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Underwriting: can you say they're Christian?

C

callfm

Guest
The FCC's rules prohibit underwriting announcements from being promotional in nature. In paragraph 6 of the below-referenced Order, the Commission explicitly writes: "...references that distinguish the underwriter from its competitors are prohibited" and "...even where statements made about an underwriter are factually true, they are not permissible if they are also promotional."

If being a "Christian business" distinguishes an underwriter from another business...can you really say a for-profit underwriter is "a Christian business," "Christian owned," "operates with Christian values," etc?

http://www.fcc.gov/eb/Orders/2001/da012178.doc
 
> "...references that distinguish the underwriter from its
> competitors are prohibited" and "...even where statements
> made about an underwriter are factually true, they are not
> permissible if they are also promotional."

It would depend on whether the competitors in a given business can also be described as "Christian". With convenience stores, hotels/motels and discount clothiers you probably couldn't use the phrase "...Christian owned and operated..." in the underwriting announcement. With family-style restaurants, funeral homes or "Celebration Station" type fun parks, you probably would not get into trouble with that or a similar phrase.

Even in the case of a Christian-owned business in a type of business where the phrase would distinguished the underwriter from its competitors, you would probably be fine saying something like "...Joe XMan from the Quick Shop is a born-again Christian, and invites everybody to come for a fast stop at the Quick Shop..." In that case, you haven't distinguished the underwriter as doing something in a better, or different way than any of his competitors.

One of my friends, who is development director of a major Public Radio station, tells me that their main policy is BREVITY. They have a 25-word limit on underwriting announcements, so once you get the business name, address and telephone number mentioned, there is little left to be construed as an advertisement.

Matt Smith
WGSR-TV
Reidsville, NC
 
> you would probably be fine
> saying something like "...Joe XMan from the Quick Shop is a
> born-again Christian, and invites everybody to come for a
> fast stop at the Quick Shop..." In that case, you haven't
> distinguished the underwriter as doing something in a
> better, or different way than any of his competitors.

Nope. You can't invite people to do anything, and saying that Joe is a Christian is a "qualitative" statement about Joe, and thus is forbidden. Also, the term "fast-stop" is qualitative and also forbidden. Remember...
IDENTIFY underwriters but don't promote. The fines are just too big to risk it!<P ID="edit"><FONT class="small">Edited by geekboy2000 on 03/21/06 08:16 PM.</FONT></P>
 
Matt wrote:
"you would probably be fine saying something like "...Joe XMan from the Quick Shop is a born-again Christian, and invites everybody to come for a fast stop at the Quick Shop..." In that case, you haven't distinguished the underwriter as doing something in a better, or different way than any of his competitors."

geekboy2000 wrote:
" Nope. You can't invite people to do anything, and saying that Joe is a Christian is a "qualitative" statement about Joe, and thus is forbidden. Also, the term "fast-stop" is qualitative and also forbidden. Remember... IDENTIFY underwriters but don't promote. The fines are just too big to risk it!"
--------------------


And this just BEGS the question...

Why would you want to make that statement (or add any other "Christian" adj.) ANYWHERE in the copy? What is the relevance and/or how is it good use of commercial or non commercial copy in relation to bringing benefit to your advertiser/sponsor, listener, and station?



<P ID="signature">______________
RADIOELIZABETH
Pleasant, Passionate, Persuasive
www.radioelizabeth.com</P>
 
You can describe the business and using the term to describe the business as "Christian Owned" is acceptable.
Why would you want to do that? Because the business requests it and you can. Some businesses are run by Christians but not owned by Christians , it's part of the description. You are not doing a call to action and that's the biggie to stay away from. You can also use the business slogan. It might have "Christian" in it. The best thing is to send the listeners to the business website, they will find everything there. Invite them to visit "blah blah's website". That's not selling. You can't sell. Example; "The phone number is ...and you may also visit them on www.....".
Some stations allow the businesses to come in and do a spot themselves as to why they support Christian radio and bring in their beliefs while briefly describing the business. Being brief is a must.
Read the current version of the FCC rules for enhanced underwriting, the rules were updated a few years ago.
 
