Legal Calendar

2017 Broadcast Legal Calendar
Important Dates Arkansas Broadcasters Need To Know*

January 1 
Closed Captioning of Internet Video Clips—Beginning on this date, Internet video clips that contain montages or compilations made from clips of video content must be captioned if the associated programming was shown on television in the United States with captions.

January 10 
Quarterly Issues/Programs List Required—All full-power radio, full-power television, and Class A television stations must place in their public inspection files by this date the Quarterly Issues/Programs List covering the period October 1, 2016 through December 31, 2016.
Certification of Children's Commercial Time Limitations Required—Commercial full-power and Class A television stations must place in their public inspection files by this date records "sufficient to verify compliance" with the FCC's commercial time limitations in children's programming broadcast during the period October 1, 2016 through December 31, 2016.
FCC Form 398 Children's Programming Report Due—Commercial full-power and Class A television stations must by this date electronically file FCC Form 398 demonstrating their responsiveness to "the educational and informational needs of children" for the period October 1, 2016 through December 31, 2016, and ensure a copy of the form as filed with the FCC is in the station's public inspection file. 
Class A Television Continuing Eligibility Certification—Class A television stations are required to maintain documentation in their public inspection files sufficient to demonstrate continuing compliance with the FCC's Class A eligibility requirements. We recommend that by this date Class A television stations generate such documentation for the period October 1, 2016 through December 31, 2016 and place it in their public inspection files.

January 14
Copyright Royalty Fee: Monthly Report of Use and Monthly Usage Statement of Account Forms Due—Commercial and noncommercial webcasters and online simulcasters must file Monthly Report of Use and Monthly Usage Statement of Account forms with SoundExchange for the month ending November 30, 2016.

January 31
Copyright Royalty Fee: Annual Minimum Fee Statement of Account Form Due—By this date, most commercial and noncommercial webcasters and those simulcasting radio programming over the Internet must submit the Minimum Fee Statement of Account Form and the annual copyright royalty fee to SoundExchange. January 31 is also the date by which certain webcasters and simulcasters are eligible to make elections affecting their royalty rates and reporting requirements for the upcoming year. If your radio broadcast station is simulcast or rebroadcast over the Internet, we encourage you to consult qualified counsel with regard to your obligations.

February 1
Annual EEO Public File Report Required—Station Employment Units that have five or more fulltime employees and are comprised of radio and/or television stations licensed to communities in Arkansas, Kansas, Louisiana, Mississippi, Nebraska, New Jersey, New York, or Oklahoma must by this date place in their public inspection files and post on their station websites a report regarding station compliance with the FCC's EEO Rule during the period February 1, 2016 through January 31, 2017. A more detailed review of station EEO obligations and the steps for implementing an effective EEO program can be found in our most recent EEO Advisory.
FCC Form 397 Mid-Term EEO Report Due—Radio Station Employment Units that have eleven or more full-time employees and are comprised of radio stations licensed to communities in Kansas, Nebraska, or Oklahoma and Television Station Employment Units that have five or more full-time employees and are comprised of television stations licensed to communities in Arkansas, Louisiana, or Mississippi must by this date electronically file with the FCC and place in their public inspection files the Mid-Term EEO Report on FCC Form 397. The Station Employment Unit’s last two EEO Public File Reports must be submitted with the Form 397. A more detailed review of station EEO obligations and the steps for implementing an effective EEO program can be found in our most recent EEO Advisory.

February 14
Copyright Royalty Fee: Monthly Report of Use and Monthly Usage Statement of Account Forms Due—Commercial and noncommercial webcasters and those simulcasting radio programming over the Internet must by this date submit the Monthly Report of Use and Monthly Usage Statement of Account forms to SoundExchange for the month ending December 31, 2016.

March 17
Copyright Royalty Fee: Monthly Report of Use and Monthly Usage Statement of Account Forms Due—Commercial and noncommercial webcasters and those simulcasting radio programming over the Internet must by this date submit the Monthly Report of Use and Monthly Usage Statement of Account forms to SoundExchange for the month ending January 31, 2017.

