Mid-term FCC EEO Reports on Form 397 will be due on December 1, 2016 for Minnesota radio stations with more than ten full-time employees and licensed to communities that are outside smaller markets. The Report covers full-time recruitment activities for the previous two years.
Under the smaller marketing exemption, a station is exempt from filing the mid-term report if it is licensed to a metropolitan area with a population of fewer than 250,000 persons or areas outside of all metropolitan areas as defined by the Office of Management and Budget.
Remember that EEO Reports are filed for Employment Units. An Employment Unit is comprised of commonly owned stations in the same market that share even a single employee, and includes time brokered stations.
The FCC Form 397 is a relatively simple report to complete, but requires that the local public file EEO report for each of the previous two years be included. Accordingly, reporting stations will have to attach in PDF format a copy of their local public file EEO reports for 2015-2016 and for 2014-2015. The mid-term report is required to be filed by radio stations with more than ten full-time employees. With fewer employees, a mid-term report is not required.