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Category Archives: EEO Compliance/Diversity

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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

Appeal Date Set for Changes in FCC Rules for Biennial Ownership Reports – Why Many College and University Licensees are Concerned

Posted in EEO Compliance/Diversity, General FCC, Noncommercial Broadcasting
The changes in the FCC’s rules for Biennial Ownership Reports on FCC Form 323 were today published in the Federal Register. That publication starts the 30 day clock for petitions for reconsideration or requests for appeal of that decision. We summarized the changes in the requirements here – changes that include putting noncommercial stations on… Continue Reading

April Regulatory Dates for Broadcasters – Quarterly Issues Programs Lists and Children’s Television Reports and Much More

Posted in AM Radio, Cable Carriage, Children's Programming and Advertising, EEO Compliance/Diversity, FM Radio, General FCC, Multiple Ownership Rules, Noncommercial Broadcasting, Political Broadcasting, Programming Regulations, Public Interest Obligations/Localism, Television
April brings the whole panoply of routine regulatory dates – from the need to prepare EEO Public File and Noncommercial Ownership Reports in some states, to Quarterly Issues Programs lists for all full-power broadcast stations and Quarterly Children’s Television Programming Reports for all TV stations.  So let’s look at some of the specific dates that… Continue Reading

Online Public Inspection File for Radio Still in the Future – Practical Impact Still a Few Months Away

Posted in AM Radio, EEO Compliance/Diversity, FM Radio, General FCC, On Line Media, Political Broadcasting, Public Interest Obligations/Localism, Television, Website Issues
In the last day or two, some broadcast trade press reports may have given the impression that the FCC’s new online public file rules for radio may now be “effective,” suggesting that Top 50 market stations with 5 or more full-time employees need to start uploading their new political documents into the file (the first… Continue Reading

FCC Announces First Round of 2016 EEO Audits for Radio and TV Stations

Posted in AM Radio, EEO Compliance/Diversity, FM Radio, Television
The FCC today issued a Public Notice announcing its first EEO audit for 2016.  Letters to about 280 radio and television stations went out on February 24 asking for evidence of their compliance with the FCC’s EEO rules.  In today’s notice, the FCC released the form audit letter and list of stations that will be audited.… Continue Reading

FCC Order on Biennial Ownership Requirements – All Broadcasters, Commercial and Noncommercial, Need to Start Collecting Information from Attributable Owners and Directors for Next Year’s Filing

Posted in AM Radio, EEO Compliance/Diversity, FM Radio, General FCC, Multiple Ownership Rules, Noncommercial Broadcasting, Television
In an order released last month which has not received much attention, the FCC clarified its requirements for the filing of Biennial Ownership Reports. Much of the order deals with fixes to the report itself that will, for the most part, make the completion of the report administratively easier in terms of the physical data… Continue Reading

FCC Releases Order on Online Public Inspection File – Answering Questions about Compliance with Radio’s New Obligations

Posted in AM Radio, EEO Compliance/Diversity, FM Radio, General FCC, Noncommercial Broadcasting, On Line Media, Political Broadcasting, Programming Regulations, Public Interest Obligations/Localism, Television, Website Issues
Last week, we wrote about the FCC’s decision to require that radio stations move their public inspection files online.  Stations with 5 or more full-time employees that are located in Top 50 markets need to make the transition to the online file later this year once the FCC gets its new rules approved by the… Continue Reading

February Regulatory Dates for Broadcasters

Posted in AM Radio, EEO Compliance/Diversity, FM Radio, FM Translators and LPFM, General FCC, Incentive Auctions/Broadband Report, Internet Radio, Noncommercial Broadcasting, Political Broadcasting, Television
It’s February, and we’re back to the normal cycle of FCC filings. Due to be placed in the public files of radio and TV stations with 5 or more full-time employees are EEO Public Inspection File Reports for radio and TV stations in the following states: Arkansas, Kansas, Louisiana, Mississippi, Nebraska, New Jersey, New York,… Continue Reading

What Washington Has in Store for Broadcasters in 2016 – Looking at the Legal Issues that the FCC Will Be Considering in the New Year

Posted in Advertising Issues, AM Radio, Broadcast Auctions, Cable Carriage, EEO Compliance/Diversity, Emergency Communications, FM Radio, FM Translators and LPFM, General FCC, Indecency, Internet Video, Low Power Television/Class A TV, Multiple Ownership Rules, Noncommercial Broadcasting, On Line Media, Payola and Sponsorship Identification, Political Broadcasting, Programming Regulations, Public Interest Obligations/Localism, Television
It’s that time of the year when we need to dust off the crystal ball and make predictions about the legal issues that will impact the business of broadcasters in 2016.  While we try to look ahead to identify the issues that are on the agenda of the FCC and other government agencies, there are… Continue Reading

