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Children’s Television Programming Reports Have A New Home

On February 9, 2016, the FCC announced that Children’s Television Programming Reports (FCC Form 398) will need to be filed on the Licensing and Management System (LMS), commencing with the First Quarter 2016 reports due in April 2016.

Licensees of commercial full-power and Class A television stations have been filing quarterly Children’s Television Programming reports since the 1990s, utilizing an antiquated filing system that is separate from the FCC’s CDBS system. Because of the system’s age, many licensees ran into difficulties submitting their reports within 10 days after the close of each quarter (e.g., April 10th), especially on the last day when many users were logged in at the same time.

The LMS platform has now been in use since October 2014, first with just full-power television stations, and then for Class A, LPTV and TV translator stations in February 2015. Ultimately, LMS will be used for all broadcast services including radio.

While the submission of the form through LMS is intended to automatically create a link within the station’s online public file, the FCC reminded licensees to double-check that the form has been linked to station’s public file folder. If the link to the report does not appear in the station’s online public file, then the licensee is obligated to upload a copy, or else face possible enforcement action.

© 2020 Faegre Drinker Biddle & Reath LLP. All Rights Reserved.National Law Review, Volume VI, Number 64


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