FCC LMS System to Replace CDBS by Early 2016

The new system is intended to allow quicker and more streamlined electronic filing of the 30 or more forms that CDBS has been used for, which LMS does by condensing most of the information those forms once required into a single form, known as Form 2100. Despite the changes, the replacement of the roughly 15-year-old CDBS by a more-modern system is unlikely to shake up the attorneys who file those forms, said Holland and Knight broadcast attorney Charles Naftalin. “We'll get used to it."

The FCC “soft launched” LMS by having a few law firms use it before Thursday’s rollout, and with the looming incentive auction, few construction permits are being filed at the moment, said the Media Bureau official. He said the LMS is being used and so far few problems have cropped up beyond those expected with new software. Phase Two of replacing CDBS is expected in early 2015, and is planned to include the movement of all Video Division activity on CDBS to LMS, the official said. Phase Three will be in late 2015 or early 2016 and involve the movement of all Audio Division forms on CDBS to LMS, and end with the new system entirely taking over, the official said.

Broadcasters may not want to depend on the FCC’s schedule, said Fletcher Heald attorney Michelle McClure in a blog post. “Let’s not write any teary-eyed obits for CDBS quite yet,” she said (http://bit.ly/1rSLb15). “The move away from CDBS has been in the works for more than five years already."

One way in which the system will streamline electronically filing forms is by doing away with requiring licensees to create CDBS accounts to do their filing. Instead, the system has users log in with their FCC Registration Number (FRN), an individualized number that’s already used by a number of other FCC processes, and was sometimes used by CDBS as well. Instead of having to log in to their CDBS account and then enter an FRN number, users will simply enter the number, the Media Bureau official said. “It’s one less thing to keep track of,” said Wiley Rein broadcast attorney Kathryne Dickerson. Dickerson wrote about the LMS system for the firm’s blog (http://bit.ly/1BDQ8vN).

The use of FRN numbers could create one new issue for filers, Dickerson said. The FCC associates each FRN number with a single postal address, while CDBS accounts let users choose what address FCC mail associated with the account was sent to, she said. Under the LMS system, companies with multiple licensees could find that all their stations’ mail is being sent to their corporate headquarters, she said. If that’s a problem caused by LMS, the bureau is likely to address it, she said

Form 2100 is the other way the system streamlines filing, the Media Bureau official said. Instead of using many different forms, which partly use similar information, the system will use the central Form 2100, and adapt it with sub-forms called “schedules.” The many forms currently used by CDBS will all be replaced with schedules, so filers will only need to enter the information relevant to their specific task, rather than having to repeatedly re-enter basic information, the official said. It will make work flow much easier, the official said. Dickerson said she agreed that filing might be easier, but the new system may add a small extra step for third parties interested to see what a station has been up to. Where before it would be clear that someone filing a Form 301 was filing a CP, now users will have to click through to see what schedule has been filed to know, she said.