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April 1, 2015 FCC EEO Deadlines
Certain radio and television stations face an upcoming Federal Communications Commission (FCC or Commission) Equal Employment Opportunity (EEO) annual reporting deadline on Wednesday, April 1, 2015:
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 Wednesday, April 1, 2015 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, 2014 through March 31, 2015, 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.
Certain broadcast license renewal applications are due on April 1, 2015. 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
Television stations in Delaware and Pennsylvania must apply for license renewal on or before Wednesday, April 1, 2015. 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 2014 (covering April 1, 2013-March 31, 2014) and 2015 (covering April 1, 2014-March 31, 2015).
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.