While there a reams of paper devoted to defining the FCC regulations surrounding underwriting on public radio. In short, · Stations are required to identify entities that provide consideration in exchange for some form of on-air acknowledgement.

• Stations are not allowed to air advertising.

• Stations are not required to identify those entities providing general station support.

The FCC defines advertising as:

• "any message or programming material which is broadcast or otherwise transmitted in exchange for any remuneration, and which is intended:

  • "to promote any service, facility, or product offered by any person who is engaged in such offering for profit;

  • "to express the views of any person with respect to any matter of public importance or interest; or

  • "to support or oppose any candidate for political office."
    

Stations are allowed to 'identify', not 'promote' commercial entities that provide general support for the station. This identification can include the following:

• The name of the person or entity

• Location information

• Telephone numbers and website addresses

• Audio logos or slogans that identify but do not promote

• Value-neutral descriptions of a product line or service

• Brand and trade names

• Product or service listings that do not include qualitative or comparative language

Important Note

The true identity of the organization providing financial support must be disclosed. In other words, the organization that writes the check must be recognized on air-one organization can not "buy" announcements for another organization. The exception to this is the case of an advertising agency acting on behalf of an underwriter.

• Price information

• Calls to action

• Inducements to buy, sell, rent or lease

• Comparative information

• Qualitative information

The FCC's rules are more lenient for non-profit organizations and these items are permissible for those organizations. That said, many stations choose to apply the for-profit rules to non-profits for several reasons. One reason is that revenues received in exchange for promoting a non-profit are subject to unrelated business income tax (UBIT), so it is an administrative hassle to segregate these revenues and determine whether tax is owed. Another reason is that some stations want to keep their on-air sound as non-commercial as possible. Listeners may not always understand that an entity is a non-profit and may be confused by what sounds like an ad. It can also be difficult for underwriting staff to explain to a for-profit underwriter why the station permits other underwriters to use the very promotional language it has told the for-profit it may not use.

Price Information

Price information of any sort is prohibited, including product or service price, savings information, value information, interest rates, or indication of no cost. For example:

• "Starting in the low $200's"

• "Offering free admission"

• "Available with a 6.5% APR"

Calls to Action

No calls to action regarding the company or a product or service are allowed. For example:

• "Come in for a test drive"

• "Get your ticket today"

• "Buy XYZ at your local drugstore"

Inducements to Buy, Sell, Rent, or Lease

Inducements to buy, sell, rent, or lease a product or utilize a service are prohibited. This includes announcements of special promotions. For example:

• "Offering a gift with purchase"

• "Includes oil changes for a year"

• "Special deals in the month of June"

Comparative Information

Anything that favorably compares an underwriter to competitors or industry standards is unacceptable. This includes mentions of awards of recognition or merit. For example:

• "Offering the best in garden supplies"

• "Named 'best place to work' three years in a row"

• "The leading maker of…"

• "Oldest bank in town"

Qualitative Information

Descriptive information that is not value neutral is deemed qualitative and is not acceptable. For example:

• "Offering exceptional customer service"

• "A perfect setting for a romantic evening"

• "High quality medical care"

Important note-

An underwriting credit may be promotional even if the information it contains is factually true. The fact that the underwriter's claim can be proven will not make it acceptable. If the copy violates one of the restrictions listed above, it is unacceptable. For example, even it were true that an underwriter had received an award or offered the lowest prices in town, the underwriting credit could not refer to these facts.