REMINDER: The quarterly listing of issue-responsive programming broadcast between January 1, 2020 and March 31, 2020 must be uploaded to radio station online public inspection files by April 10, 2020.
However, the FCC’s Media Bureau will grant waivers of the report filing deadline to stations that are experiencing staffing shortages or other hardships due to the coronavirus, including those caused by employee illnesses and government-imposed shutdowns and quarantines. If your station is short-staffed due to the coronavirus or is experiencing other coronavirus-related hardships, and you think you will have difficulty meeting the upcoming deadline, you should ask the FCC for a waiver.
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.
If you have any questions about these ongoing recordkeeping obligations, please contact any attorney in our office.