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Date: March 14, 2017

Under the FCC’s rules, members of the governing board of a noncommercial educational licensee (for example, a Board of Directors, Tribal Council, Board of Regents, etc.) are treated as having an ownership interest in the licensee’s stations. These “attributed” ownership interests must be reported in biennial Ownership Reports (FCC Form 323-E). If the membership of a licensee’s board has turned over 50% or more since the FCC granted an application (not just as listed in an Ownership Report) seeking FCC consent to the board, then the licensee must file a Transfer of Control application.

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