by Abby North
One of the greatest obstacles music publishers face in royalty collections is proper and comprehensive registration of all their works.
Within the United States, there are several performance rights organizations (PROs), two of which (ASCAP and BMI) expressly allow publishers to register works by providing data files using Musicmark’s Electronic Batch Registration (EBR) standard. SOCAN, the Canadian PRO also accepts EBR files.
EBR data is delivered as an .xls file, which makes the format accessible to all publishers.
Outside of the United States and Canada, societies are called Collective Management Organizations (CMOs), and they often collect mechanical royalties, and sometimes collect synchronization fees in addition to performance royalties.
To batch register works at the CMOs outside of the United States and Canada, publishers must deliver their data via Common Works Registration (CWR), a “standard” that is not truly standard because of each society’s unique data and naming requirements and because most publishers do not have the tools required to export data in CWR format.
While the CWR data specification file is readily available, examples of correct CWR files are not. CWR files are text files that must be specifically formatted per the CWR standard. (Current CWR files have a “.v21” suffix, which indicates CWR version 2.1.)
Those publishers with the means and inclination to license Vistex’s Music Maestro royalty administration software are able to export CWR files from Music Maestro. However, even these exports are often fallible, due in part to each CMO’s specific data requirements, which Music Maestro’s software is not always programmed to deliver correctly.
Matija Kolaric (www.matijakolaric.com) is a software developer and music publishing expert from Croatia who has built a set of subscription-based CWR tools that give music publishers that do not use Music Maestro the ability to create valid, accepted CWR files. Kolaric’s tools include an “EBR to CWR” converter. Except in some unusual cases, EBR files contain enough data to create a CWR file that will be accepted by many CMOs and most sub-publishers. The tools are able to accommodate additional data, should it be necessary.
Even with access to CWR tools, the raw data must be clean and it must be comprehensive. Without clean data, the CWR files will be rejected and the works will not be registered.
Publishers that create their own royalty administration databases must be aware of how EBR and CWR work, and specifically, what fundamental data fields are absolutely required. Data that is entered into one’s own database must be exact and confirmed upon ingestion, or the result is likely to be “garbage in, garbage out.”
When estimating the time required to develop royalty administration tools, ample time should be allowed for development of the CWR and/or EBR export tools within the publisher’s database. Because of the differences in each society’s requirements and interpretations of the ‘standard,’ ongoing trial and error is required. Sometimes this process can take months or years.
Some of the CWR specific requirements are:
–Within each work registration in a CWR file, every controlled publisher must have a clear relationship with at least one writer.
— The publisher’s database should create and store a unique “Submitter Work ID” for each work, and that “Submitter ID” should be included in the CWR file.
— Many foreign societies use society-assigned agreement IDs to identify publishing agreements. These agreement IDs reference information about the relationships among the original publisher, administrator and sub-publishers in various territories. ICE, a licensing service created by PRS, STIM and GEMA, monitors these agreements and generates the IDs for those societies, as well as for Koda, Teosto, Tono, Buma/Stemra and Sabam. When registering works at any society that uses agreement IDs, that agreement ID must be included in the CWR file. Each ICE society represented in the agreement ID will also receive those works registrations.
All of the party names and international identification numbers assigned to songwriters and publishers (IPIs) represented under that agreement ID must be included in the file, and the data must be correct, or the CWR file will be kicked back.
— The territories represented by the CMOs must be indicated in the CWR file. Different societies have specific territory requirements for registrations. For example, APRA requires that all of its local territories, which include Australia, Fiji, New Zealand, Vanuatu and Solomon Islands, are explicitly specified as included or excluded, something not required by PRS, whose local territories are United Kingdom and Ireland.
— Successful registrations require work titles and writer or publisher names that contain only allowed characters. For example, comma ‘,’ is allowed in a title, but not in a publisher’s name. An accent over an “e” (i.e. é)” is allowed only in some very specific cases.
After a publisher submits a CWR file to a society, that society returns an acknowledgement (ACK) file, which indicates which works were accepted and those that were rejected. For rejections, some explanation is typically provided, although the explanations are often not completely clear. Ideally, the royalty database has the ability to ingest and interpret ACK files so when a work is rejected, the publisher is alerted of the need to correct the data and re-submit the registration in a new CWR file.
After works have been successfully registered, the publisher is able to revise the registrations with new CWR files. The societies refer to the Submitter Work ID when identifying which work to revise.
While properly filling out an EBR or CWR file is not rocket science, many publishers find that their data is not ready for export to EBR or CWR. Though it may be extremely time-consuming, data clean-up and validation is crucial in works registration, or else substantial revenue could be missed globally.