Alert

December 1, 2020 FCC EEO Deadlines for Stations in AL, GA, CO, MN, MT, ND, SD, CT, ME, MA, NH, RI, VT

November 2, 2020

Annual EEO Public File Report

Radio and television station employment units (SEUs) located in Alabama, Georgia, Colorado, Minnesota, Montana, North Dakota, South Dakota, Connecticut, Maine, Massachusetts, New Hampshire, Rhode Island, and Vermont with five or more full-time employees must prepare by Tuesday, December 1, 2020, an annual EEO Public File Report (PFR). The report must be posted on the website belonging to each station in the SEU and uploaded to its online public inspection file at the Federal Communication Commission's (FCC’s) website.

Note: It is the licensee’s responsibility to ensure the PFR is uploaded to the online public inspection file by the deadline. Files receive an electronic date/time stamp when uploaded to the online public file, making it clear to FCC staff if they are posted late.

The PFR should summarize the SEU's recruitment activity from December 1, 2019 through November 30, 2020, 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.

Schedule 396 Broadcast EEO Program Report

Television SEUs in Alabama and Georgia and radio SEUs in Colorado, Minnesota, Montana, North Dakota and South Dakota must submit a license renewal application by Tuesday, December 1, 2020. Prior to submitting the license renewal application, each SEU must file a Schedule 396 Broadcast EEO Program Report.

The Schedule 396 requires licensees to report discrimination complaints and, for SEUs with five or more full-time employees, provide a narrative description of their outreach efforts, identify the individual with overall EEO responsibility at the SEU, and submit PFRs covering the time period from December 1, 2018 – November 30, 2019 and December 1, 2019 – November 30, 2020. Once filed, the FCC will automatically upload a copy of the Schedule 396 to the online public inspection file for each station in the employment unit.

If you have any questions about the annual PFR, the Schedule 396, or FCC EEO compliance in general, please contact the Wiley attorneys listed on this alert.

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