NALs and Forfeiture Orders

While it has been awhile since our last “Penalty Box” article in this newsletter, that doesn’t mean that the FCC hasn’t been busy issuing notices of apparent liability and collecting monetary fines from broadcasters. Popular rule violations that make the FCC’s credit card chip reader work (or cash register ring) have been running the full gamut, including failure to file children’s television reports on time, failing to place items in the public file on time, failure to operate within licensed parameters, and incorrectly certifying to compliance in applications filed with the FCC. Fines vary based on the FCC’s schedule, but recent ones have ranged from $3,000 to $10,000.

Fines always spike with renewal applications (when oversights are often discovered), and now that the FCC has completed its processing of the last round of renewal applications, some of the forfeiture actions should taper off. But in the interim, be watchful of certain easily observable items like presence at the main studio, tower lighting and fencing, and EAS operation.

We don’t wish to relentlessly beat the compliance drum (ok, yes we do), but the best way to ensure ongoing compliance and avoid a scare at license renewal time is to use two-person control for each FCC or public inspection filing. That way, if someone is out sick on a deadline day, their backup is able to cover the required filing.