Yes, it’s that time of year again, for Periodicals mailers to file their annual Statement of Ownership, Management and Circulation with the United States Postal Service® (USPS). This document, Form 3526, is required to be filed annually by publishers for each authorized Periodical publication. The completed Statement of Ownership form is due by October 1 each year. The completed form must be filed at the post office serving the publishers offices.
This form is NOT required to be filed for publications that mail at other classes of mail, such as Standard, Package Services or First-Class, nor is it required to be filed for publications that are currently mailing as Periodicals Pending.
There are actually two versions of the form, Form 3526 for General (paid) and other publications and Form 3526-R for Requester publications. The forms require that publishers submit information regarding the ownership and management of the publication, as well as circulation information. Publishers must include circulation information for the issue of the publication closest to the filing date as well as an average for all the issues for the year.
Aside from confirming the ownership and management information, the USPS uses the circulation information as a basis to insure publishers are meeting the circulation requirements to qualify for Periodicals mail. These requirements specify that at least 50% of the total circulation of a publication be circulated to those who have paid for or requested the publication. If the paid/requested ratio on this annual form reflects a percentage of between 50% and 60%, this can trigger a more detailed postal audit.
The information needed to complete the form may be found on postage statements, print orders, print invoices, distribution instructions, etc. It is easier if publishers maintain this information on an issue-by-issue basis in a spreadsheet or something similar so that when it comes time to complete the annual form, all the necessary information is at hand. If this is not done, you should gather up all the pertinent documents for each issue of the year before attempting to complete the form.
A common problem that publishers run into is that the subscriber/nonsubscriber copies have not been reported correctly on the postage statements during the course of the year. If the paid/requester counts on the statement of ownership do not correspond with the subscriber/nonsubscriber counts on the postage statements, that discrepancy can also trigger an audit.
To prevent this problem, it is critical that detailed instructions be provided by the publisher to the mailing list processor so that they can correctly identify and report the subscriber and nonsubscriber copies in the mail.dat files and on the postage statements. Any changes to the way these address records are identified during the course of the year also needs to be communicated to the list processor.
It is also critical that publishers monitor postage statements during the course of the year to insure that these counts are reported accurately and to rectify any problems early on if they are not. It can be very problematic (not to mention expensive and time consuming) to try to correct a whole year of postage statements right before you are ready to file your statement of ownership, particularly if rate changes have occurred or if software updates have taken place in the interim.
In addition to filing the completed form, the information on the completed form must be published in the publication for titles authorized under the General or Requester categories. This information is required to be published in the first issue subsequent to filing the form. For example, if the publication has a monthly frequency, the information should be published in the first issue produced after the filing date of October 1. If the publication is weekly or less frequent, but more than monthly, the information should be published in an issue no later than October 31. For weeklies or more frequent, the information should be published in an issue by October 10.
There are no regulations regarding the size or format of this published information, as long as it is legible and complete. Some publishers replicate the actual form itself for publication, while others convert the information to text format.
If for some reason you do not meet the filing deadline of October 1, you should contact the post office serving your publishing offices and notify them of the reason for the delay and the date by which you estimate you will submit the completed form. Publication of the information is more strictly enforced. If you do not publish the statement of ownership information in the timeline described above, the USPS can hold the mailing of subsequent issues until this requirement is met. Again, if you fall behind in meeting this deadline, it is best to notify your post office up front in order to prevent mailing delays.
If you need assistance to complete or publish your forms, contact your local Business Mail Entry (BME) office and ask for the Periodicals mail expert. They can walk you through the form and provide information about filing and publication of the information.
Monica Lundquist, Postal Affairs Manager, Window Book, Inc.