On Friday, the FCC released a Public Notice announcing that the rules requiring the inclusion in the online public file of TV station “shared services agreements” is now effective after having been approved by the Office of Management and Budget pursuant to the Paperwork Reduction Act. This obligation for TV stations to put in their public file agreements between independently owned TV stations for shared broadcast services (including shared news operations, accounting staffs and other operational matters) became effective on March 23. It was adopted in the 2016 FCC Ownership Order and the obligation was not changed in last year’s reconsideration of that order (see our summary here). Thus, new shared services agreements should be placed into the public file shortly after being entered into. Agreements existing before the March 23 effective date need to be added to the file within 180 days. As the definition of shared services agreements is very broad, seemingly including pretty much any kind of service other than an on-the-fly, single event-based news cooperation agreements and agreements totally unrelated to broadcast operations (like shared janitorial services), if your TV station shares services of any sort with another station in its market, talk to your attorney about whether that agreement needs to be included in your public file.
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