Periodicals Mailers-Time to File Statement of Ownership!


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.

ACS Full Service: Will it REALLY work? By Monica Lundquist, Postal Affairs, Window Book Inc.


ACS Full Service: Will it REALLY work?

Some recent mailing industry discussions have involved all the uncertainties regarding Address Change Service (ACSTM) services under Intelligent Mail®. There is still a lot of confusion and miscommunication surrounding this topic. However, one element which is very fundamental is not being discussed, and unfortunately it could be a real show-stopper.

Many mailers do not realize that the USPS handles address corrections differently for the various processing categories of mail. One of the methods the USPS utilizes is a system called Postal Automated Redirection System (PARS), which reads the address during postal processing, bounces it against the USPS Change of Address (COA) database, and then automatically applies the new address and forwards the mail (depending on the class of mail and service endorsements) to the new address. The processing equipment used to process this mail is predominantly for letter size mail.

For mail that is not forwarded, the USPS uses a different method. In these cases, the address corrections are triggered at the mail delivery carrier level. When the carrier determines that the recipient is no longer at the address on the mailpiece, or that the mailpiece is otherwise undeliverable as addressed, the piece is sent to a Computerized Forwarding System (CFS) center for further processing. The CFS sites are where the ACS notices are generated. Before this is done, however, the mail carrier manually crosses out the barcode on the mailpiece so that the piece does not get re-directed to the old or bad address. Therein lies the problem. If the Intelligent Mail barcode (IMb) is obliterated by the mail carrier, it will not be able to be scanned at the CFS centers, which means that the USPS will not be able to process the address corrections in the Intelligent Mail environment.

Theoretically, it should be as simple as training all the mail carriers to stop crossing out the barcodes on this Undeliverable As Addressed (UAA) mail. However, since there are tens of thousands of mail carriers across the country, the likelihood of this training getting accomplished quickly and thoroughly is not very high. This is particularly true given the financial straits of the USPS.

The November implementation date for the Intelligent Mail postage discounts is not all that far away. This problem is not being actively discussed, so how can mailers be assured that they will be receiving their address corrections when they convert to Intelligent Mail? This is particularly concerning for Periodicals mailers, who are required to receive and pay for address corrections through the USPS. Many Periodicals mailers have adopted the ACS service over the years as a method of reducing the cost of the address corrections. Since these mailers are already paying for address corrections through the USPS, very few utilize other methods of obtaining address corrections, such as NCOALink®, because of the additional costs. The free ACS service as part of Intelligent Mail Full Service is particularly attractive for these Periodicals mailers since they can now obtain these corrections free of charge, whereas in the past there was a charge per correction. Getting corrections for free, however, is no deal if the process results in not being able to get any address corrections at all.

An alternative is for mailers to continue to print the ACS participant codes and keylines on the mailpieces. This would allow the USPS to access this human readable data in cases where the IMb is obliterated or otherwise unreadable. However, this does not address the issue of the type of service requested by the mailer. Traditionally this would be indicated in the type of ancillary endorsement printed on the mailpiece (e.g. Change Service Requested). Under Intelligent Mail, however, the only endorsement permitted is Electronic Service Requested, so that would not be of any help in cases where the IMb is not readable. Also at issue is how these address corrections would be charged. Theoretically if the IMb is unreadable, the ACS notices would no longer be free but would rather be charged at traditional rates. However, if the USPS causes the barcodes to be unreadable, how will that be charged?

Mailers who plan to use Full Service ACS should be working with their mailing associations so that this concern can be communicated to the USPS. These mailers should also be working with their fulfillment suppliers or database managers to be actively participating in testing for the Full Service ACS program so that any potential problems can be identified quickly.

Everyone in the mailing industry wants Intelligent Mail to be successful, and only through timely communication can potential problems be identified and corrected quickly.

Monica Lundquist

Postal Affairs Manager

Window Book, Inc.