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April 1, 2013 FCC EEO Deadlines

February 20, 2013

Certain radio and television stations face an upcoming Federal Communications Commission (FCC or Commission) Equal Employment Opportunity (EEO) annual reporting deadline on Monday, April 1, 2013:

Annual EEO Public File Report
Radio and television station employment units (SEUs) located in Indiana, Kentucky, Tennessee, Texas, Delaware and Pennsylvania with five or more full-time employees must prepare and place in their public inspection file(s) and post on their website(s) belonging to each station in the SEU by Monday, April 1, 2013 an annual EEO Public File Report (PFR).  (All full-power and Class A television stations must also upload the PFR to the station's online public inspection file hosted by the FCC.)

The PFR should summarize the SEU's recruitment activity from April 1, 2012 through March 31, 2013, including full-time positions filled, the recruitment sources used to advertise those job openings and the total number of interviewees and hires 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 April 1, 2013 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 Texas as well as television stations in Indiana, Kentucky and Tennessee must apply for license renewal on or before Monday, April 1, 2013.  A critical component of the Commission's license renewal process is the Form 396 Broadcast EEO 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 2012 (covering April 1, 2011 - March 31, 2012) and 2013 (covering April 1, 2012 - March 31, 2013).  Once filed with the FCC, the Form 396 must be placed in the public inspection file(s) belonging to each station in the SEU.  (In the case of full-power and Class A television stations, the Form 396 must be uploaded to the station's online public inspection file hosted by the FCC.)

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.