Federal Communications Commission
Washington, D.C. 20554
Approved by OMB
3060-0009 (June 2010)
FCC 316
FOR FCC USE ONLY
 
APPLICATION FOR CONSENT TO ASSIGN BROADCAST STATION CONSTRUCTION PERMIT OR LICENSE OR TO TRANSFER CONTROL OF ENTITY HOLDING BROADCAST STATION CONSTRUCTION PERMIT OR LICENSE

Read INSTRUCTIONS Before Filling Out Form

FOR COMMISSION USE ONLY
FILE NO.

BTCH - 20140514AFB
Section I - General Information
1. Legal Name of the Licensee/Permittee
BROWN BROADCASTING SERVICE, INC.
Mailing Address
88 BENEVOLENT ST.

City
PROVIDENCE
State or Country (if foreign address)
RI
Zip Code
02906 - 2046
Telephone Number (include area code)
4012729550
E-Mail Address (if available)
GM@WBRU.COM
FCC Registration Number:
0003764453
Call Sign
WBRU
Facility ID Number
7313
2. Contact Representative (if other than licensee/permittee)
SCOTT B. HARRIS, ESQ.
Firm or Company Name
HARRIS, WILTSHIRE & GRANNIS LLP
Mailing Address
1200 18TH ST. N.W.
SUITE 1200

City
WASHINGTON
State or Country (if foreign address)
DC
ZIP Code
20036 - 2560
Telephone Number (include area code)
7038301330

E-Mail Address (if available)
SBHARRIS@HARRISWILTSHIRE.COM
3. If this application has been submitted without a fee, indicate reason for fee exemption (see 47 C.F.R. Section 1.1114):
Governmental Entity Noncommercial Educational Licensee/Permittee Other
N/A (Fee Required)
4.
a.  Voluntary Assignment or Transfer of Control  Involuntary Assignment or Transfer of Control
Amendment to pending application
File number of pending application: -

If an amendment, submit as an Exhibit a listing, by Section and Question Number, of the portions of the pending application that are being revised.

[Exhibit 1]

b.

Applicant certifies that the use of FCC Form 316 is appropriate for this transaction.

 

Yes No
See Explanation in
[Exhibit 2]
5.

Were any of the authorizations that are the subject of this application obtained through the Commission's competitive bidding procedures (see 47 C.F.R. Sections 1.2111(a) and 73.5000)?

If yes, list pertinent authorizations in an Exhibit.

Yes No

[Exhibit 3]



NOTE: In addition to the information called for in this section, an explanatory exhibit providing full particulars must be submitted for each question for which a "No" response is provided.

Section II - Assignor/Transferor

1. Certification.   Assignor/Transferor certifies that it has answered each question in this application based on its review of the application instructions and worksheets. Assignor/Transferor further certifies that where it has made an affirmative certification below, this certification constitutes its representation that the application satisfies each of the pertinent standards and criteria set forth in the application instructions and worksheets. Yes No
2.
Application for (check one): Consent to Assign Construction Permit Consent to Transfer Control of Permittee
Consent to Assign License Consent to Transfer Control of Licensee
Amendment to pending application
3.
Legal Name of the Assignor/Transferor
OLD BOARD OF DIRECTORS OF BROWN BROADCASTING SERVICE, INC.
Mailing Address
BROWN BROADCASTING SERVICE, INC.
88 BENEVOLENT ST.

City
PROVIDENCE
State or Country (if foreign address)
RI
Zip Code
02906 - 2046
Telephone Number (include area code)
4012729550
E-Mail Address (if available)

GM@WBRU.COM
4.
Contact Representative (if other than Assignor/Transferor)
SCOTT B. HARRIS, ESQ.
Firm or Company Name
HARRIS, WILTSHIRE & GRANNIS, LLP
Mailing Address
1200 - 18TH ST.
SUITE 1200

City
WASHINGTON
State or Country (if foreign address)
DC
Zip Code
20036 - 2560
Telephone Number (include area code)
2027301330

E-Mail Address (if available)
SBHARRIS@HARRISWILTSHIRE,COM
 
If more than one Transferor, submit the information requested in Questions 3 and 4 for each transferor.
[Exhibit 4]
5. Authorizations to be Assigned/Transferred. List the authorized stations and construction permits to be assigned/transferred. Provide the Facility Identification Number and the Call Sign, or the Facility Identification Number and the File Number of the Construction Permit, and the location, for each station to be assigned/transferred. Include main stations, FM and/or TV translator stations, LPTV stations, FM and/or TV booster stations.

