united-states radio fcc communications-law
What constitutes &quot;management&quot; for an amateur radio club?
<p>A group of licensed radio amateurs has joined together to form a club. The club meets monthly, sponsors classes to license new amateurs, hosts an amateur repeater station and operates at public events. The club has bylaws and is a 501(c)(3) entity. The club has no officers and no dues. As a small group of reasonable people, club members agree on what to do and chip in as needed.</p>

<p>The club would like to obtain a permanent call sign for use at club events. (This in contrast to a "special event" call sign which would have to be obtained on a per-use basis.) The US Federal Communications Commission (FCC) regulations state, in part 97.5(b)(2) <strong>(emphasis supplied)</strong>:</p>

<blockquote>
  <p><em>A club station license grant.</em> A club station license grant may be held
  only by the person who is the license trustee designated by <strong>an officer</strong>
  of the club. The trustee must be a person who holds an
  operator/primary station license grant. The club must be composed of
  at least four persons and must have a name, a document of
  organization, <strong>management</strong>, and a primary purpose devoted to amateur
  service activities consistent with this part.</p>
</blockquote>

<p>The club is told by an organization that administers amateur radio licenses for the FCC that the club's "management" must comprise a president, vice president, secretary and treasurer. Part 97.5(b)(2) makes no mention of how the <em>management</em> should be structured; reference to "an officer" indicates that a single individual could comprise the management. The club eschews the trappings of a management structure, but would consider investing a single member with the title of president if needed to pass legal muster.</p>

<p>What are the club's options?</p>

<blockquote>
  <p>The first thing is to change the club license to your name and address, as you are the custodian of the club license. The club license belongs to the club, but you ensure that all FCC rules are followed. The FCC privatized the Club Call Sign Assignment System several years ago. All club licenses MUST go through a Club Station Call Sign Administrator and there are three, the ARRL VEC in Newington, the W5YI VEC and the W4VEC. There is no charge, but the appropriate form must be used. When applying through the ARRL VEC, the form is the ARRL VEC Form 605-C. If the club does not have a club license and if it wants one, it can be obtained by using the above URL. The FCC will not accept club license forms directly from the applicant; if you send it to the FCC, it will be returned without action. The form must bear two different signatures, the new trustee and another officer in the club. The signatures cannot be the same. <a href="http://www.arrl.org/club-station-faq" rel="nofollow noreferrer">http://www.arrl.org/club-station-faq</a></p>
</blockquote>

<p>You can appoint someone president, but you will need more than one officer, or an officer and a trustee, since you need the trustee and the officer to sign.</p>

<p>The form is available here:
<a href="http://www.arrl.org/files/file/VEs/ARRLClub%20NEW%20605C-2017_Interactive.pdf" rel="nofollow noreferrer">http://www.arrl.org/files/file/VEs/ARRLClub%20NEW%20605C-2017_Interactive.pdf</a></p>

<p>As a 501(c)(3) organization you have responsibilities and potential liabilities. More critically than the FCC management issue might be the issue of governance of your tax exempt association - at least to stay with the 503(c)(3) constraints. I assume you have by-laws and a board.Someone must have the power to sign, on behalf of the organization, the required yearly federal forms.</p>
