IBrakeForTrees
Unfortunately, the FCC does not address the ability of any FCC regulated device to require moving the closed-captioning/subtitle location.
Only requirements are...
- Equipment covered by FCC rules must enable consumers to adjust closed captions in a variety of ways. Under these requirements, consumers must be able to adjust the font, size, color (both text and background color), opacity, and edge attributes of their closed captions.
https://www.fcc.gov/consumers/guides/closed-captioning-display-requirements-equipment
The above are all addressed in the Roku Accessibility settings.
The best you can do is to keep trying to adjust the opacity, background, and colors, a bit. However, sometimes subtitles and closed-captioning are treated similarly so hard to just adjust just one setting as it may affect both layouts.
You can use some subtitle editors when making your own subtitles for content (or importing subtitles) that allows you to change the location to top or bottom. However, pretty tough to watch when they are at top. Does come in handy though in situations like you described. (needing both closed captioning and subtitles at same time).
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I did see what you are talking about in this show. The subtitles (when enabled) are using the formatting specified in Roku settings. When subtitles are disabled, the embedded format is white. (of course, when disabled, no English subtitles/closed captioning is present). The problem you are experiencing is because you are attempting to view closed captioning over an embedded (burnt-in) subtitle. Really is going to be a matter of adjusting the settings until you get something "bearable" in these situations.