April 1
Annual EEO Public File Report Required—Station Employment Units that have five or more fulltime employees and are comprised of radio and/or television stations licensed to communities in Delaware, Indiana, Kentucky, Pennsylvania, Tennessee, or Texas must by this date place in their public inspection files and post on their station websites a report regarding station compliance with the FCC's EEO Rule during the period April 1, 2016 through March 31, 2017. A more detailed review of station EEO obligations and the steps for implementing an effective EEO program can be found in our most recent EEO Advisory.
FCC Form 397 Mid-Term EEO Report Due—Radio Station Employment Units that have eleven or more full-time employees and are comprised of radio stations licensed to communities in Texas and Television Station Employment Units that have five or more full-time employees and are comprised of television stations licensed to communities in Kentucky, Indiana, or Tennessee must by this date electronically file with the FCC and place in their public inspection files the Mid-Term EEO Report on FCC Form 397. The Station Employment Unit’s last two EEO Public File Reports must be submitted with the Form 397. A more detailed review of station EEO obligations and the steps for implementing an effective EEO program can be found in our most recent EEO Advisory. Note that because this filing deadline falls on a weekend, the submission of this item to the FCC may be made on April 3.

April 10
Quarterly Issues/Programs List Required—All full-power radio, full-power television, and Class A television stations must place in their public inspection files by this date the Quarterly Issues/Programs List covering the period January 1, 2017 through March 31, 2017.
Certification of Children's Commercial Time Limitations Required—Commercial full-power and Class A television stations must place in their public inspection files by this date records "sufficient to verify compliance" with the FCC's commercial time limitations in children's programming broadcast during the period January 1, 2017 through March 31, 2017.
FCC Form 398 Children's Programming Report Due—Commercial full-power and Class A television stations must by this date electronically file FCC Form 398 demonstrating their responsiveness to "the educational and informational needs of children" for the period January 1, 2017 through March 31, 2017, and ensure a copy of the form as filed with the FCC is in the station's public inspection file.
Class A Television Continuing Eligibility Certification—Class A television stations are required to maintain documentation in their public inspection files sufficient to demonstrate continuing compliance with the FCC's Class A eligibility requirements. We recommend that by this date Class A television stations generate such documentation for the period January 1, 2017 through March 31, 2017 and place it in their public inspection files.

April 14
Copyright Royalty Fee: Monthly Report of Use and Monthly Usage Statement of Account Forms Due—Commercial and noncommercial webcasters and those simulcasting radio programming over the Internet must by this date submit the Monthly Report of Use and Monthly Usage Statement of Account forms to SoundExchange for the month ending February 28, 2017.

May 15
Copyright Royalty Fee: Monthly Report of Use and Monthly Usage Statement of Account Forms Due—Commercial and noncommercial webcasters and those simulcasting radio programming over the Internet must submit by this date the Monthly Report of Use and Monthly Usage Statement of Account forms to SoundExchange for the month ending March 31, 2017.

June 1
Annual EEO Public File Report Required—Station Employment Units that have five or more fulltime employees and are comprised of radio and/or television stations licensed to communities in Arizona, the District of Columbia, Idaho, Maryland, Michigan, Nevada, New Mexico, Ohio, Utah, Virginia, West Virginia or Wyoming must by this date place in their public inspection files and post on their station websites a report regarding station compliance with the FCC's EEO Rule during the period June 1, 2016 through May 31, 2017. A more detailed review of station EEO obligations and the steps for implementing an effective EEO program can be found in our most recent EEO Advisory.
FCC Form 397 Mid-Term EEO Report Due—Radio Station Employment Units that have eleven or more full-time employees and are comprised of radio stations licensed to communities in Arizona, Idaho, Nevada, New Mexico, Utah, or Wyoming and Television Station Employment Units that have five or more full-time employees and are comprised of television stations licensed to communities in Michigan or Ohio must by this date electronically file with the FCC and place in their public inspection files the Mid-Term EEO Report on FCC Form 397. The Station Employment Unit’s last two EEO Public File Reports must be submitted with the Form 397. A more detailed review of station EEO obligations and the steps for implementing an effective EEO program can be found in our most recent EEO Advisory.

