Online TV Public Inspection Files: Tick, Tick, Tick . . .

The deadline for completion of the upload process is nearly here – are you ready?

TV licensees (that is, full-power and Class A licensees) – this is your final warning from us here at CommLawBlog. You’ve got until February 4 to get your public inspection file uploaded to the FCC’s online system. That’s only two weeks from now, so if you haven’t gotten started on this yet, now would be a good time.

We have previously provided a number of tips on this topic: how to access the system; once you’re in, how to upload the required materials; what documents have to be uploaded. If you missed those posts, click here and here to get started.

We’re not going to re-visit the myriad details of the new rules, their genesis, their implementation, etc., etc. Been there, done that.

We do, though, want to offer a cautionary reminder.

We haven’t canvassed the status of everybody’s public files. It’s possible – maybe not likely, but possible – that everyone has already done everything that they need to do, and our warning here is a churlish and unnecessary bit of hectoring. If you, dear reader, have uploaded your public file already, congratulations, and please accept our apologies for suggesting otherwise. But for everybody else, we do want to underscore one consideration that should motivate any folks who have been dragging their feet. 

The FCC’s online public file system is, ahem, an ONLINE public file system. Because of that, anybody anywhere anytime is in a position, unbeknownst to you, to check the status of your file. Once the deadline for completing the upload process arrives – that would be on February 4 – any shortcomings will be rule violations for which the Commission could issue fines. And anybody, anywhere, anytime will be in a position to identify such violations and bring them to the FCC’s attention.  Even if the Commission opts not to start handing out fines immediately (and while the Commission may indeed restrain itself, particularly in the initial phase, such self-restraint is not mandatory), it’s hard to imagine a greater incentive to get your file in order by February 4.

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