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 regulatory deadlines, comment dates on certain FCC proceedings, a new CALM Act deadline, and some decisions for which broadcasters should be watching are among the regulatory actions that we can expect this coming month.
First, let’s look at the standard recurring obligations. By June 1, Annual EEO Public Inspection File Reports need to be placed in the public inspection files (including the online files of TV stations) of stations that are part of a station employment unit with five or more full-time (30 hours per week) employees that are licensed to communities in these states: Arizona, Idaho, Maryland, Michigan, Nevada, New Mexico, Ohio, Utah, Virginia, West Virginia, Wyoming, and the District of Columbia. As we wrote in more detail yesterday, June 1 also brings the obligation of radio stations that are part of employment units with 11 or more full-time employees, and are located in Maryland, DC, Virginia or West Virginia to file their Form 397, EEO Mid-Term Report. Every other month for the next four years we will see a similar obligation arise for a group of radio or TV stations in states that have celebrated the 4th anniversary of the filing of their license renewal applications.
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