Sinclair submitted a revised plan for its proposed $3.9 billion acquisition of Tribune Media, which includes the divestiture of WGN-TV in Chicago, and WPIX-TV in New York in order to comply with the FCC’s 39 percent national ownership cap.

According to a Wednesday FCC filing, spotted by MultiChannel News, Sinclair has purchase agreements with undisclosed buyers, with the deals concluding around the time the Tribune merger is completed.

In footnotes, however, Sinclair indicated it would enter into service agreements with the buyers; a move Bloomberg pointed out that could leave the broadcast giant in de facto control over a placeholder owner.

“It’ll be one of those arrangements where, for all intents and purposes, they still own and run the stations,” Gigi Sohn, an FCC aide when the agency in 2014, tried to curb sharing practices used by Sinclair and others, told Bloomberg. “It is a complete and total evasion of the rules.”

FCC Ajit Pai last year put an end to the previous Democratic FCC’s guidance to carefully examine joint service agreements.

Sinclair is also divesting one or more stations in Seattle-Tacoma; St. Louis, Mo.; Salt Lake City, Utah; Oklahoma City, Okla.; Greensboro-High Point-Winston Salem, N.C.; Grand Rapids, Mich.; Richmond, Va.; and Des Moines-Ames, Iowa.

The company is seeking permission to own two of the top four stations in Greensboro-High Point-Winston Salem, N.C., Harrisburg-Lancaster-Lebanon-York, Pa., and Indianapolis.

Sinclair also wants to keep both of its stations in Portland, Ore., as the FCC eliminated the requirement that at least eight independently owned TV stations remain in a market after combining ownership of two stations.

The FCC will consider the potential duopolies on a case-by-case basis.

Last month the FCC paused its review of the proposed deal, putting its 180-day “shot clock” for the merger on hold so divestiture applications from Sinclair could be filed and fully reviewed by the agency.