How to Upload Your Public Inspection Files

How to Meet the New Public Inspection File Requirements

Friday is an important solar day for many U.S. radio stations; hither's what the legal beagles are advising clients about the procedure

Files, files, (smash) files …
Mark your calendar for Friday — OPIF is about hitting the spotlight.

Starting Fri, many U.S. broadcast radio stations will be required to begin using the Federal Communications Commission's new database known equally the Online Public Inspection File or OPIF.

If y'all are a commercial broadcast radio station in the height 50 Nielsen audio markets and have 5 or more total-time employees, using this arrangement becomes mandatory June 24 (also looking at you, SiriusXM, sure cable systems and DBS providers). On Friday, you need to log in via the FCC website and activate your files so the public tin admission the content online. You will have six months to place pre-existing public file documents there.

So rather than Friday beingness a borderline, think of it as the "start" date for your uploading responsibility, said John Garziglia, partner with legal house Womble Carlyle. But if a political buy arrives Friday at a big commercial radio station in a peak 50 market, it must exist uploaded to the online public file rather than the old concrete one.

A 2d wave of broadcasters has until March 2018. This includes all NCE radio broadcast stations; commercial radio broadcast stations in the peak fifty Nielsen Sound markets with fewer than v full-time employees; and all commercial radio circulate stations in markets below the superlative 50 or exterior all markets, as well every bit certain cable providers.

Guidance to radio stations has been coming from various constabulary firms.

The Comm Law Centre newsletter, published past the firm Pillsbury Winthrop, shared commonsense steps the FCC has taken simplify the transition — for case the FCC will automatically upload well-nigh applications to a station's online public inspection file as well as reports that are electronically filed with the FCC.

"However, stations should non exist conceited that the FCC is assuming responsibility for the public file being complete," writes Senior Quango Lauren Lynch Picture on the commlawcenter.com website. "Stations must still be knowledgeable almost which items actually belong in the public inspection file and for how long."Not all of those items that are required to be filed electronically with the commission must be kept specifically in the public file, and vice versa, she wrote. In addition, stations must know where in the file to upload required items.

The business firm as well published an advisory to assist commercial and noncommercial radio and television stations as they endeavour to comply with the changing public file rules. The informational discusses the public access, content, retention and organizational requirements of the regulations.

Garziglia's own house Womble Carlyle has been offering several tips:

• Ensure the FCC's online public file has correct contact information for your station representative.

• On June 24, stations should post a link on their own site that links up with the station's new FCC online public file.
• Other than political materials, the first absolute upload requirement for elevation 50 market stations will be July 10 for the Apr-June quarterly bug/programs lists.

• On Aug. i, stations in California, North and Southward Carolina, Illinois and Wisconsin will exist required to upload their Almanac EEO Public File Reports on their license renewal filing engagement anniversary, as well as post a link to those reports on the station's own website.

• For top 50 market stations, all existing local public file materials (other than pre-June 24political file materials) must be uploaded by December. 24, 2016 — "Merry Christmas Eve," adds Garziglia. Such existing local public file materials requiring upload would include issue/programs lists and annual EEO public file reports going dorsum to the last license renewal engagement, besides every bit other materials that exercise non now appear in the FCC'southward Consolidated Database System — awaiting paper-filed AM license applications, citizens agreements, time brokerage and joint sales agreements, materials relating to an FCC investigation or complaint, and NCE donor lists.

• In that location is no requirement to upload political file materials that date to prior to June 24;those must be kept in the current local public file. Too, for now, letters and emails from the public must be kept in the electric current local public file going forward.

• Materials uploaded to the FCC's online public file will be engagement- and time-stamped. It is critical, therefore, to "timely fix and upload" them — particularly for the quarterly issues/programs lists and annual EEO public file reports.

• Any radio station public file materials uploaded to the FCC's online beta/demo site prior to Friday will not exist transferred over to the actual new system; merely materials uploaded to the bodily FCC online public file at https://publicfiles.fcc.gov on or after June 24will be office of the radio station'southward online local public file.

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Source: https://www.radioworld.com/news-and-business/how-to-meet-the-new-public-inspection-file-requirements

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