Legal Bulletins


The OAB, through its FCC and Ohio counsel, provides updates on current issues and regulatory changes that impact broadcasters.


Commission Announces Second Round of 2022 EEO Audits; Responses Due by October 7, 2022

Approximately 128 radio stations, 19 TV stations, and their corresponding employment units will be part of the FCC’s second batch of EEO (“equal employment opportunity”) audits of 2022, according to a recent Public Notice (the “Notice”).  The Commission has already begun mailing audit letters to the selected stations; those stations must upload their audit responses by October 7, 2022 to their online public inspection files (“OPIF”).

Per the Commission’s EEO rules, each year approximately five percent of all radio and television stations are randomly selected for EEO audits.  Although audit letters are issued to individual stations, it’s important to note that an EEO audit applies to any and all stations in the identified station’s “employment unit.”  Generally, any commonly owned stations in the same market that share at least one common employee are part of the same employment unit for FCC EEO reporting and audit purposes.

The form EEO audit letter describes, among other things, the specific data requested by the Commission, procedures for responding, and special circumstances for time-brokered stations, as well as limited exceptions pursuant to which broadcasters may be relieved of the requirement to submit a full audit response.  The data requested in the audit letter is extensive, and stations identified in the audit will need to act promptly to respond.  As with any government audit, consultation with counsel is advisable.

Legal bulletin provided by Brooks, Pierce, McLendon, Humphrey & Leonard, LLP.


This Legal Update should in no way be construed as legal advice or a legal opinion on any specific set of facts or circumstances. Therefore, you should consult with legal counsel concerning any specific set of facts or circumstances. The information provided through this update does not constitute legal advice from the OAB or its legal counsel and does not establish an attorney-client relationship between any member and OAB legal counsel.