Get Ready!! Big Changes Coming To The FCC Registration System (CORES) And The Use Of The FCC Registration Number (FRN)

Nearly every broadcaster who has done business with the FCC is familiar with the FRN. Since 2000, anyone doing business with the Commission is required to first obtain a unique identifying number through the FCC Commissioning Registration System, known as CORES, called an FCC Registration Number or "FRN."

An FRN is required to submit or file applications, remit payments to the Commission and conduct many other types of business. As a part of the Commission's effort to reform and transform itself into a "model of excellence" in government, the new CORES system is designed to implement many of the privacy and security goals the Commission laid out in its 2010 Notice of Proposed Rule Making; specifically, to strengthen the security of FCC records, make CORES more user-friendly and improve the Commission compliance with various statutes that govern debt collection and the collection of personal information. The changes are significant and everyone who does business with the FCC must become familiar with them.

The new system allows users to employ a single FRN that, at their discretion, may be linked to subsidiary or associated accounts of associates and consultants. This system will facilitate a regulated entity to identify multiple points of contact that can access the system on its behalf. It is designed to accommodate many of the FCC's exceptions to the requirement that entities and individuals provide their taxpayer identification number ("TIN"), but will require all FRN holders to establish and use email addresses, a user name and password for their CORES login procedures.

Fortunately, or unfortunately, the transition has not been easy and the FCC has had problems rolling it out. Initially, the changes were to take effect on or about September 1st, 2016. That date was proponed and the new that effective date was to be March 1st, 2019. However, with the new CORES system still not yet fully implemented, FCC staff reports that the new system is still not completely ready for a mandatory cutover, and intends to issue a public notice in the next few days, sometime before April 15th, establishing a new date for the mandatory cutover. When the changes do become mandatory, the changes will:

• Require existing and new users to designate a user-specific ID (username) to access FCC registration numbers (FRNs) and related records;
• Allow registrants to establish multiple usernames for each FRN with different levels of access. By default, the first user establishing access to an existing FRN will be granted administrative responsibilities over the account and will have the ability to limit the level of access for other users.
• Require users to provide a valid e-mail address for online access to the system; and
• Establish password-recovery security questions specific to each user.

The FCC also has forms for those without an e-mail address. Users can register for an FRN or update an FRN by printing an FCC Form 160 (CORES Registration Form) or 161 (CORES Update/Change Forms) obtained from the FCC's Forms.

The Commission provides more details, at its CORES website: FCC Registration- Commission Registration System, including guidance for how to register a new username account, register for a new FRN and importantly, how to associate a username with an existing FRN. The new CORES system is accessed through the bullets under "Updated CORES System;" sdditional functions are available to reset a password, approve or reject an FRN association request (access request); update FRN information; check on a red light alert; and establish different levels of user access. It also maintains a CORES Q&A webpage which can be found at: CORES Q&A

Once the Legacy CORES System is retired, the only way to utilize the FCC online filing and payment systems will be through an FCC username account in the updated CORES' system. Any individual can go to CORES Registration to register a username or to obtain or reset a forgotten username and create a password.

A good source is CORES What You Need to know. or FCC Registration Help. That latter page contains a series of links each of which provides written instructions to navigate the various functions of the new CORES system. Remember, once you have established your username and password, the most important function is to associate with the needed FRN. Instructions are provided on that page. Once your username is associated with the needed FRN and the administrator has granted the necessary access, it will no longer be necessary to login to the user account by the FRN and password. When a new user requests FRN access through the updated CORES system, a request is automatically sent to the FRN administrator for association approval. If an FRN administrator has not yet been associated with the FRN, the request will get an error message and someone with that FRN and password access must log into the new system and become the administrator and grant access.

Skill with the Updated CORES System will become critically important when multiple parties must access an FRN to prepare and file forms or perform other functions for a Commission licensee. Problems frequently occur when a consultant, engineer or attorney who does not know the current password, finds a way to change the password without notifying all others who need access. This has resulted in sometimes frantic attempts to find the new password in order to meet a filing deadline. The new system will solve that problem! Everyone working on a matter requiring an FRN will have to request and be granted access through to their own username, deleting a requirement that each person have access to the FRN password. The full system of instructions is also available to be downloaded as a PDF file at the Commission Registration System CORES help page.

The bottom-line is that sometime in the Spring or Summer of 2019, the FCC will transition to the mandatory CORES password system. It behooves all engineers, lawyers, broadcasters and their employees who do business with the FCC to become familiar with the new system, establish their own username and password and request necessary association with appropriate FRNs, so they are ready when the updated CORES system becomes mandatory.

This column is provided for general information purposes only and should not be relied upon as legal advice pertaining to any specific factual situation. Legal decisions should be made only after proper consultation with a legal professional of your choosing.