Why would you?

My question still isn't answered...

WHY would this description be included in copy?

What benefit does it bring the advertiser, listener, or station?

What is the adjective saying and why?<P ID="signature">______________
RADIOELIZABETH
Pleasant, Passionate, Persuasive
www.radioelizabeth.com</P>
 
Re: Why would you?

> My question still isn't answered...
>
> WHY would this description be included in copy?
>
> What benefit does it bring the advertiser, listener, or
> station?
>
> What is the adjective saying and why?
>

Hopefully the adjective means the business is run on Christian principles, i.e. honesty, integrity, generousity, etc. Personally, I'd rather hear someone state that outright than to call themselves a "Christian business", but that would seem to more blatantly violate the underwriting rules.
 
Re: Why would you?

> My question still isn't answered...
>
> WHY would this description be included in copy?
>
> What benefit does it bring the advertiser, listener, or
> station?
>
> What is the adjective saying and why?

I thought it was pretty clear what I said. The client wants "Christian owned" somewhere in the spot to separate their business from a secular owned business. That is why we are on this subject, another wanted to know if he could do it on his underwriting spot.
 
Re: Why would you?

>
> "Hopefully the adjective means the business is run on
> Christian principles, i.e. honesty, integrity, generousity,
> etc. Personally, I'd rather hear someone state that
> outright than to call themselves a "Christian business", but
> that would seem to more blatantly violate the underwriting
> rules."

Exactly! You get it! clap clap.
 
Re: Why would you?

"... to separate their business from a secular owned business..."

But how do you reconcile that with the FCC's statement: "...references that distinguish the underwriter from its competitors are prohibited..."??

In my opinion a label carries little weight. The mere fact that a business is identified as supporting a radio station that clearly presents Jesus to the listener should bring the business a great benefit by their association with the messenger.
 
No offense redhead, but you have a poor grasp of non-comm underwriting rules.

> You can describe the business and using the term to describe
> the business as "Christian Owned" is acceptable.

You can only describe the business in a value-neutral context: "Programming on KXYZ is underwritten by Acme Widgets, offering widgets and widget accessories for the home and car. Acme Widgets, on Widget St. in Widgetown... 555-5555 or online at www.acmewidgets.com

> You are not doing a call to action and that's the biggie to stay
> away from.

No... promotional language is just as forbidden as calls to action.

> You can also use the business slogan.

Yes, depending on the language in the slogan. If it identifies but doesn't promote the business, then it's OK.

> Invite them to visit "blah blah's website". That's
> not selling. You can't sell. Example; "The phone number is
> ...and you may also visit them on www.....".

Nope. You CAN say "their website is www....." but don't invite them to do anything.

> Read the current version of the FCC rules for enhanced
> underwriting, the rules were updated a few years ago.

Excellent idea!! LOL
 
Re: Why would you?

> "... to separate their business from a secular owned
> business..."
>
> But how do you reconcile that with the FCC's statement:
> "...references that distinguish the underwriter from its
> competitors are prohibited..."??
>
>I would interpet that as using superlatives such as "The Best" "better than" which you can not do. Acknowledging a business as a Christian owned company is a description, as is the term "family owned" or Italian restaurant. Actually some Christian owned companies may not have as good a reputation as a secular company but that's taking another route and not on target to what we are talking about.
 
> No offense redhead, but you have a poor grasp of non-comm
> underwriting rules.
>
Perhaps you do.
 
Re: Why would you?

radioelizabeth wrote:
"My question still isn't answered... WHY would this description be included in copy? What benefit does it bring the advertiser, listener, or station? What is the adjective saying and why?"

varedhead wrote:
"I thought it was pretty clear what I said. The client wants "Christian owned" somewhere in the spot to separate their business from a secular owned business. That is why we are on this subject, another wanted to know if he could do it on his underwriting spot."


