Non-Commercial Educational Including LPFM

Underwriting Compliance Guide

Michelle Bradley, CBT

Revised December 13, 2021

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

Table of Contents

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. Certain types of businesses with restrictions on messages
   4. Emergency Alert System (EAS) elements  NEW
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
   5. Review and approval process
7. Consequences for underwriting violations