A recent fine imposed by the Federal Communications Commission
(FCC) underscores how important it is for broadcasters to keep up
with their Equal Employment Opportunity (EEO) obligations.
On October 16, 2023, the FCC's Enforcement Bureau, which is
now home to its EEO division, issued a Notice of Apparent Liability
(NAL) for $25,000 against a small, family-owned broadcaster
operating two radio clusters in Kansas. Due to financial
difficulties, the broadcaster no longer has five full-time
employees and therefore is no longer subject to the EEO rules.
Nevertheless, the FCC cited issues with the broadcaster's 2020
and 2021 EEO Public File Reports (PFRs) to justify the fine.
Specifically, the NAL cited the broadcaster's failure to: (i)
timely upload their annual EEO Public File Reports to the
stations' online public inspection files (OPIFs); (ii) timely
upload their EEO Public File Reports to the stations' websites;
(iii) broadly recruit for certain vacancies; (iv)