[Enter Station Information]


List the authorized stations and construction permits to be assigned/transferred. Provide the Facility Identification Number and the Call Sign, or the Facility Identification Number and the File Number of the Construction Permit, and the location, for each station to be assigned/transferred. Include main stations, FM and/or TV translator stations, LPTV stations,, FM and/or TV booster stations.

Facility ID Number
Call Sign or Construction Permit File Number
City
State
7313 WBRU - PROVIDENCE RI


6.
Agreements for Sale/Transfer of Station.
a. If the transaction is voluntary, Assignor/Transferor certifies that:
  i. it has placed in licensee's/permittee's public inspection file(s) and submitted as an exhibit to this item copies of all agreements for the assignment/transfer of the station(s);
  ii. these documents embody the complete and final understanding between assignor/transferor and assignee/transferee; and
  iii. these agreements comply fully with the Commission's rules and policies.
b. If the transaction is involuntary, the Assignor/Transferor certifies that court orders or other authorizing documents have been issued and that it has placed in the licensee's/permittee's public inspecition file(s) and submitted to the Commission copies of such court orders or other authorizing documents.
Exhibit Required
Yes No
N/A

[Exhibit 5]


Yes No
N/A

[Exhibit 6]

7.
Character Issues. Assignor/Transferor certifies that neither licensee/permittee nor any party to the application has or has had any interest in, or connection with:
a. any broadcast application in any proceeding where character issues were left unresolved or were resolved adversely against the applicant or any party to the application; or
b. any pending broadcast application in which character issues have been raised.
Yes No

See Explanation in
[Exhibit 7]

8.
Adverse Findings. Assignor/Transferor certifies that, with respect to the assignor/transferor and each party to the application, no adverse finding has been made, nor has an adverse final action been taken by any court or administrative body in a civil or criminal proceeding brought under the provisions of any law related to any of the following: any felony; mass media-related antitrust or unfair competition; fraudulent statements to another governmental unit; or discrimination.
Yes No
See Explanation in
[Exhibit 8]
9. Auction Authorization. Assignor/transferor certifies that more than five years have passed since the issuance of the construction permit for the station being assigned, where that permit was acquired in an auction through the use of a bidding credit or other special measure. Yes No
N/A


See Explanation in
[Exhibit 9]
10. Anti-Drug Abuse Act Certification. Assignor/Transferor certifies that neither licensee/permittee nor any party to the application is subject to denial of federal benefits pursuant to Section 5301 of the Anti-Drug Abuse Act of 1988, 21 U.S.C. Section 862. Yes No

I certify that the statements in this application are true, complete, and correct to the best of my knowledge and belief, and are made in good faith. I acknowledge that all certifications and attached Exhibits are considered material representations.

Typed or Printed Name of Person Signing
JUSTIN GLAVIS-BLOOM
Typed or Printed Title of Person Signing
PRESIDENT
Signature
Date
05/14/2014
WILLFUL FALSE STATEMENTS ON THIS FORM ARE PUNISHABLE BY FINE AND/OR IMPRISONMENT (U.S. CODE, TITLE 18, SECTION 1001), AND/OR REVOCATION OF ANY STATION LICENSE OR CONSTRUCTION PERMIT (U.S. CODE, TITLE 47, SECTION 312(a)(1)), AND/OR FORFEITURE (U.S. CODE, TITLE 47, SECTION 503).



NOTE: In addition to the information called for in this section, an explanatory exhibit providing full particulars must be submitted for each question for which a "No" response is provided.