December Regulatory Dates for Broadcasters – Ownership and EEO Reports, Retransmission Consent and Foreign Ownership Rulemaking Comments, Incentive Auction and Accessibility Obligations

Posted in Cable Carriage, Digital Television, EEO Compliance/Diversity, Emergency Communications, FCC Fees, General FCC, Incentive Auctions/Broadband Report, Internet Video, Noncommercial Broadcasting, On Line Media, Programming Regulations, Public Interest Obligations/Localism, Television, Website Issues
December is one of those months when all commercial broadcasters have at least one FCC deadline, and there are also many other filing dates of which many broadcasters need to take note.  For all commercial broadcasters, Biennial Ownership Reports are due on December 2.  Hopefully, most broadcasters have already completed this filing obligation, as FCC… Continue Reading

FCC Sets Comment Dates on Proposal to Relax Restrictions on Foreign Ownership in Companies Holding US Broadcast Station Licenses – What Is the FCC Proposing?

Posted in AM Radio, Assignments and Transfers, Digital Television, EEO Compliance/Diversity, FM Radio, Multiple Ownership Rules, Television
In Friday’s Federal Register, the FCC published a summary of the Commission’s Notice of Proposed Rulemaking looking to revise its policies regarding the ownership of broadcast stations by non-US citizens setting the date for comments on its proposal of December 21, with Reply Comments being due by January 20.  The FCC two years ago issued… Continue Reading

November Regulatory Dates for Broadcasters – Incentive Auction and Biennial Ownership Report Preparation, Reg Fee Comments, Music Issues, Text to Speech Emergency Information and More

Posted in AM Radio, Broadcast Auctions, Broadcast Performance Royalty, Cable Carriage, Digital Television, EEO Compliance/Diversity, Emergency Communications, FCC Fees, FM Radio, General FCC, Intellectual Property, Internet Radio, Music Rights, Television
November is another of those months with no regular filing obligations – no EEO public file and Mid-Term reports, no noncommercial ownership reports, and no quarterly issues programs lists or children’s television reports. EEO public file reports and noncommercial station ownership reports, being tied to renewal dates, will be back in December. See our Broadcaster’s… Continue Reading

October Regulatory Dates for Broadcasters – Many Routine Filings for All Broadcasters, Incentive Auction Actions, and More

Posted in AM Radio, Cable Carriage, Children's Programming and Advertising, Digital Television, EEO Compliance/Diversity, FM Radio, FM Translators and LPFM, General FCC, Incentive Auctions/Broadband Report, License Renewal, Low Power Television/Class A TV, Noncommercial Broadcasting, Programming Regulations, Public Interest Obligations/Localism, Television
October is one of those months where the regulatory stars align, when not only do broadcasters in many states have EEO Public File report obligations, but also Quarterly Issues Programs Lists need to be placed in the public files of all commercial and noncommercial stations, and Quarterly Children’s Television Reports need to be filed at… Continue Reading

FCC Sets December 2 Deadline for Filing 2015 Biennial Ownership Reports for Commercial Broadcast Stations

Posted in AM Radio, Digital Television, EEO Compliance/Diversity, FM Radio, General FCC, Low Power Television/Class A TV, Multiple Ownership Rules, Public Interest Obligations/Localism, Television
The FCC today released an Order setting December 2 as the date for the filing of FCC Form 323 Ownership Reports by commercial broadcast stations. All commercial broadcasters must submit this report. While the report is technically supposed to be filed by November 1 every other year, that date has routinely been extended as the… Continue Reading

August Regulatory Dates for Broadcasters – While Incentive Auction Dominates the News, Other Dates to Watch

Posted in AM Radio, Cable Carriage, Digital Television, EEO Compliance/Diversity, Emergency Communications, FCC Fees, FM Radio, General FCC, Incentive Auctions/Broadband Report, License Renewal, Noncommercial Broadcasting, Programming Regulations, Public Interest Obligations/Localism
With tomorrow’s FCC meeting to detail dates and procedures for the TV incentive auction dominating the headlines, there are other August regulatory dates that should not be overlooked. While we never can get to all of the relevant dates in our monthly highlight article, here are a few items worth your consideration. For one, we… Continue Reading

July Regulatory Dates for Broadcasters – Quarterly Issues Programs Lists and Children’s Television Reports, Incentive Auction Actions, CRB Webcasting Closing Argument and More

