Non-Commercial Educational Including LPFM

Underwriting Compliance Guide

Michelle Bradley, CBT

Revised August 4, 2024 (includes a major change in our position on live remotes.)

REC Networks
https://recnet.com
202 621-2355

Table of Contents

Click a link below to review that chapter:

1. Introduction
   
   1. About this Compliance Manual
   2. FCC Order #1
   3. Communications Act Section 399b
   4. A brief history of noncommercial radio in America
   5. Why is LPFM a noncommercial service
2. Underwriting Basics
   
   1. Underwriting vs. advertising
   2. Why would a business want to underwrite?
   3. Messages on behalf of not-for-profit entities
   4. Remuneration is more than just cash
3. Identification vs. Promotion
   
   1. Starting with a “business card”/avoid “menu” listing
   2. Calls to action
   3. Inducements, enticements, solution suggesting and seed planting
   4. Qualitative, quantitative & comparative statements; references to reputation, exclusivity or uniqueness
   5. Pricing, discounts and interest rates
   6. Endorsements
   7. Slogans
   8. Affinity/membership cards
   9. Don’t try to sound like NPR/PBS
   10. Old time radio commercials
4. Other prohibited acts
   
   1. Requests from political campaigns
   2. Payola and plugola
   3. Program-related products  NEW
   4. Certain types of businesses with restrictions on messages
   5. Smoke shops 
   6. Emergency Alert System (EAS) elements
   7. Sponsorship of station elements such as the studio 
5. Third-Party Fundraising
6. Station policy
   
   1. Longer is not better
   2. Live copy vs. prerecorded copy
   3. Other things to avoid
   4. Live remotes   MAJOR POSITION CHANGE
   5. Review and approval process
7. Consequences for underwriting violations