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Category Archives: EEO Compliance/Diversity

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FCC Finds Online Sources Satisfy EEO Requirements for Wide Dissemination of Job Openings by Broadcasters and MVPDs

Posted in EEO Compliance/Diversity
The FCC on Friday released a declaratory ruling making it significantly easier for broadcasters and MVPDs to meet their EEO obligations imposed by FCC rules.  These rules for broadcasters and MVPDs (cable and satellite TV providers) requires that these businesses, when filling job openings, widely disseminate information about the openings in a manner that is… Continue Reading

FCC to Eliminate Need for Social Security Numbers from Board Members of Noncommercial Licensees for Biennial Ownership Report

Posted in EEO Compliance/Diversity, Noncommercial Broadcasting
Last week, we wrote about two of the three broadcast items to be considered at the FCC meeting on April 20. We wrote here about the draft order to restore the UHF discount, and here about the relaxation of the restrictions on fund-raising for third parties by noncommercial stations. The third item, also related to… Continue Reading

April Regulatory Dates for Broadcasters – Quarterly Issues Programs Lists and Children’s Television Reports, Incentive Auction Closing Notice, AM Translator Site Relocation Relaxation Effective Date

Posted in Children's Programming and Advertising, EEO Compliance/Diversity, FM Radio, FM Translators and LPFM, General FCC, Incentive Auctions/Broadband Report, Noncommercial Broadcasting, Programming Regulations, Public Interest Obligations/Localism, Television
April has many important dates for broadcasters – both radio and TV.  This includes both regular regulatory obligations and dates unique to this April for both radio and TV – including the release of the FCC’s Closing Notice for the TV incentive auction and the effective date for the new rules liberalizing the location of… Continue Reading

What’s Up for Broadcasters in Washington Under the New Administration – A Look Ahead at TV and Radio FCC Issues for the Rest of 2017

Posted in AM Radio, EEO Compliance/Diversity, FCC Fines, FM Radio, FM Translators and LPFM, General FCC, Incentive Auctions/Broadband Report, Indecency, Multiple Ownership Rules, Noncommercial Broadcasting, Political Broadcasting, Programming Regulations, Television
A new President and a new Chair of the FCC have already demonstrated that change is in the air in Washington. Already we’ve seen Chairman Pai lead the FCC to abolish the requirement that broadcasters maintain letters from the public about station operations in their public file (which will take effect once the Paperwork Reduction… Continue Reading

FCC Releases First EEO Audit for 2017 – Over 200 Radio and Almost 80 TV Stations Named in the Audit Notice

Posted in AM Radio, EEO Compliance/Diversity, FCC Fines, FM Radio, Television
In the swirl of news about the deregulatory efforts of the new FCC, one could almost forget that there are still many regulations in place that require significant amounts of paperwork retention by broadcasters. That point was hammered home yesterday, when the FCC released its first EEO audit letter of 2017 for radio and TV… Continue Reading

FCC Votes to Abolish Requirement for Retaining Letters From the Public on Station Operations – First Step in Broadcast Deregulation?

Posted in AM Radio, EEO Compliance/Diversity, FM Radio, General FCC, License Renewal, Programming Regulations, Public Interest Obligations/Localism
The FCC on Tuesday voted to abolish the 44 year old requirement that commercial broadcast stations retain, in their public file, letters (and emails) from the public dealing with station operations (see the full Order here). As noted by the Commissioners in their comments at the FCC meeting (and as we suggested here and here… Continue Reading

February Regulatory Dates for Broadcasters – EEO Reports and Comments on Ownership, EEO and Copyright Issues

Posted in EEO Compliance/Diversity, FM Radio, General FCC, Incentive Auctions/Broadband Report, Intellectual Property, Internet Radio, Multiple Ownership Rules, Music Rights, Television
While there is a new administration in charge at the FCC, there are still those regular regulatory dates that broadcasters must face, as well as dates unique to pending proceedings that arise from time to time. Before we get to the February dates, we should remind broadcasters of those January 31 dates that they should… Continue Reading

FCC Denies Reconsideration of Noncommercial Broadcasting Ownership Report Requirements – But Signs that New Commission May See Things Differently