Section III - Assignee/Transferee

1. Certification.   Assignee/Transferee certifies that it has answered each question in this application based on its review of the application instructions and worksheets. Assignee/Transferee further certifies that where it has made an affirmative certification below, this certification constitutes its representation that the application satisfies each of the pertinent standards and criteria set forth in the application instructions and worksheets. Yes No
2.
Legal Name of the Assignee/Transferee
NEW BOARD OF DIRECTORS OF BROWN BROADCASTING SERVICE, INC.
Mailing Address
BROWN BROADCASTING SERVICE, INC.
88 BENEVOLENT ST.

City
PROVIDENCE
State or Country (if foreign address)
RI
Zip Code
02906 - 2046
Telephone Number (include area code)
4012729550
E-Mail Address (if available)

GM@WBRU.COM
3.
Contact Representative (if other than Assignee/Transferee)
SCOTT B. HARRIS, ESQ.
Firm or Company Name
HARRIS, WILTSHIRE & GRANNIS, LLP
Mailing Address
1200 18TH ST., N.W.
SUITE 1200

City
WASHINGTON
State or Country (if foreign address)
DC
Zip Code
20036 - 2560
Telephone Number (include area code)
2027301330

E-Mail Address (if available)
SBHARRIS@WILTSHIREGRANNIS.COM
 
If more than one Transferee, submit the information requested in Questions 2 and 3 for each transferee.
[Exhibit 10]
4.
Agreements for Sale/Transfer of Station. Assignee/Transferee certifies that:
a. the written agreements in the licensee/permittee's public inspection file embody the complete and final agreement for the sale or transfer of the station(s); and
b. these agreements comply fully with the Commission's rules and policies.
Yes No
[Exhibit 11]
5. Changes in interests as a result of assignment/transfer.
a. [Enter Changes in Interests Information]

Changes in Interests as a Result of Assignment/Transfer

(A) NAMES AND ADDRESSES OF ANY PARTY TO APPLICATION HOLDING AN ATTRIBUTABLE INTEREST
(B)
CITIZENSHIP
INTEREST HELD
(C) BEFORE TRANSFER OR ASSIGNMENT
(D) AFTER TRANSFER OR ASSIGNMENT
(1) Percentage Vote
(2) PercentageTotal Assets

(Equity plus Debt)

(1) Percentage Votes
(2) PercentageTotal Assets

(Equity plus Debt)

SUSAN HOWITT, 29 GARLAND RD., NEWTON, MA 02469 US 12.5 0 10 0

(A) NAMES AND ADDRESSES OF ANY PARTY TO APPLICATION HOLDING AN ATTRIBUTABLE INTEREST
(B)
CITIZENSHIP
INTEREST HELD
(C) BEFORE TRANSFER OR ASSIGNMENT
(D) AFTER TRANSFER OR ASSIGNMENT
(1) Percentage Vote
(2) PercentageTotal Assets

(Equity plus Debt)

(1) Percentage Votes
(2) PercentageTotal Assets

(Equity plus Debt)

JEAN A. HARRINGTON, 1800 FINANCIAL PLAZA, PROVIDENCE, RI 02903 US 12.5 0 10 0

(A) NAMES AND ADDRESSES OF ANY PARTY TO APPLICATION HOLDING AN ATTRIBUTABLE INTEREST
(B)
CITIZENSHIP
INTEREST HELD
(C) BEFORE TRANSFER OR ASSIGNMENT
(D) AFTER TRANSFER OR ASSIGNMENT
(1) Percentage Vote
(2) PercentageTotal Assets

(Equity plus Debt)

(1) Percentage Votes
(2) PercentageTotal Assets

(Equity plus Debt)

DAVID WHITNEY, 49 LINDEN ST., ARLINGTON, MA 02476 US 12.5 0 10 0

(A) NAMES AND ADDRESSES OF ANY PARTY TO APPLICATION HOLDING AN ATTRIBUTABLE INTEREST
(B)
CITIZENSHIP
INTEREST HELD
(C) BEFORE TRANSFER OR ASSIGNMENT
(D) AFTER TRANSFER OR ASSIGNMENT
(1) Percentage Vote
(2) PercentageTotal Assets

(Equity plus Debt)

(1) Percentage Votes
(2) PercentageTotal Assets

(Equity plus Debt)

