2004 Form 396-C
As you are aware, the 2004 FCC EEO Form 396-C is due September 30, 2004. This form is filed annually by cable operators and multi-channel video providers (“MVPDs”) as a means for measuring compliance with the FCC’s EEO regulations. Cable operators filed this form last year using the Commission’s CDBS system. The CDBS system will be used again this year to file the 2004 Form 396-C. The CDBS system is located on the web at: http://svartifoss2.fcc.gov/prod/cdbs/forms/prod/cdbs_ef.htm.
Late last week the Commission activated the cable EEO employment unit numbers that will receive a Supplemental Investigation Sheet or “SIS” in the CDBS system. The Commission randomly picks these unit numbers, selecting one out of every five cable EEO employment units for a SIS every year. The 2004 SIS will ask for the operator’s job description of its sales workers. In addition, the SIS will ask questions 2, 4, and 6 which address the operator’s dissemination of its EEO program to job applicants, employees, and those with whom it regularly does business, the operator’s promotion policy, and the operator’s findings in its self-analysis of its EEO program. The operator’s 2004 EEO public file report should be attached as a response to the SIS questions as well. Today, the Commission will be releasing by Public Notice the list of cable employment unit numbers which were selected for a SIS.
If your employment unit number is on the list of units selected in 2004 for a SIS and you filed your 2004 396-C before September 1, 2004, you must file an amendment to your Form 396-C and attach the answers to the SIS questions. In the Form 396-C pre-form, select “amendment to program report” radio button and on the first page of the Form 396-C, manually click on the SIS button and provide answers to the SIS questions.
If you started filling out your 2004 396-C before last week but have not officially filed it with the Commission, and you were selected for a SIS, manually select the SIS button on the first page of the Form 396-C report and attach your answers to the SIS questions.
If you are just beginning to fill out your 2004 396-C, the CDBS system will notify you on the first page of the Form 396-C that you are required to fill out a SIS.
Please contact us if you have any additional questions regarding this year’s Form 396-C filing and the associated SISs. We are available to review any SIS answers you have crafted and can draft responses for you if you would like such assistance.