June 14
Copyright Royalty Fee: Monthly Report of Use and Monthly Usage Statement of Account Forms Due—Commercial and noncommercial webcasters and those simulcasting radio programming over the Internet must by this date submit to SoundExchange the Monthly Report of Use and Monthly Usage Statement of Account forms for the month ending April 30, 2017.

July 1
Closed Captioning of Live and Near-Live Programs on the Internet—Beginning on this date, live programs that are placed online must be captioned within 12 hours of airing on television. In addition, all near-live programs (i.e., programs recorded less than 24 hours before being aired for the first time) that are placed online must be captioned within 8 hours of airing on television.

July 10
Quarterly Issues/Programs List Required—All full-power radio, full-power television, and Class A television stations must place in their public inspection files by this date the Quarterly Issues/Programs List covering the period April 1, 2017 through June 30, 2017.
Certification of Children's Commercial Time Limitations Required—Commercial full-power and Class A television stations must place in their public inspection files by this date records "sufficient to verify compliance" with the FCC's commercial time limitations in children's programming broadcast during the period April 1, 2017 through June 30, 2017.
FCC Form 398 Children's Programming Report Due—Commercial full-power and Class A television stations must by this date electronically file FCC Form 398, demonstrating their responsiveness to "the educational and informational needs of children" for the period April 1, 2017 through June 30, 2017, and ensure a copy of the form as filed with the FCC is in the station's public inspection file.
Class A Television Continuing Eligibility Certification—Class A television stations are required to maintain documentation in their public inspection files sufficient to demonstrate continuing compliance with the FCC's Class A eligibility requirements. We recommend that by this date Class A television stations generate such documentation for the period April 1, 2017 through June 30, 2017 and place it in their public inspection files.
 

July 15
Copyright Royalty Fee: Monthly Report of Use and Monthly Usage Statement of Account Forms Due—Commercial and noncommercial webcasters and those simulcasting radio programming over the Internet must by this date submit the Monthly Report of Use and Monthly Usage Statement of Account forms to SoundExchange for the month ending May 31, 2017.

July 31
Copyright Royalty Claims Due—Television stations with locally-produced programming whose signals were carried as distant signals by at least one cable or satellite system in 2016 are eligible to file royalty claims for compensation with the Copyright Office in Washington, DC by this date. Under the federal Copyright Act, cable systems and satellite operators must pay "compulsory license" royalties to carry distant TV signals on their systems. The royalties are used to compensate the owners of copyrighted works broadcast on those signals. Stations that do not file claims by the deadline will not be able to collect royalties for carriage of their signals during 2016.

August
Regulatory Fees Announced—The FCC is expected to release a Public Notice this month indicating the date by which annual regulatory fees must be filed with the FCC and the amounts of those fees. Broadcasters should remain alert for this announcement.

August 1
Annual EEO Public File Report Required—Station Employment Units that have five or more fulltime employees and are comprised of radio and/or television stations licensed to communities in California, Illinois, North Carolina, South Carolina, or Wisconsin must by this date place in their public inspection files and post on their station websites a report regarding station compliance with the FCC's EEO Rule during the period August 1, 2016 through July 31, 2017. A more detailed review of station EEO obligations and the steps for implementing an effective EEO program can be found in our most recent EEO Advisory.
FCC Form 397 Mid-Term EEO Report Due—Radio Station Employment Units that have eleven or more full-time employees and are comprised of radio stations licensed to communities in California and Television Station Employment Units that have five or more full-time employees and are comprised of television stations licensed to communities in Illinois or Wisconsin must by this date electronically file with the FCC and place in their public inspection files the Mid-Term EEO Report on FCC Form 397. The Station Employment Unit’s last two EEO Public File Reports must be submitted with the Form 397. A more detailed review of station EEO obligations and the steps for implementing an effective EEO program can be found in our most recent EEO Advisory.

