Cut Red Tape, Costs of Pro Forma Transactions, Commenters Tell FCC

said then. In comments due Friday in docket 20-186, the American Consumer Institute Center for Citizen Research noted that, according to the petition, the FCC Wireless Bureau processes an average of 600 pro forma applications per year. “Pro forma transactions can strain resources for license holders, delay business decisions, and divert the already strained resources to comply with the onerous and unnecessary fillings and review procedures required for such transactions,” the group said. The burdens from existing filing requirements are “significant,” NAB commented. “A single non-substantial internal transaction can result in filing requirements that strain resources, delay business decisions and divert sparse resources,” broadcasters said. “Pro forma transactions are by their very nature non-substantive; the associated filing requirements ought to be as well,” Verizon said. “For companies like T-Mobile, with a complex ownership structure and numerous licensee subsidiaries, a non-substantive ownership change can require a large number of burdensome filings,” the carrier said. The rules permit post-closing notice of pro forma transactions for common carrier radio station licenses, submarine cable landing licenses, international authorizations and common carrier satellite and earth station licenses, T-Mobile said: They require prior approval of pro forma transactions including private radio licenses, some experimental licenses and licenses held by designated entities. The Land Mobile Communications Council said it “fully supports this common-sense proposal that will reduce regulatory burdens.” Markets are "the most efficient means of assigning radio operating rights,” wrote the R Street Institute.