This article appeared in NFCB’s monthly newsletter. Subscribe below:
In April, NFCB issued a new community radio station underwriting guide, the successor to its long-running authoritative reference manual. The new release, the NFCB Practical Guide to Underwriting, is a complete rewrite of NFCB’s previous Underwriting Guide, with a focus on offering practical advice rather than strictly a legal analysis of the FCC’s rules. It features updated content and approaches for how your station can do underwriting effectively and within the legal guidelines.
The new guide arrives at an important time for underwriting in community broadcasting.
A significant number of noncommercial broadcasters rely on underwriting to support their operations. However, the rules governing such sponsor identification are broad. Over the last three years, the Federal Communications Commission has fined several stations, including low-power FM stations, for violations of guidelines. One low-power station recently received a $15,000 penalty for spots deemed too commercial, as have others. The largest decree was $115,000, aimed at a full-power educational station for crossing the underwriting line.
NFCB’s new guide is part of the organization’s commitment to help stations stay in legal compliance, as well as to prosper. However, the context behind underwriting is long and complicated.
Here are some reads to understand public media and underwriting:
- In spite of the rules, stations can make underwriting errors. Community radio history and ally Matthew Lasar offers his iconoclastic take on how not to mess up in his classic “How to avoid breaking the FCC’s ridiculously lenient rules against non-commercial radio advertising.” While underwriting interpretations have changed over time, Lasar reminds us that stations should always take a step back and exercise common sense when being approached by underwriters with big ideas for copy.
- Among the major contemporary questions is accepting underwriting from cannabis and CBD businesses. While stations handle these matters in different ways, NFCB supporter and Wish You Were Here sponsor Foster Garvey covered this issue in a two-part essay for Radio Matters. Part one helps frame the topic in relationship to federal law, while part two explores the legal nuances such as digital platforms that your station will want to consider.
- Cannabis is just one gray area for underwriting representatives. In a recent webinar for NFCB (login required), Wish You Were Here sponsor Fletcher, Heald & Hildreth offered stations a primer on determining what underwriting is permissible or legal to accept. From tobacco and vaping companies to alcohol and niche industries, underwriters can come from anyplace. Attorneys Francisco Montero and Robert Winteringham inject their expert analysis into this subject.
- At some stations, there is an undercurrent critical about underwriting. The heart of negative views of underwriting is centered in ethics and trust. Nonprofit AF’s Vu Le recommends some principles to which to hold your revenue efforts. “We have all been trained to prioritize our organization’s mission first, to raise as much money as possible for our individual missions. But our missions are interrelated, and the community is best served if we see ourselves as part of a larger ecosystem.”
The NFCB Practical Guide to Underwriting is now available in NFCB’s Solution Center, a service for member stations. Your organization can join today, if you are not yet a member. You can also contact us to get login assistance.