Commercial and non-commercial AM and FM stations must prepare and place in their public inspection files a list of programs that have provided the most significant treatment of community issues during the preceding quarter. The listing should provide a brief narrative statement that identifies the issues that were given significant treatment, and should describe the programs in which the issues were addressed. Each program description must include the date, time and title of each program, the duration of each responsive programming segment, and a brief explanation demonstrating how the programming addressed the community issue.
The maintenance of issue-responsive programming lists is required under the FCC’s public inspection file rule. Fines of $10,000 and more have been assessed when quarterly issues programs lists were not timely prepared and placed in the public file as required.
As a reminder: Many commercial radio stations now need to upload public inspection file documents (like quarterly issue-responsive programming lists) to their online public inspection files. This new online public file requirement currently applies to commercial radio stations that have five or more full-time employees in their employment units, and are located in one of the top 50 Nielsen Audio markets. Other stations have until 2018 to begin compliance with the online public file rule. For more information about the new online public file requirement for radio stations, see our May 18, 2016 memo.
If you have any questions about these ongoing recordkeeping and related obligations, please contact one of the Lerman Senter attorneys with whom you work.