[grc] FCC reg re "call to action"

Tracy Rosenberg tracy at media-alliance.org
Sat Feb 5 16:39:18 PST 2022


And it is important to say that the IRS rule mostly focuses on candidates,
not on legislation or policy. Hypothetically, if you spent literally the
majority of your time as a 501c3 working on legislation, you
would be running afoul of 501c3 regulations, but there is literally no
scenario where a radio station could possibly do that. So the key for radio
stations is not to endorse or oppose particular candidates.

The FCC prohibitions are part of the underwriting rules and mostly relate
to sponsorships and commercial call to actions. In other words,
underwritten announcements are not supposed to constitute
specific calls to buy products so they don't sound too much like
commercials. So the nexus is a remuneration to the station related to the
announcement. A call to action makes it sound very activisty, but
that is really not what the FCC is talking about. They are talking about
underwritten announcements.

- Tracy

On Sat, Feb 5, 2022 at 4:33 PM Ken Freedman via grc <grc at maillist.peak.org>
wrote:

> Hi Kim -
>
> I think what you’re referring to is an IRS and not an FCC rule. The IRS
> prohibits 501-c-3 organizations from spending a significant amount of time
> or money trying to effect elections or legislation.
>
> Ken Freedman
>
> Sent. From. Phone.
>
> > On Feb 5, 2022, at 5:40 PM, Kim Kaufman via grc <grc at maillist.peak.org>
> wrote:
> >
> > Hi all -
> >
> > My understanding is that NCE's can't do "call to action" things,
> especially around fed legislation. Does anyone know the FCC reg for this or
> where to find it?
> >
> > Thank you.
> >
> > Kim Kaufman
> > KPFK LSB Treasurer
> >
> >
> > _______________________________________________
> > grc mailing list
> > grc at maillist.peak.org
> > http://maillist.peak.org/mailman/listinfo/grc
> _______________________________________________
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>


-- 
Tracy Rosenberg
Executive Director
Media Alliance
2830 20th Street Suite 201
San Francisco, CA 94110
https://media-alliance.org <http://www.media-alliance.org>
Email: tracy at media-alliance.org
415-746-9475 (office)
510-684-6853 (cell)
Encrypted email at tracy.rosenberg at protonmail.com
Text via Signal
Pronouns: She/Her/Hers

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