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April 1, 2014 FCC EEO Deadlines

March 5, 2014

Certain radio and television stations face an upcoming Federal Communications Commission (FCC or Commission) Equal Employment Opportunity (EEO) annual reporting deadline on Tuesday, April 1, 2014: 

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 by Tuesday, April 1, 2014 an annual EEO Public File Report (PFR).  The report must be placed in the public inspection file of each station in the SEU.  For full-power and Class A television stations, this means the PFR must be uploaded to the station's online public inspection file hosted by the FCC. The PFR must also be posted on the website belonging to each station in the SEU. 
 
The PFR should summarize the SEU's recruitment activity from April 1, 2013 through March 31, 2014, 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.
 
Note:  Television stations in Delaware and Pennsylvania will be filing license renewal applications on April 1, 2015.  These stations should consider sending a draft of the April 1, 2013 through March 31, 2014 PFR for our review now—the PFR must be filed with the Commission as part of the Form 396 Broadcast EEO Program Report next April (in addition to the subsequent April 1, 2014-March 31, 2015 PFR).
 


Certain broadcast license renewal applications are due on April 1, 2014.  The license renewal process includes the filing of an FCC Form 396 Broadcast EEO Program Report, as described below: 
 
FCC Form 396 Broadcast EEO Program Report 

Radio stations in Delaware and Pennsylvania as well as television stations in Texas must apply for license renewal on or before Tuesday, April 1, 2014.  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 2013 (covering April 1, 2012-March 31, 2013) and 2014 (covering April 1, 2013-March 31, 2014).  
 
Once filed with the FCC, the Form 396 must be placed in the public inspection file of each station in the SEU.  For full-power and Class A television stations, the FCC will automatically place the electronically filed Form 396 in the station's online public inspection file.  Stations should check their online public files to make sure the Form 396 is there.

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.