As of March 1, 2018, all radio and television stations were required to transition their public inspection file to the Federal Communications Commission’s (FCC) online public file system. However, despite the year-old deadline, a substantial number of broadcasters have not yet activated their online public file or have failed to keep their public file up-to-date.
These stations are at risk of substantial FCC fines. While the FCC has emailed warning notices to some stations, we strongly urge you not to wait for an FCC notice. Stations should immediately confirm that they are complying with the FCC’s rules.
Ensuring that your station’s online public file is online and complete takes on added importance as we enter the license renewal cycle. Renewal applications require stations to either certify that their public file has been complete and up-to-date at all times during the license term or disclose violations. In addition to substantial fines, an incomplete online public file can lead to extensive delays in the license renewal process.
Of particular concern is the failure to upload the quarterly issues/programs lists, which demonstrate how a station has addressed the needs and interests of its community. These lists must be placed in each station’s online public file on a quarterly basis, going back to the start of the current 8-year license term. Failure to comply can be extremely costly. The FCC recently fined five radio stations $10,000 to $12,000 each for lacking copies of the issues/programs lists in their online public files. In addition to the issues/programs lists, stations should promptly upload their annual EEO public file reports, children’s television reports, political broadcasting information, and all other required materials.
If you have questions, please contact your station’s legal counsel or the NAB legal department at 866.682.0276.