Posted in Broadcast Auctions, Children's Programming and Advertising, Digital Television, EEO Compliance/Diversity, FM Radio, Incentive Auctions/Broadband Report, Intellectual Property, Internet Radio, Music Rights, Programming Regulations, Public Interest Obligations/Localism, Television
Another month is upon us, with the typical list of FCC dates of importance – and some new issues (including incentive auction developments that will probably be a regular part of our news through a good part of next year). One date of importance to some TV broadcasters was yesterday – July 1 – when… Continue Reading

June Regulatory Dates for Broadcasters – EEO Public File Reports and Form 397, CALM Act Compliance Obligations, Incentive Auction Actions, Comments on Reg Fees and LPFM Rules, and More

Posted in Digital Television, EEO Compliance/Diversity, FCC Fees, FM Radio, FM Translators and LPFM, General FCC, Incentive Auctions/Broadband Report, License Renewal, Noncommercial Broadcasting, Programming Regulations, Public Interest Obligations/Localism, Television
June brings some standard obligations for broadcasters in a number of states with anniversaries of their license renewal filing, plus the return of an obligation that we have not seen in 4 years- the obligations of radio stations in certain states to file an FCC Form 397 Mid-Term EEO Report. In addition to these routine… Continue Reading

FCC Issues Reminder on Form 397 EEO Mid-Term Reports – Filing Obligations Begin on June 1 for Radio Stations in DC, Maryland, Virginia and West Virginia

Posted in AM Radio, EEO Compliance/Diversity, FM Radio, License Renewal
EEO Mid-Term Reports on FCC Form 397 must be filed at the mid-point of the renewal cycle of radio stations if they are part of a station employment unit with more than 10 full-time employees, or 5 or more full-time employees for TV. A station employment unit is one or more commonly-controlled stations serving substantially the… Continue Reading

May Regulatory Dates for Broadcasters – Including EEO Mid-Term Reports, FM Auction, Emergency Communications Compliance, TV Market Modification Comments, Class A TV Digital Conversion Deadline and More

Posted in Broadcast Auctions, Cable Carriage, EEO Compliance/Diversity, Emergency Communications, FM Radio, General FCC, Incentive Auctions/Broadband Report, License Renewal, Television
May is one of those months where there are no routine, recurring FCC regulatory filing deadlines – no EEO reports or Quarterly Issues Programs lists, no Children’s Television Programming Reports or noncommercial station ownership report deadlines. But, as with any month, that does not mean that there are no dates of concern for broadcasters –… Continue Reading

The Confusing State of AM Radio Revitalization Efforts – No FM Translator Window for AM Licensees?

Posted in AM Radio, EEO Compliance/Diversity, FM Translators and LPFM, Incentive Auctions/Broadband Report, Public Interest Obligations/Localism
Almost two years ago, the FCC launched its AM revitalization efforts with great flourish, and promises of prompt action. We wrote about the two aspects of potential assistance for AM stations that were proposed in the FCC’s Notice of Proposed Rulemaking – technical proposals which mostly focused on ways to make the relocation of AM… Continue Reading

April Regulatory Dates for Broadcasters – Including Quarterly Issues Programs and Children’s Television Reports; Comments In Proceedings Including One on Digital Auxiliaries; and More Incentive Auction Seminars

Posted in Broadcast Auctions, Children's Programming and Advertising, EEO Compliance/Diversity, FM Radio, General FCC, Incentive Auctions/Broadband Report, License Renewal, Noncommercial Broadcasting, Payola and Sponsorship Identification, Programming Regulations, Public Interest Obligations/Localism, Television
April is one of those months with many routine FCC obligations. Quarterly Issues Programs lists need to be in your public file by the 10th of the month. This is an obligation for all full-power broadcast stations – commercial or noncommercial. Similarly, all TV stations have an obligation to submit their Children’s Television Reports on… Continue Reading

March Regulatory Dates for Broadcasters – Closed Captioning Quality Standards Effective Date, Comments on Online Public File, MVPD Status for Online Video Providers, LIFO for Political Ads, and FRNs for Biennial Ownership Reports

Posted in AM Radio, EEO Compliance/Diversity, FM Radio, General FCC, Internet Video, License Renewal, Noncommercial Broadcasting, On Line Media, Political Broadcasting, Programming Regulations, Television
March is one of those rare months on the broadcast calendar when there are few routine regulatory deadlines for broadcasters. As we are winding down in the television license renewal cycle, the month’s only license renewal obligations for TV broadcasters are the pre-filing license renewal announcements on the 1st and 16th of the month for… Continue Reading