I’m a non-commercial station. I know I can’t advertise, but what can I say about businesses that want to financially support the ministry?
Applicable CFR: 47 C.F.R. Â§ 73.1125
Any acknowledgement should never be more than 30 seconds in length. The Bible and the FCC both agree that in the multitude of words, sin and violations abound!
While tempting, don’t try to make any acknowledgement sound like a commercial. Music beds, sound effects or even dialog between two people truly distract from the heart and the intent of an acknowledgement, which is giving thanks for the support a business is providing.
If the business is a not for profit (501c3), then you can promote them as you would in traditional advertising. While permissible, this isn’t always advisable, as this could attract the unwanted attention of people who want to cause you problems, which inevitably invites the FCC. You’ll be spending a lot of time justifying your actions.
If the business is for profit, then in short, you can only state the facts about a business.
You cannot be qualitative and quantitative in any description about the goods or services a business provides. This is very easy. NEVER put “est” or “er” at the end of any word! Words like largest, oldest, greater, best, highest, lowest are examples of words that end in er and est and would be qualitative or quantitative. The FCC looks at that as advertising.
You cannot state any pricing or discounts of any kind as it relates to a product or service.
You cannot make calls to action. Simply put, you can’t tell people to “do” anything. “Call now” “Come on down” “Stop by” “Try our new widget” are examples of calls to action that are strictly forbidden.
Instead, you can say “for more information, Joe’s Gift Shop can be reached at 555-212-2000 or online at joesgiftshop.com” This language is not telling anyone to take action, but only where they can find more information.
Special inducements are also considered a call to action. This tends to bridge the first two elements above. Think things like “We’re giving a special bonus to customers who sign up this week” or “Free samples to the first 50 callers” or “Pre-holiday discounts now in effect”.
The trouble is that there is a lot of room between the obviously promotional and the narrowly identifying. And let’s be honest here: underwriters usually want, and probably expect, more than a “name/rank/serial number” announcement in return for their contribution.
So the NCE licensee ends up pulled between the need to comply with the FCC’s less than specific limitations and the underwriter’s preference for at least a little bang for its buck.
Furthermore, the Enforcement Bureau of the FCC has identified the following terms as prohibited:
- With respect to restaurants: “a unique eatery” whose food is “made with only the freshest ingredients”; “their world-famous pepperoni rolls”.
- With respect to a copy center: “your one-stop shop for black and white [and] color copies. You can stop by one of our two locations.”
- An automotive service center: the owner “takes pride in their honest and reliable service”
A good acknowledgement begins with an honest conversation with your prospective underwriter to explain the legal limitations so they’ll have realistic expectations.