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FCC: 15K dinger against KELS-LP for running commercials upheld

Not much has changed in policy. The FCC is not always quick to update their "information" pages. I do have a couple of recent examples and will probably add more examples in the future in the Compliance Guide. Keep a watch on:
Agreed that not much has changed, but considering the long term ongoing discussion of what is legal and what is not the more case history that can be referenced the better. Precedent is what is defining the rules as there is obviously some gray area.
 
If one follows the business card model, the announcements will be fairly brief.
  • Name of underwriter
  • Short non-promotional description of line of businesses (3 or less)
  • Location information
  • Contact information
Programming on WREC-LP is supported by our friends at Red Lobster, a restaurant serving seafood and steaks. They are located at 123 Main Street. Their phone number is 410-555-1212. More information at redlobster.com.
Can you call them "our friends"? Would that qualify as a superlative or endorsement or qualitative statement? I don't see an issue, but someone sure could....
 
Agreed that not much has changed, but considering the long term ongoing discussion of what is legal and what is not the more case history that can be referenced the better. Precedent is what is defining the rules as there is obviously some gray area.
If it wasn't for past precedence and policy interpretation of rules and law, LPFM and NCE stations would be required to follow the strict §73.503(a) guideline and could only be licensed to accredited schools. The past efforts of Moody Bible Institute, Pacifica Foundation and others who had challenged the NCE qualifications over the years, shaped the service we have today.
 
Can you call them "our friends"? Would that qualify as a superlative or endorsement or qualitative statement? I don't see an issue, but someone sure could....
I don't really view it that way. Because, it is the station's voice speaking (like it should on all underwriting acknowledgements), I don't see an issue of referring to an underwriter as a "friend" of the station because that in itself is not qualitative, quantitative, a call to action nor a seed plant. It would be different if it was worded differently:
"WREC-LP is supported in part by our friends with the most choices in seafood, Red Lobster..." (quantitative)
"WREC-LP is supported in part by our friends at the best seafood restaurant in town, Red Lobster..." (qualitative/comparative)
"WREC-LP invites you to dine tonight with our friends and station supporter, Red Lobster..." (call to action)
"Can't decide where to go out and eat? Programming on WREC-LP is supported in part by our friends at Red Lobster..." (seed plant)
All of these examples are not good for air on NCE/LPFM.
 
Can you call them "our friends"? Would that qualify as a superlative or endorsement or qualitative statement? I don't see an issue, but someone sure could....
I would only do this if it was every script. Saying it in some messages and not others suggests a comparison IMO.

Or, even better:
"Support comes from Jazz 91 friends and members, and from Quahog Tire and Auto Center, a dealer for Goodyear Tires"
 
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