Broadcast Deadlines:

January 31, 2020

Biennial Ownership ReportsAll licensees and entities holding an attributable interest in a licensee of one or more AM, FM, TV, Class A television, and/or Low Power TV (LPTV) stations must file a biennial ownership report reflecting information as of October 1, 2019. Please recall that not only corporations and limited liability companies, but also sole proprietorships and partnerships composed entirely of natural persons (as opposed to a legal person, such as a corporation), are included in the licensees that must file reports. Please recall that noncommercial and commercial entities are required to file by the same date. Additionally, all persons holding an attributable interest in a commercial licensee must have acquired either an FCC Registration Number (FRN) or Restricted Use FRN.

February 1, 2020

License Renewal Pre-Filing Announcements – Radio stations licensed in Indiana, Kentucky, and Tennessee must begin broadcasts of their pre-filing announcements with regard to their applications for renewal of the license. These announcements must be continued on February 16, March 1, and March 16.

Radio Post-Filing Announcements – Radio stations licensed in Arkansas, Louisiana, and Mississippi that have filed license renewal applications must begin broadcasts of their post-filing announcements with regard to their license renewal applications on February 1. If the renewal application is not filed until the February 3 deadline, wait until then to begin the post-filing announcements. Either way, these announcements must continue on February 16, March 1, March 16, April 1, and April 16. Once complete, a certification of broadcast, with a copy of the announcement’s text, must be posted to the online public file within seven days.

February 3, 2020

License Renewal Applications Due – Applications for renewal of license for radio stations located in Arkansas, Louisiana, and Mississippi must be filed in the Commission’s License and Management System (LMS). These applications must be accompanied by Schedule 396, the Broadcast Equal Employment Opportunity (EEO) Program Report, also filed in LMS, regardless of the number of full-time employees.

EEO Public File Reports – All radio and television station employment units with five or more full-time employees and located in Arkansas, Kansas, Louisiana, Mississippi, Nebraska, New Jersey, New York, and Oklahoma must place EEO Public File Reports in their online public inspection files. For all stations with websites, the report must be posted there as well. Per announced FCC policy, the reporting period may end ten days before the report is due, and the reporting period for the next year will begin on the following day.

March 9, 2020

All-Digital AM Broadcasting – Comments are due in response to the Commission’s Notice of Proposed Rulemaking seeking input on a proposal to allow AM broadcasters to broadcast an all-digital signal using the HD Radio in-band on-channel (IBOC) mode known as MA3.

March 30, 2020

Children’s Television Programming Reports – For the first time, all commercial television and Class A television stations must file electronically annual children’s television programming reports with the Commission, although the first one will cover only the portion of the year which began with the effective date of the revised rules (September 16-December 31, 2019). These reports should be automatically included in the online public inspection file, but we would recommend checking, as the FCC bases its initial judgments of filing compliance on the contents and dates shown in the online public file.

Telecom Deadlines:

January 31, 2020

Lifeline Recertification (FCC Form 555) – All eligible telecommunications carriers must re-certify all subscribers every 12 months, except for subscribers in states where the National Verifier, state Lifeline administrator, or other state agency is responsible for annual re-certification of subscribers’ Lifeline eligibility. In 2018, the FCC changed Form 555 to make the filing due for all carriers on January 31 each year, rather than on a rolling 12-month basis for each carrier. Carriers should file the form using Universal Service Administration Company’s E-file system.

February 1, 2020

Numbering Resource Utilization Forecast (NRUF) (FCC Form 502) – Twice a year, service providers with numbers from the North American Numbering Plan Administrator (NANPA), a Pooling Administrator, or another telecommunications carrier must file a numbering resource utilization forecast. Subscriber toll-free numbers are not included in the report. Interconnected Voice over Internet Protocol (VoIP) providers are subject to the reporting requirement along with other service providers who receive NANPA numbers, such as wireless carriers, paging companies, incumbent local exchange carriers (ILECs), and competitive local exchange carriers (CLECs). The next biennial reporting deadline is February 1, 2020.

Quarterly Telecommunications Reporting Worksheet (FCC Form 499-Q) – FCC rules require telecommunications carriers and interconnected VoIP providers to file quarterly revenue statements reporting historical revenue for the prior quarter and projecting revenue for the next quarter. The projected revenue is used to calculate contributions to the Universal Service Fund (USF) for high cost, rural, insular and tribal areas as well as to support telecommunications services for schools, libraries, and rural health care providers. USF assessments are billed monthly.

February 14, 2020

Quarterly Percentage of Interstate Usage (PIU) Reporting and Certification – Prepaid calling card providers (PCCPs) must report the percentage of interstate use factors and associated call volumes to carriers that provide them with transport services.  Additionally, PCCPs must file traffic information and a certification signed by a company officer stating that the provider is in compliance with the FCC’s PIU and USF reporting requirements.

March 1, 2020

Annual Consumer Proprietary Network Information (CPNI) Certification – FCC rules require telecommunications carriers and interconnected VoIP providers to certify compliance with FCC CPNI regulations. See 47 C.F.R. § 64.2001 et seq. Thus, telecommunications carriers file an annual CPNI certification with the FCC, including: (1) an explanation of any actions they have taken against data brokers; (2) a summary of all customer complaints received in the previous calendar year concerning the unauthorized release of CPNI; and (3) a summary of all CPNI policies and procedures. The filing must be made with the Enforcement Bureau in EB Docket No. 06-36.

FCC Form 477 – This form is filed online biannually on March 1 and September 1. The Commission collects a variety of information about broadband deployment and wireless and wired telephone service on Form 477.  Broadly speaking, the following providers must fill Form 477: 1) facilities-based providers of broadband connections to end users, 2) providers of wired or fixed wireless local exchange telephone service, 3) providers of interconnected VoIP service; and 4) facilities-based providers of mobile telephony (mobile voice) services. If you have any questions about whether your company must file Form 477 or what information your company is required to submit in the filing, you should contact your telecommunications counsel.