Posted in EEO Compliance/Diversity, General FCC, Multiple Ownership Rules, Noncommercial Broadcasting
The FCC’s Media Bureau yesterday issued an order denying reconsideration of the full Commission decision from last year, synchronizing the Biennial Ownership Report filing requirement for noncommercial broadcasters with that of commercial broadcasters, and requiring that all individuals who have attributable interests in these stations obtain an FCC Registration Number (an “FRN”)(see our summary of… Continue Reading

January Regulatory Dates for Broadcasters – Quarterly Issues Programs Lists and Children’s Television Reports, Ownership and EEO Comments, Copyright Issues and More

Posted in Children's Programming and Advertising, EEO Compliance/Diversity, General FCC, Intellectual Property, Internet Radio, Internet Video, Multiple Ownership Rules, Music Rights, On Line Media, Programming Regulations, Public Interest Obligations/Localism, Television, Website Issues
Here we are at the start of a new year, and right away we have numerous regulatory deadlines for broadcasters. By the 10th of the month, all broadcast stations need to have placed in their public inspection files (online for TV and for those radio stations that have already converted to the online public file,… Continue Reading

Should Online Recruiting Satisfy the FCC’s EEO Requirements for Wide Dissemination of Job Openings? – Comments Requested on Petition Saying that it Does

Posted in AM Radio, EEO Compliance/Diversity, FM Radio, Television
The FCC yesterday issued a Public Notice of the filing of a Petition for Rulemaking asking the FCC to declare that a broadcaster, by using its own airwaves and online sources to publicize job openings at its station, satisfies the requirement that a broadcaster widely disseminate information about job openings to members of all groups… Continue Reading

And Then There Were Three – Chairman Wheeler to Step Down on Inauguration Day Leaving a Republican-Controlled FCC – What’s It Mean for Broadcasters?

Posted in AM Radio, EEO Compliance/Diversity, General FCC, Multiple Ownership Rules
After months of speculation, Chairman Wheeler today announced that he will step down from the FCC on Inauguration Day. Together with the Senate not confirming the renomination of Commissioner Rosenworcel (as the Senate is effectively on recess and not expected to return before the end of the term, her renomination will almost certainly not be… Continue Reading

December Regulatory Dates for Broadcasters – EEO Reports, Ownership and Ancillary Revenue Reports, Ownership Review and Incentive Auction Updates

Posted in Broadcast Auctions, EEO Compliance/Diversity, FCC Fees, General FCC, Incentive Auctions/Broadband Report, Multiple Ownership Rules, Noncommercial Broadcasting
While we are into the holiday season, that does not stop the routine regulatory obligations for broadcasters. December 1 brings a host of routine obligations for stations in many states. EEO public file reports must be added to the public files of Commercial and Noncommercial Full-Power and Class A Television Stations and AM and FM… Continue Reading

Looking at the Last Night’s Election Results and the Future of Washington Policy For Broadcasters

Posted in EEO Compliance/Diversity, General FCC, Multiple Ownership Rules
Early this week, in some of the legal journals that circulate in Washington, there was much speculation as to potential appointees to various government positions after the election. For positions such as the chairman of the FCC, many of these publications listed familiar DC names as likely appointees if, as expected by most pundits, Hillary… Continue Reading

October Regulatory Dates for Broadcasters – Quarterly Issues Programs Lists and Children’s Television Reports, EEO Obligations, Noncommercial Biennial Ownership Reports, and Incentive Auction Comment Deadlines

Posted in AM Radio, Broadcast Auctions, Children's Programming and Advertising, EEO Compliance/Diversity, FM Radio, General FCC, Incentive Auctions/Broadband Report, Noncommercial Broadcasting, Programming Regulations, Television
Another month has started – and it is one with regulatory dates for broadcasters. All broadcasters, commercial and noncommercial, have an obligation to complete their Quarterly Issues Programs lists and place them into their public inspection filed by October 10. For TV stations and large-market commercial radio, that means that these lists need to be… Continue Reading

Full Text of FCC Decision on Quadrennial Review of the Multiple Ownership Rules Released Today

Posted in AM Radio, EEO Compliance/Diversity, FM Radio, Multiple Ownership Rules, Television
In the last few minutes, the FCC has released its order on the Quadrennial Review of its multiple ownership rules, about which we wrote last week. The decision is available here, and includes dissenting opinions from the two Republican commissioners and a concurring statement from Commissioner Clyburn. In total, the text is 199 pages long,… Continue Reading

Preparing for the FCC’s Soon to be Released Decision on Changes to its Multiple Ownership Rules

