As a follow-up to our posting on September 17, 2015, and in response to questions we have received from several of our readers, I wanted to clarify that the Federal Communication Commission’s (FCC) revision to its contest rules did not go into effect immediately after its September 17 meeting.
In fact, the revised rules must first be reviewed by the Office of Management and Budget (OMB). OMB is the agency that approves the changed rules and it will determine when they will go into effect. OMB’s approval and the effective date it sets will be announced in the Federal Register.
We called the FCC to confirm this procedure. The FCC anticipates the process will probably take between four to six months from the Commission’s September meeting.
Dale Joerling is the chair of Thompson Coburn’s Advertising, Marketing and Promotion Law group. He is editorial director of the Sweepstakes Law Blog. You can find Dale on Google+ and Twitter, and reach him at (314) 552-6058 or email@example.com.