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 previous quarter. The listing should include 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 the program, the duration of each responsive programming segment, and a brief explanation of how the programming addressed the issue(s).
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: all commercial radio stations should have uploaded their public inspection file documents (including quarterly issue-responsive programming lists) to their online public inspection files. This online public file requirement at first applied 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 had until March 1, 2018 to begin compliance with the online public file rule. For more information about the online public file requirement for radio stations, see this memo.
If you have any questions about these ongoing recordkeeping obligations, please contact any attorney in our office.