August 14
Copyright Royalty Fee: Monthly Report of Use and Monthly Usage Statement of Account Forms Due—Commercial and noncommercial webcasters and those simulcasting radio programming over the Internet must by this date submit the Monthly Report of Use and Monthly Usage Statement of Account forms to SoundExchange for the month ending June 30, 2017.

September 14
Copyright Royalty Fee: Monthly Report of Use and Monthly Usage Statement of Account Forms Due—Commercial and noncommercial webcasters and those simulcasting radio programming over the Internet must by this date submit the Monthly Report of Use and Monthly Usage Statement of Account forms to SoundExchange for the month ending July 31, 2017.

September 30
EEO 1 Report Due—Broadcasters that are subject to the federal Equal Employment Opportunity Commission's (EEOC) reporting requirements must file their EEO 1 Report (Form 100) by this date. We encourage you to consult with counsel on the filing and visit http://www.eeoc.gov/employers/eeo1survey/.

October 1
Annual EEO Public File Report Required—Station Employment Units that have five or more fulltime employees and are comprised of radio and/or television stations licensed to communities in Alaska, Florida, Hawaii, Iowa, Missouri, Oregon, Washington, American Samoa, Guam, the Mariana Islands, Puerto Rico, Saipan, or the Virgin Islands must by this date place in their public inspection files and post on their station websites a report regarding station compliance with the FCC's EEO Rule during the period October 1, 2016 through September 30, 2017. A more detailed review of station EEO obligations and the steps for implementing an effective EEO program can be found in our most recent EEO Advisory.
FCC Form 397 Mid-Term EEO Report Due—Radio Station Employment Units that have eleven or more full-time employees and are comprised of radio stations licensed to communities in Alaska, Hawaii, Oregon, Washington, American Samoa, Guam, the Mariana Islands, or Saipan and Television Station Employment Units that have five or more full-time employees and are comprised of television stations licensed to communities in Iowa or Missouri must by this date electronically file with the FCC and place in their public inspection files the Mid-Term EEO Report on FCC Form 397. The Station Employment Unit’s last two EEO Public File Reports must be submitted with the Form 397. A more detailed review of station EEO obligations and the steps for implementing an effective EEO program can be found in our most recent EEO Advisory. Note that because this filing deadline falls on a weekend, the submission of this item to the FCC may be made on October 2.

October 10
Quarterly Issues/Programs List Required—All full-power radio, full-power television, and Class A television stations must place in their public inspection files by this date the Quarterly Issues/Programs List covering the period July 1, 2017 through September 30, 2017.
Certification of Children's Commercial Time Limitations Required—Commercial full-power and Class A television stations must place in their public inspection files by this date records "sufficient to verify compliance" with the FCC's commercial time limitations in children's programming broadcast during the period July 1, 2017 through September 30, 2017.
FCC Form 398 Children's Programming Report Due—Commercial full-power and Class A television stations must by this date electronically file FCC Form 398, demonstrating their responsiveness to "the educational and informational needs of children" for the period July 1, 2017 through September 30, 2017, and ensure a copy of the form as filed with the FCC is in the station's public inspection file.
Class A Television Continuing Eligibility Certification—Class A television stations are required to maintain documentation in their public inspection files sufficient to demonstrate continuing compliance with the FCC's Class A eligibility requirements. We recommend that by this date Class A television stations generate such documentation for the period July 1, 2017 through September 30, 2017 and place it in their public inspection files.

October 15
Copyright Royalty Fee: Monthly Report of Use and Monthly Usage Statement of Account Forms Due—Commercial and noncommercial webcasters and those simulcasting radio programming over the Internet must by this date submit the Monthly Report of Use and Monthly Usage Statement of Account forms to SoundExchange for the month ending August 31, 2017.

