FCC Eliminates Paper Filing of Broadcast Contracts

The FCC has eliminated the requirement that broadcasters file paper copies of certain station contracts, agreements, and ownership-related documents. Broadcasters will now have the option of either uploading the documents to their online public inspection files or maintaining a current list of the documents in their online files and providing copies of the documents upon request. Documents will need to be uploaded, or lists updated, within 30 days of document execution.

Broadcasters will no longer be required to file paper copies of:

• network affiliation agreements
• articles of incorporation
• bylaws or other documents relating to ownership or control of the licensee
• contracts that relate to management of a station by someone other than a regular employee, officer or director of the station
• time brokerage agreements
• joint sales agreements

The change will take effect upon announcement in the Federal Register. Until then, broadcasters should continue to file paper copies as before.

If you have any questions regarding your document filing obligations, please contact any attorney in our office.