Contributors: Brad C. Deutsch, Principal, Foster Garvey, P.C. and Benjamin J. Lambiotte, Principal, Foster Garvey, P.C.
Just as the 2020 federal election campaign shifts into high gear, on October 16, 2019, the Federal Communications Commission issued two significant orders “clarifying” broadcasters’ political public file obligations in response to complaints filed against several stations. In both orders, the Commission made it very clear that it is station licensees – and not political ad sponsors or their ad buyers – who are responsible for ascertaining, collecting, and uploading in a timely manner to the FCC online political public file, all the information required by Section 315(e) of the Communications Act and the FCC’s political broadcasting rules.