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June 1, 2012 FCC EEO Deadlines

May 3, 2012

Certain radio and television stations face an upcoming Federal Communications Commission (FCC or Commission) Equal Employment Opportunity (EEO) annual reporting deadline on Friday, June 1, 2012:

Annual EEO Public File Report
Radio and television station employment units (SEUs) located in the District of Columbia, Maryland, Virginia, West Virginia, Michigan, Ohio, Arizona, Idaho, Nevada, New Mexico, Utah and Wyoming with five or more full-time employees must prepare and place in their public inspection file(s) and post on their website(s) by Friday, June 1, 2012 an annual EEO Public File Report (PFR).

The PFR should summarize the SEU's recruitment activity from June 1, 2011 through May 31, 2012, including full-time positions filled, the recruitment sources used to advertise those job openings and the total number of interviewees and hirees produced by each recruitment source. The PFR must also include a summary of the SEU's recruitment initiatives.

The next round of broadcast license renewal applications are due by June 1, 2012 as well, which requires the filing of this key EEO report for certain radio and television stations:

FCC Form 396 Broadcast EEO Program Report
Radio stations in Michigan and Ohio and television stations in the District of Columbia, Maryland, Virginia and West Virginia must apply for license renewal on or before Friday, June 1, 2012. A critical component of the Commission's license renewal process is the Form 396 Broadcast Equal Employment Opportunity Program Report, which must be submitted to the FCC, electronically, prior to the filing of the Form 303-S Application for Renewal of Broadcast Station License. The Form 396 requires applicants to report discrimination complaints and, for SEUs with five or more full-time employees, to submit PFRs for 2011 (covering June 1, 2010-May 31, 2011) and 2012 (covering June 1, 2011-May 31, 2012).

If you would like a copy of our renewal primer, including information on the EEO component of the application, or should you have any questions about FCC EEO compliance, please contact the Wiley Rein attorneys listed below.