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Underwriting

Last Updated on July 23, 2008 by Will R

Most FCC licensed student radio stations are noncommercial radio stations, but what does that mean?

The FCC says in its regulations, “No promotional announcement on behalf of for profit entities shall be broadcast at any time in exchange for the receipt, in whole or in part, of consideration to the licensee, its principals, or employees. However, acknowledgements of contributions can be made. The scheduling of any announcements and acknowledgements may not interrupt regular programming.” (http://www.hallikainen.com/FccRules/2014/73/503/)

The simple answer is that your station, if licensed by the FCC as noncommercial MAY NOT air commercials.  But what constitutes a commercial vs a sponsorship or the acknowledgement of an underwriter over the air?  What can  you say and what can’t you say?

In short, you may not promote a for-profit business or its products or services, you may not provide a call to action, you may not provide price information.  For example, “For the absolute best service from the best auto mechanics in the county” would be promotional.  “Call XYZ automotive today today” would be a call to action.  “XYZ auto will give you an oil change for only $19.95” would include price information.  All of these examples would violate the FCC rules.  Further “free” is also a violation of the price rules.

Menus of what the supporters offer.  For instance, if a sponsor wanted to say we offer penzoil, quaker state, syz, ccc, sss, and qqq oil, the FCC could find that be to a violation.  “We find that these excessively detailed menus of multiple product/service offerings by underwriters exceed the type of information that would enable listeners to identify supporters of noncommercial programming and are similar to promotional broadcasts that have resulted in monetary forfeitures.”

Comparative statements.  “we are the number one car dealer in the county”.  Comparative and not allowed.

For additional guidance, see http://www.fcc.gov/encyclopedia/noncommercial-nature-educational-broadcasting.

This page is provided as general information and not as legal guidance.  Consult your broadcast attorney for details.

Again, what you may not do in a nutshell:

  • calls to action
  • price info
  • comparative/promotional language

Five Underwriting Controversies