JUSTIN B. GLAVIS-BLOOM, 88 BENEVOLENT ST., PROVIDENCE, RI 02906 US 12.5 0 10 0

(A) NAMES AND ADDRESSES OF ANY PARTY TO APPLICATION HOLDING AN ATTRIBUTABLE INTEREST
(B)
CITIZENSHIP
INTEREST HELD
(C) BEFORE TRANSFER OR ASSIGNMENT
(D) AFTER TRANSFER OR ASSIGNMENT
(1) Percentage Vote
(2) PercentageTotal Assets

(Equity plus Debt)

(1) Percentage Votes
(2) PercentageTotal Assets

(Equity plus Debt)

STUART SAUNDERS, 15260 VENTURA BLVD., SUITE 200, SHERMAN OAKS, CA 91403 US 12.5 0 10 0

(A) NAMES AND ADDRESSES OF ANY PARTY TO APPLICATION HOLDING AN ATTRIBUTABLE INTEREST
(B)
CITIZENSHIP
INTEREST HELD
(C) BEFORE TRANSFER OR ASSIGNMENT
(D) AFTER TRANSFER OR ASSIGNMENT
(1) Percentage Vote
(2) PercentageTotal Assets

(Equity plus Debt)

(1) Percentage Votes
(2) PercentageTotal Assets

(Equity plus Debt)

EDWARD MCENROE, 75 ARLINGTON ST., 10TH FLOOR, BOSTON , MASSACHUSETTS 02116 - 3936 US 0 0 10 0

(A) NAMES AND ADDRESSES OF ANY PARTY TO APPLICATION HOLDING AN ATTRIBUTABLE INTEREST
(B)
CITIZENSHIP
INTEREST HELD
(C) BEFORE TRANSFER OR ASSIGNMENT
(D) AFTER TRANSFER OR ASSIGNMENT
(1) Percentage Vote
(2) PercentageTotal Assets

(Equity plus Debt)

(1) Percentage Votes
(2) PercentageTotal Assets

(Equity plus Debt)

SCOTT B. HARRIS, 1200 - 18TH ST., N.W. 12TH FLOOR WASHINGTON, D.C. 20036-2506 US 0 0 10 0

(A) NAMES AND ADDRESSES OF ANY PARTY TO APPLICATION HOLDING AN ATTRIBUTABLE INTEREST
(B)
CITIZENSHIP
INTEREST HELD
(C) BEFORE TRANSFER OR ASSIGNMENT
(D) AFTER TRANSFER OR ASSIGNMENT
(1) Percentage Vote
(2) PercentageTotal Assets

(Equity plus Debt)

(1) Percentage Votes
(2) PercentageTotal Assets

(Equity plus Debt)

ANDREW TRIEDMAN, 88 BENEVOLENT ST., PROVIDENCE, RI 02906 US 0 0 10 0

(A) NAMES AND ADDRESSES OF ANY PARTY TO APPLICATION HOLDING AN ATTRIBUTABLE INTEREST
(B)
CITIZENSHIP
INTEREST HELD
(C) BEFORE TRANSFER OR ASSIGNMENT
(D) AFTER TRANSFER OR ASSIGNMENT
(1) Percentage Vote
(2) PercentageTotal Assets

(Equity plus Debt)

(1) Percentage Votes
(2) PercentageTotal Assets

(Equity plus Debt)

ELISE KIPNESS, 88 BENEVOLENT ST., PROVIDENCE, RI 02906 US 0 0 10 0

(A) NAMES AND ADDRESSES OF ANY PARTY TO APPLICATION HOLDING AN ATTRIBUTABLE INTEREST
(B)
CITIZENSHIP
INTEREST HELD
(C) BEFORE TRANSFER OR ASSIGNMENT
(D) AFTER TRANSFER OR ASSIGNMENT
(1) Percentage Vote
(2) PercentageTotal Assets

(Equity plus Debt)

(1) Percentage Votes
(2) PercentageTotal Assets

(Equity plus Debt)

PETER LITMAN, 88 BENEVOLENT ST., PROVIDENCE, RI 02906 US 0 0 10 0

(A) NAMES AND ADDRESSES OF ANY PARTY TO APPLICATION HOLDING AN ATTRIBUTABLE INTEREST
(B)
CITIZENSHIP
INTEREST HELD
(C) BEFORE TRANSFER OR ASSIGNMENT
(D) AFTER TRANSFER OR ASSIGNMENT
(1) Percentage Vote
(2) PercentageTotal Assets

