commission, such as their status in the Commission’s Red Light Display System, their debarment status, or the fact that we have discovered that their contact information is incorrect or nonoperational. The NPRM proposes to remedy this by enhancing CORES to permit the Commission to post individualized warning messages that would appear the next time a user accesses his or her FRN through the system. Another potential use for this feature might be to display payment histories and unpaid bills for Commission-related activities, such as unpaid fines and forfeitures, as well as the section 9 regulatory fee payment status.
Tax Exempt Indicator: Because tax-exempt entities often qualify for a reduction or elimination of their section 8 or section 9 annual regulatory fee requirements, the Commission is considering adding a data field to CORES that would enable entities and individuals to indicate any tax exempt status that they possess. The availability of such data and documentation through CORES would simplify the process for confirming eligibility for a reduction of (or exemption from) annual fee requirements, thus improving our financial operations, and reducing errors.
Bankruptcy Indicator: In certain contexts, our various Bureaus and Offices have an interest in knowing when industry participants are filing for (or emerging from) bankruptcy. For example, the Commission is required to process assignments or transfers of control of licenses for parties that enter bankruptcy. Also, the Commission’s Office of Financial Operations routinely receives requests for waiver of Section 9 regulatory fees from debtors claiming to be in bankruptcy. Currently, the Commission does not have a central depository of notifications that an entity is in bankruptcy. Therefore, to reduce administrative burdens at the Commission, the NPRM proposes to add a data field that would enable entities and individual license holders (or their representatives) to notify the Commission through CORES that they have entered into bankruptcy, or that there has been a change in their bankruptcy status (such as, for example, when they emerge from bankruptcy under Chapter 11 of the U.S. Bankruptcy Code).
Company Dashboard: In light of the Commission’s intent to develop and deploy an agency-wide Consolidated Licensing System, the NPRM seeks comments on the usefulness of utilizing a company dashboard or summary profile that filers would see upon login, which would serve as a central repository of information for the filer. Through the dashboard, the filer would have the ability to quickly and easily review various pertinent information, such as the progress on their filings, fees that are due, the history of files the filer has submitted, as well as any other important information the filer may need. Other uses for such a dashboard may include: identifying any information that is missing from a pending application, updating their profile, and detecting actions requiring immediate attention.