Posted in AM Radio, EEO Compliance/Diversity, FM Radio, Multiple Ownership Rules, Public Interest Obligations/Localism, Television
While the trade press has been full of reports that the FCC has voted on an order addressing the issues raised in its Quadrennial Review of its multiple ownership rules, and that the decision largely left those rules unchanged (including the broad ban on the cross-ownership of daily newspapers and broadcast stations), no final decision… Continue Reading

August Regulatory Dates for Broadcasters – New Fees, EAS Registration Requirement, EEO Obligations and More

Posted in Broadcast Auctions, EEO Compliance/Diversity, Emergency Communications, FCC Fees, FCC Fines, Incentive Auctions/Broadband Report
As we enter the last full month of summer, when many are already looking forward to the return to the more normal routines of autumn, regulatory obligations for broadcasters don’t end. Even if you are trying to squeeze in that last-minute vacation before school begins or other Fall commitments arise, there are filing deadlines this… Continue Reading

$11,000 FCC EEO Fine for Recruiting Solely Through Online Sources – Time to Revisit the FCC Rules?

Posted in EEO Compliance/Diversity, FCC Fines
An FCC decision fining a cable company $11,000 for not adequately recruiting for job openings should be viewed as a warning to broadcasters as well as well as MVPDs – failure to recruit for job openings by disseminating information about those opening through diverse sources will likely result in a substantial fine under the current… Continue Reading

Legal Issues for Broadcasters – Updates on Pending Matters

Posted in AM Radio, Appearances, Cable Carriage, Digital Television, EEO Compliance/Diversity, Emergency Communications, FM Radio, FM Translators and LPFM, General FCC, Incentive Auctions/Broadband Report, Low Power Television/Class A TV, Multiple Ownership Rules, Music Rights, Payola and Sponsorship Identification, Political Broadcasting, Programming Regulations, Public Interest Obligations/Localism, Television
There are so many legal issues that facing broadcasters that it is sometimes difficult to keep up with them all. This Blog and many other activities that those at my firm engage in are meant to help our clients and other broadcasters keep up to date on all of the many regulatory challenges with which… Continue Reading

June Regulatory Dates for Broadcasters – EEO and Noncommercial Ownership Reports, Incentive Auction, Radio Online Public File, and Comments on EAS and Regulatory Fees

Posted in AM Radio, EEO Compliance/Diversity, Emergency Communications, FCC Fees, FM Radio, General FCC, Incentive Auctions/Broadband Report, Television
While summer has just about arrived, FCC regulatory dates do not depart to the beach and leave the world behind.  Instead, there are a host of filing deadlines this month.  EEO Public Inspection file reports must, by June 1, be placed in the public inspection files of stations that are part of employment units with… Continue Reading

Appeals Court Tells FCC to Finalize Multiple Ownership Review, Throws Out TV JSA Attribution, and Questions Newspaper-Broadcast Cross-Ownership Ban

Posted in EEO Compliance/Diversity, Multiple Ownership Rules
The Third Circuit Court of Appeals yesterday issued an opinion faulting the FCC for not completing any required review of its broadcast ownership rules since the 2006 review was completed in 2007. These reviews of its ownership rules, now done as “Quadrennial Reviews” every four years, but previously required to be done biennially, have been… Continue Reading

FCC Announces June 24 Effective Date for Radio Online Public Inspection File and New System for TV Stations Online File, Plus a Reminder to Upload JSAs

Posted in AM Radio, EEO Compliance/Diversity, FM Radio, General FCC, Multiple Ownership Rules, On Line Media, Political Broadcasting, Public Interest Obligations/Localism, Television, Website Issues
The FCC today issued a Public Notice that the obligation will begin on June 24 to start uploading documents to the online public file for radio stations in the Top 50 markets .   For Top 50 market commercial radio stations that are part of employment units with 5 or more full-time employees, the June 24… Continue Reading

Summer Internships – Good for FCC EEO Credit, But Be Careful of Wage and Hour Law Implications

Posted in EEO Compliance/Diversity
As summer approaches, many stations are preparing for the arrival of summer interns.  While internship programs can earn stations EEO “credit” towards meeting the requirement that they conduct non-vacancy specific outreach efforts (the so-called “menu options” or “supplemental efforts” offered by the FCC to encourage stations to reach out to their communities to educate community residents as… Continue Reading