(Equity plus Debt)

(1) Percentage Votes
(2) PercentageTotal Assets

(Equity plus Debt)

PETER TANNENWALD, 1300 N. 17TH ST., 11TH FLOOR, ARLINGTON, VA 22209 US 12.5 0 0 0

(A) NAMES AND ADDRESSES OF ANY PARTY TO APPLICATION HOLDING AN ATTRIBUTABLE INTEREST
(B)
CITIZENSHIP
INTEREST HELD
(C) BEFORE TRANSFER OR ASSIGNMENT
(D) AFTER TRANSFER OR ASSIGNMENT
(1) Percentage Vote
(2) PercentageTotal Assets

(Equity plus Debt)

(1) Percentage Votes
(2) PercentageTotal Assets

(Equity plus Debt)

GRACE MURPHY, 35 NORTH LAKE DRIVE, BARRINGTON, RI 02806 US 12.5 0 0 0

(A) NAMES AND ADDRESSES OF ANY PARTY TO APPLICATION HOLDING AN ATTRIBUTABLE INTEREST
(B)
CITIZENSHIP
INTEREST HELD
(C) BEFORE TRANSFER OR ASSIGNMENT
(D) AFTER TRANSFER OR ASSIGNMENT
(1) Percentage Vote
(2) PercentageTotal Assets

(Equity plus Debt)

(1) Percentage Votes
(2) PercentageTotal Assets

(Equity plus Debt)

GILLIAN CHU, 88 BENEVOLENT ST., PROVIDENCE, RI 02906 US 12.5 0 0 0


or [Exhibit 12]
 
 
b. Applicant certifies that equity interests not set forth above are non-attributable.
Yes No

N/A

[Exhibit 13]

6. Other Authorizations. List call signs, locations, and facility identifiers of all other broadcast stations in which assignee/transferee or any party to the application has an attributable interest. N/A

[Exhibit 14]

7. Acquisition of Control. List the file number and date of grant of FCC Form 301, 314, or 315 application by which the Commission approved the qualifications of the individual or entity with a pre-existing interest in the licensee/permittee that is now acquiring control of the licensee/permittee as a result of the grant of this application. N/A

[Exhibit 15]

8.
Character Issues. Assignee/Transferee certifies that neither assignee/transferee nor any party to the application has or has had any interest in, or connection with:
a. any broadcast application in any proceeding where character issues were left unresolved or were resolved adversely against the applicant or any party to the application; or
b. any pending broadcast application in which character issues have been raised.
Yes No

See Explanation in
[Exhibit 16]

9.
Adverse Findings. Assignee/Transferee certifies that, with respect to the assignee/transferee and each party to the application, no adverse finding has been made, nor has an adverse final action been taken by any court or administrative body in a civil or criminal proceeding brought under the provisions of any law related to any of the following: any felony; mass media-related antitrust or unfair competition; fraudulent statements to another governmental unit; or discrimination.
Yes No

See Explanation in
[Exhibit 17]

10. Alien Ownership and Control. Assignee/Transferee certifies that it complies with the provisions of Section 310 of the Communications Act of 1934, as amended, relating to interests of aliens and foreign governments. Yes No

See Explanation in
[Exhibit 18]

11. Auction Authorization. Assignee/transferee certifies that where less than five years have passed since the issuance of the construction permit and the permit had been acquired in an auction through the use of a bidding credit or other special measure, it would qualify for such credit or other special measure. Yes No
N/A


See Explanation in
[Exhibit 19]
12. Anti-Drug Abuse Act Certification. Assignee/transferee certifies that neither licensee/permittee nor any party to the application is subject to denial of federal benefits pursuant to Section 5301 of the Anti-Drug Abuse Act of 1988, 21 U.S.C. Section 862. Yes No

I certify that the statements in this application are true, complete, and correct to the best of my knowledge and belief, and are made in good faith. I acknowledge that all certifications and attached Exhibits are considered material representations. I hereby waive any claim to the use of any particular frequency as against the regulatory power of the United States because of the previous use of the same, whether by license or otherwise, and request an authorization in accordance with this application. (See Section 304 of the Communications Act of 1934, as amended.)