November 3
EAS Foreign Language Reporting Requirement—By this date, Emergency Alert System (“EAS”) Participants must prepare and submit to their respective State Emergency Communications Committees a description of their efforts and activities to make available EAS alert message content to persons who communicate in languages other than English.


November 14

Copyright Royalty Fee: Monthly Report of Use and Monthly Usage Statement of Account Forms Due—Commercial and noncommercial webcasters and those simulcasting radio programming over the Internet must by this date submit the Monthly Report of Use and Monthly Usage Statement of Account forms to SoundExchange for the month ending September 30, 2017.

December 1
FCC Form 323 Biennial Ownership Report Due—All commercial radio, television, low power television, and Class A television stations must electronically file by this date their biennial ownership reports on FCC Form 323 and pay the required FCC filing fee. FCC Form 323 as filed must be placed in stations' public inspection files. Note that the FCC has adopted changes to the commercial ownership report form, which, as of the date of this publication, have not yet gone into effect. Upon publication of OMB approval of the new form in the Federal Register, FCC Form 323 will be superseded by FCC Form 2100, Schedule 323.
FCC Form 2100, Schedule 323-E Biennial Ownership Report Due—All noncommercial radio and television stations must electronically file by this date their biennial ownership reports on FCC Form 2100, Schedule 323-E. FCC Form 2100, Schedule 323-E does not require a filing fee. The form as filed must be placed in stations' public inspection files. Note that this unified national deadline for noncommercial biennial ownership reports permanently replaces the prior state-by-state deadlines.
Annual EEO Public File Report Required—Station Employment Units that have five or more fulltime employees and are comprised of radio and/or television stations licensed to communities in Alabama, Colorado, Connecticut, Georgia, Maine, Massachusetts, Minnesota, Montana, New Hampshire, North Dakota, Rhode Island, South Dakota, or Vermont must by this date place in their public inspection files and post on their station websites a report regarding station compliance with the FCC's EEO Rule during the period December 1, 2016 through November 30, 2017. A more detailed review of station EEO obligations and the steps for implementing an effective EEO program can be found in our most recent EEO Advisory.
FCC Form 397 Mid-Term EEO Report Due—Radio Station Employment Units that have eleven or more full-time employees and are comprised of radio stations licensed to communities in Connecticut, Maine, Massachusetts, New Hampshire, Rhode Island or Vermont and Television Station Employment Units that have five or more full-time employees and are comprised of television stations licensed to communities in Colorado, Minnesota, Montana, North Dakota, or South Dakota must by this date electronically file with the FCC and place in their public inspection files the Mid-Term EEO Report on FCC Form 397. The Station Employment Unit’s last two EEO Public File Reports must be submitted with the Form 397. A more detailed review of station EEO obligations and the steps for implementing an effective EEO program can be found in our most recent EEO Advisory.
FCC Form 2100, Schedule G, Annual DTV Ancillary/Supplementary Services Report Due (formerly FCC Form 317)—Commercial television, digital Class A television, and digital LPTV stations must by this date electronically file FCC Form 2100, Schedule G, the Annual DTV Ancillary/Supplementary Services Report for Commercial Digital Television Stations, with the FCC whether or not they have received any income from transmitting ancillary or supplementary services. If a digital station provided ancillary or supplementary services during the 12-month time period ending on the preceding September 30, and received compensation for doing so, the station is required to pay to the FCC five percent of the gross revenue from such services concurrently with the filing of Form 2100, Schedule G.

December 15
Copyright Royalty Fee: Monthly Report of Use and Monthly Usage Statement of Account Forms Due—Commercial and noncommercial webcasters and those simulcasting radio programming over the Internet must by this date submit the Monthly Report of Use and Monthly Usage Statement of Account forms to SoundExchange for the month ending October 31, 2017.

* This calendar is intended to be a general source of information on issues of interest to Arkansas Broadcasters. For information on specific circumstances you should seek advice from your attorney. Always double-check specific filing dates and requirements.