From our "Gee, haven’t we heard this before somewhere?" file
If you happened to read our post from a month ago, you already know that the effective date for the new attribution rules relative to TV joint sales arrangements is June 19, 2014. The Media Bureau has now confirmed that in a public notice.
The Bureau’s notice sheds no new light on anything. Au contraire, it confirms our previous observations that: (a) the new filing requirements relative to the TV JSA rules are not yet effective (thanks to the need for OMB review mandated by the Paperwork Reduction Act) and (b) the two-year compliance period wraps up on June 19, 2016. On that last point, the public notice doesn’t say anything about the fact that, at least according to our official CommLawBlog calendar, June 19, 2016 is expected to be a Sunday.
Of course, as of their effective date, the new rules apply to new JSA’s — that is, the two-year compliance period relates only to JSA’s already in existence prior to the effective date.
So no real news here, but now we do have official confirmation.