Typed or Printed Name of Person Signing
JUSTIN GLAVIS-BLOOM
Typed or Printed Title of Person Signing
PRESIDENT
Signature
Date
05/14/2014
WILLFUL FALSE STATEMENTS ON THIS FORM ARE PUNISHABLE BY FINE AND/OR IMPRISONMENT (U.S. CODE, TITLE 18, SECTION 1001), AND/OR REVOCATION OF ANY STATION LICENSE OR CONSTRUCTION PERMIT (U.S. CODE, TITLE 47, SECTION 312(a)(1)), AND/OR FORFEITURE (U.S. CODE, TITLE 47, SECTION 503).



Exhibits
Exhibit 2
Description:
JUSTIFICATION FOR USE OF FORM 316

ALTHOUGH WBRU IS LICENSED AS A COMMERCIAL BROADCAST STATION, THE LICENSEE IS A NON-PROFIT CORPORATION WITH AN IRS SECTION 501(C)(3) TAX EXEMPTION. IT HAS NO STOCKHOLDERS.   IT HAS TWO CLASSES OF CORPORATE MEMBERS STUDENTS (PRIMARILY ENROLLED AT BROWN UNIVERSITY), WHO CHANGE FREQUENTLY, AND A BOARD OF DIRECTORS, WHOSE MEMBERS CHANGE OCCASIONALLY. THE DIRECTORS, WHO ARE ALUMNI AND UNIVERSITY OFFICIALS PLUS ONE STUDENT, MUST RATIFY ALL MAJOR DECISIONS AND CHOOSE THEIR OWN SUCCESSORS (RATIFIED BY STUDENTS); SO THE LICENSEE CONSIDERS THEM THE CONTROL GROUP FOR FCC PURPOSES.

ALTHOUGH THE LICENSEE IS A SEPARATE NON-PROFIT CORPORATION, THE STATIONS PURPOSE IS TO SERVE AS AN EDUCATIONAL WORKSHOP FOR STUDENTS ENROLLED AT BROWN UNIVERSITY. THE LICENSE IS COMMERCIAL BECAUSE LEARNING HOW TO OPERATE A SELF-SUPPORTING BUSINESS IS CONSIDERED AN IMPORTANT PART OF THE TRAINING MISSION.

THE LICENSEE KNOWS OF NO DIRECT CASE LAW DISTINGUISHING BETWEEN COMMERCIAL AND NONCOMMERCIAL NON-PROFIT STUDENT-OPERATED STATIONS FOR THE PURPOSE OF TRANSFERS OF CONTROL DUE TO GRADUAL BOARD TURNOVER. THE COMMISSION HAS PREVIOUSLY ALLOWED THESE COMMERCIALLY LICENSED STATIONS TO APPLY THE SAME WAY THAT AN NCE STATION WOULD, ON FORM 316. PAST APPROVED FORM 316 APPLICATIONS INCLUDE:

WBRU, FAC. ID 7313 (BROWN BROADCASTING SERVICE, INC.): BTCH-19860530GE, BTCH-19931014GN, BTCH-20061018ACO, BTCH-20121017ABH

WVBR-FM, FAC. ID 13909 (CORNELL RADIO GUILD, INC.): BTCH-19960206GE, BTCH-19980609EK, BTCH-20050406ACC, BTCH-20080201ADO

OF THE 8 DIRECTORS WHO HELD OFFICE IN 2012, 5 NOW REMAIN. SINCE 2012, 3 DIRECTORS WERE REPLACED AND ONE WAS WAS ADDED, FOR A TOTAL OF 9 DIRECTORS (5 PREVIOUSLY APPROVED). THIS APPLICATION REQUESTS PERMISSION TO ADD A 10TH DIRECTOR, WHOSE ADDITION WILL RESULT IN 50% OF THE DIRECTORS NOT BEING PREVIOUSLY APPROVED.

