Last week, the FCC voted to eliminate the requirement that larger radio and television stations submit the EEO Mid-Term Report (FCC Form 397) at the midpoint of their license terms. While the FCC will continue to conduct EEO mid-term reviews, it determined that filing the EEO Mid-Term Report was no longer necessary, as most of the information required for an EEO mid-term review is already available in a broadcaster’s on line public inspection file. Two important points:
- MID-TERM EEO REPORTS FOR NEW YORK TELEVISION STATIONS WERE DUE ON FEBRUARY 1, 2019. YOU MUST STILL FILE THESE REPORTS.
- SECOND, WHILE THE FCC ELIMINATED THE ACTUAL REPORT (FORM 397), IT WILL STILL ANALYZE YOUR PERFORMANCE. THE UNDERLYING EEO OBLIGATION REMAINS.
In fact, the FCC will require radio stations uploading an annual EEO public file report to its On-line Public File (OPIF), to identify whether their staff size is sufficient (i.e., five or more full time employees) to trigger a mid-term review. This information, entered into the OPIF itself rather than simply recorded on an uploaded document, will allow Commission staff to quickly and easily identify stations subject to mid-term review.
For additional information from our friends at Pillsbury Winthrop LLP click HERE.
To see a copy of the FCC’s Decision click HERE.
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