Based on credible reports from Commission staff, REC can confirm that the FCC Media Bureau plans to require the use of the License Management System (LMS) for renewal filings in the upcoming cycle. The first renewal filings for Maryland, D.C., Virginia and West Virginia must be filed on or just before June 1, 2019.
LMS has been used primarily by television broadcasters for most of their application needs. In television, assignments and transfers still go through CDBS. In full-service radio, LMS has been used only for ownership reports. LPFM stations are not required to file ownership reports.
The LMS form is called Form 2100. Similar to the IRS 1040 tax form, Form 2100 uses "schedules" and other variations in order to handle specific needs of the application. We have not yet seen the presentation of how the form will be laid out. Since the existing renewal form (Form 303-S) is fairly simple and straightforward, we expect the LMS version of the form to be the same.