THE NEW DIRECTORS SHOWN IN SECTION III HAVE BEEN ELECTED GRADUALLY, WHICH IS A REQUIREMENT TO USE FORM 316:

EDWARD MCENROE (REPLACING GRACE MURPHY) WAS ELECTED ON MARCH 27, 2013.
ELISE KIPNESS WAS ELECTED ON OCTOBER 7 2013.
ANDREW TRIEDMAN (STUDENT OFFICER, REPLACING WYATT CROWELL, WHO IN TURN REPLACED GILLIAN CHU IN 2012) WAS ELECTED ON DECEMBER 4, 2013.
SCOTT B. HARRIS (REPLACING PETER TANNENWALD) WAS ELECTED ON FEBRUARY 26, 2014.
PETER LITMAN'S ELECTION WILL BECOME EFFECTIVE UPON APPROVAL OF THIS APPLICATION.

Attachment 2


Exhibit 4
Description:
MULTIPLE TRANSFERORS

SEE WITHDRAWING DIRECTORS LISTED IN TRANSFEREE'S SECTION III, QUESTION 5(A).

Attachment 4


Exhibit 5
Description:
AGREEMENT FOR THE ASSIGNMENT OF THE LICENSEE

THIS QUESTION IS ANSWERED 'YES' BECAUSE CDBS WILL NOT VALIDATE THE APPLICATION WITHOUT A 'YES' ANSWER TO EITHER QUESTION 6A OR 6B. HOWEVER, BECAUSE THIS APPLICATION INVOLVES A GRADUAL TUROVER IN THE BOARD OF DIRECTORS OF A NON-PROFIT ENTITY WITH NO STOCKHOLDERS, THERE IS NO CONTRACT OR OTHER FORMAL AGREEMENT BETWEEN THE TRANSFEROR AND TRANSFEREE. THE ONLY DOCUMENTATION OF THE CHANGE IS MINUTES OF THE VARIOUS BOARD MEETINGS WHERE VOTES WERE TAKEN TO ELECT NEW DIRECTORS, AND THOSE MINUTES ARE INTERNAL CORPORATE DOCUMENTS THAT ARE NOT IN THE PUBLIC FILE.

Attachment 5


Exhibit 10
Description:
MULTIPLE TRANSFEREES

SEE INCOMING DIRECTORS LISTED IN SECTION III, QUESTION 5(A).

Attachment 10


Exhibit 11
Description:
AGREEMENT

SEE DISCUSSION IN TRANSFEROR'S EXHIBIT 5.

Attachment 11


Exhibit 12
Description:
ADDITIONAL INFORMATION

DIRECTORS LISTED PRIOR TO TRANSFER ARE BASED ON THE MEMBERS OF THE BOARD OF DIRECTORS APPROVED IN BTCH-20121017ABH.

Attachment 12


Exhibit 13
Description:
NON-ATTRIBUTABLE INTERESTS

THE LICENSEE IS A NON-PROFIT CORPORATION WITH NO 'OWNERS' AS SUCH. THUS THERE ARE NO NON-ATTRIBUTABLE INTERESTS.

Attachment 13


Exhibit 15
Description:
LONG FORM APPROVAL

BBS ACQUIRED WBRU ON A LONG FORM APPLICATION IN 1965. IT WAS THE SAME NON-PROFIT, NON-STOCK CORPORATION THEN, WITH THE SAME PURPOSE OF TRAINING STUDENTS, THAT IT IS TODAY. PERSONS NOW AFFILIATED WITH THE STATION DO NOT KNOW THE FILE NUMBER OF THE 1965 LONG FORM, AND IT IS NOT RETRIEVABLE FROM THE COMMISSION'S WEBSITE, WHICH DOES NOT HAVE RECORDS BEFORE 1980. COPIES OF THE 1986 AND 1993 SHORT-FORM TRANSFER APPLICATIONS ARE AVAILABLE, BUT THOSE FORMS DID NOT ASK FOR THE 1965 FILE NUMBER. THE 1965 FILE NUMBER WAS LIKEWISE NOT AVAILABLE AT THE TIME OF THE 2006 SHORT FORM TRANSFER OF CONTROL.

Attachment 15