Underwriting Compliance Guide: 5. Third-Party Fundraising
5. Third-Party Fundraising
Noncommercial stations can interrupt programming in order to raise money for the station or its licensee nonprofit organization. This is common on NPR and PBS stations as “pledge breaks” or telethons/radiothons. Donations received must directly benefit the station.
Noncommercial stations can also interrupt programming in order to raise money for other organizations with specific restrictions and reporting requirements. This is called Third-Party Fundraising (TPF). This also includes fundraising for organizations in the wake of a major disaster.
Noncommercial stations (both LPFM and full-power) are limited to one percent of their annual airtime to be devoted to third-party fundraising. Beneficiary organizations must hold a federal IRS 501(c)(3) status. Third-party fundraising can’t benefit non-profits that are only recognized by the state and are not listed as an IRS 501(c)(3) nor can it benefit fraternal organizations, labor unions, political action committees or political campaigns as those organizations are not IRS 501(c)(3).
Stations are required to keep reports of their third party fundraising activities. For full-service NCE stations, these reports are done quarterly (only in quarters with any third-party fundrasing that takes place) and those reports need to be uploaded to the Online Public Inspection File (OPIF) system. LPFM stations should keep their reports in their station records (LPFM stations using the Voluntary Public File system can also post them there). For LPFM stations, REC recommends that you keep those files for the entire term of the current license and for at least two years from the quarter that the activity took place.
DISCLAIMER: THIS MANUAL WAS NOT WRITTEN BY AN ATTORNEY AND THEREFORE SHOULD NOT BE CONSTRUED AS LEGAL ADVICE. REC NETWORKS IS NOT RESPONSIBLE FOR ANY CONSEQUENTIAL DAMAGES THAT MAY ARISE FROM THE USE OF THIS MANUAL. THIS GUIDE IS BASED ON 20 YEARS OF KNOWLEDGE OF THE NON-COMMERCIAL (INCLUDING LPFM) BROADCAST SERVICE.