Upcoming Cable/Video Provider Deadlines: Copyright Statements, Cable EEO Program

Cable TV and video providers should be preparing for two upcoming deadlines. First, semi-annual cable copyright statement of account forms and royalty payments are due to the Library of Congress by August 29. As well, all companies with six or more employees must file their Cable EEO Annual Reports by October 1.

Cable Copyright Statements of Account
The semi-annual cable copyright statement of account forms and royalty payments for the first half of calendar year 2018 are due to the Library of Congress Copyright Office by August 29. Semiannual gross receipts of $527,600 or more for the January 1-June 30 accounting period must be reported on the SA3 Long Form and require detailed reporting of distant signal carriage. If you have completed SA1-2 Short Form statements in the past and are approaching this threshold, you should review your channel lineup as the carriage of distant signals significantly affects your copyright royalty fee calculation. If you completed the SA3 Long Form in the past but have revised your channel lineup for broadcast stations, you should ensure that these revisions are reflected in the SA3 Long Form.

FCC Form 396-C Cable EEO Program Annual Report
The FCC’s Media Bureau has announced the October 1 deadline for video/cable TV providers to file FCC Form 396-C, Cable EEO Annual Report. It also has released the names of those cable operators selected to complete the Supplemental Investigation Sheet (SIS), which requires additional information.

If you have six or more full-time cable employees (those who spend at least 30 hours per week on cable operations), you must file the Form 396-C by the October 1 deadline. Filings must be made electronically at https://licensing.fcc.gov/cgi-bin/ws.exe/prod/cdbs/forms/prod/cdbsmenu.hts.

At the same time that the FCC Form 396-C is filed with the FCC, the EEO Public File Report must be posted on your company’s website and placed in your cable Public Inspection File. The EEO Public File Report is distinct from the Form 396-C and provides details of:

• Vacancies filled during the preceding year, identified by job title;
• Recruitment sources used to fill those vacancies;
• Recruitment source that referred the hiree;
• Total number of persons interviewed for each vacancy, by recruitment source; and
• Recruitment initiatives undertaken during the preceding year.

For cable operators with 1,000+ subscribers that maintain the required Online Public Inspection File, note that although the FCC Form 396-C reports are automatically imported from the FCC’s database, your EEO Public File Report is not and must be uploaded to your online file.

If you have fewer than six full-time cable employees and have in the past filed a Form 396-C to indicate you are under that threshold, no further filing is needed. If you have initiated cable service within the last year and have never filed this form, JSI recommends that you file the form once to establish that you have fewer than six full-time cable employees.

For assistance with either of these filings, contact Kim Waldvogel in JSI’s Maryland office at 301-459-7590.