Lest we be lulled into complacency by recent de-regulatory efforts at the FCC, the commission has recently issued the largest ever fine for underwriting violations. Additionally, several stations in eastern South Carolina were fined $10-12,000 per station for missing Quarterly Issues and Programs reports. For more about this and available CRA resources and services, Visit our Website.
Record Underwriting Fines
This is the latest occurrence of this type of enforcement action as you may recall that we wrote about a similar instance, here. The FCC, along with issuing public notice of these fines, has included both reminders of what is acceptable for a non-commercial station when recognizing for-profit underwriters and examples of underwriting acknowledgments which were deemed unacceptable. If you have not already seen the latest public notice it is available here.
If you are still unsure as to what you can and cannot air as a non-commercial station, CRA members may submit their underwriter acknowledgement copy for review. We will be more than happy to offer guidance and suggestions in this area as one of many benefits of CRA membership. Please contact us for more information.
Public File Violations: Cumulus Group Fined $10-12,000 PER STATION
The FCC today released notices of monetary forfeiture for 5 stations in South Carolina licensed to Cumulus. All of the stations were unable to produce Quarterly Issues & Programs reports for various quarters throughout the respective license periods. Cumulus representatives cited difficulties with computer software and a lack of consistency with personnel as the primary reasons for the lack of compliance. The commission, nonetheless, ruled that the violations were “willful,” defined as, “the conscious and deliberate commission or omission of [any] act, irrespective of any intent to violate the law.” (47 U.S.C. § 312(f)(1))
It is also worth noting at this point that on March 1, 2018, all public files must be converted to the FCC online format. With regards to the Quarterly I&Ps, you must first make sure you have uploaded EVERY QUARTER all the way back to the most recent license renewal. Then, it is important to note that future Quarterlies which are uploaded will be date-stamped. Those which are uploaded late, (after the 10th of the month following the end of the quarter), may be subject to fines.
The CRA makes available to its members Quarterly I&P templates which are to serve your station both as a quarterly reminder and as a convenient template which you may easily complete with your station’s programming information. If you are a full power station and you are not currently receiving these quarterly templates, please contact us and we’ll get you included in the future.
NOTE: LPFMs do not have a Public File requirement and are therefore completely exempt from the online conversion process.