by Matthew Lasar
May 31, 2013
I spent the morning at the National Federation of Community Broadcasters conference here in San Francisco. First stop: a panel on the dos-and-don’ts of underwriting acknowledgements. Expert attorney Michael Berg spoke on the subject, and offered a very nice advisory handout on slogans and logos, from which I draw the following wisdom.
Bottom line: the Federal Communications Commission’s rules on underwriting announcements seek to protect the noncommercial quality of noncommercial educational (NCE) broadcasting. Thus such spots can “identify” and “describe” the underwriter and its products, but they can’t “promote” them. The FCC expects NCE stations to make “good faith judgements” in these regards.
So legal details include the donor’s name, contact information, brands and names of its products and services, and “historical information about the donor’s operations (such as how long they’ve been in business).” But data about pricing, “calls to action,” “inducements to buy,” or language comparing the donor’s products to the rest of the market is out of bounds.