No. Not clear.

If the answer is simply because the client wants it...ok. But I would still wonder if station's allow all copy client's want to broadcast? That isn't always the case.

Also... what about THAT adjective separates their business?

Again...what benefit does it bring the client, the listener, and the station?
<P ID="signature">______________
RADIOELIZABETH
Pleasant, Passionate, Persuasive
www.radioelizabeth.com</P>
 
Re: Why would you?

"Hopefully the adjective means the business is run on Christian principles, i.e. honesty, integrity, generousity, etc. Personally, I'd rather hear someone state that outright than to call themselves a "Christian business", but that would seem to more blatantly violate the underwriting rules."

varedhead wrote:
"Exactly! You get it! clap clap."


Consider that the adjective could also mean: broken, sinful and very fallen.

Honesty, Integrity, Generosity, etc. are not exclusive to the Christian. So I'm not seeing that the word "Christian" separates the business from any other.


<P ID="signature">______________
RADIOELIZABETH
Pleasant, Passionate, Persuasive
www.radioelizabeth.com</P>
 
Re: Why would you?

"Acknowledging a business as a Christian owned company is a description, as is the term "family owned" or Italian restaurant. Actually some Christian owned companies may not have as good a reputation as a secular company but that's taking another route and not on target to what we are talking about."


But that is part of what we are talking about.

I'm honestly not seeing how "Christian" and "Italian" are equal here.

Italian is a KIND of food. It speaks to the menu, the flavor and the atmosphere...meeting expectation of the patron when they arrive.

How is "Christian" in any way similar in it's use on the air?


<P ID="signature">______________
RADIOELIZABETH
Pleasant, Passionate, Persuasive
www.radioelizabeth.com</P>
 
Re: Christian or Italian?

Elizabeth wrote:
> I'm honestly not seeing how "Christian" and "Italian" are
> equal here.
>
> Italian is a KIND of food. It speaks to the menu, the flavor
> and the atmosphere...meeting expectation of the patron when
> they arrive.
>
> How is "Christian" in any way similar in it's use on the
> air?

I actually went to a Christian restaurant once, but all they served was grape juice and crackers. (and really bad coffee.)
 
Re: Christian or Italian?

> Elizabeth wrote:
> > I'm honestly not seeing how "Christian" and "Italian" are
> > equal here.
> >
> > Italian is a KIND of food. It speaks to the menu, the
> flavor
> > and the atmosphere...meeting expectation of the patron
> when
> > they arrive.
> >
> > How is "Christian" in any way similar in it's use on the
> > air?
>
> I actually went to a Christian restaurant once, but all they
> served was grape juice and crackers. (and really bad
> coffee.)
>

funny. bad coffee is better than no coffee at all.

wow. i have lots of typos today! maybe i should have some myself!
<P ID="signature">______________
RADIOELIZABETH
Pleasant, Passionate, Persuasive
www.radioelizabeth.com</P>
 
Re: Why would you?

>
> Again...what benefit does it bring the client, the listener,
> and the station?

The answer is so obvious yet it seems to be such a hard thing to understand for some reason.
The client is happy, the listener knows the business is Christian owned and with those two elements happy, that makes a happy station. Of course I am being flippant but this is going somewhere really strange. In all reality it doesn't matter if the description is there or not, most listeners figure that if it is on a Christian station, the station will make sure the product/business being underwritten represents their standards.
We could discuss the rules of underwriting, and each one get a different view or understanding. Discussing this subject with other stations, and in listening elsewhere, some go far to the edge without going over, some stay away from the edge and others don't even do underwriting spots for fear of not doing it correctly. Just do the best to follow the rules and if you feel queasy about adding the Christian description, just don't. Let your conscious be your guide.
 
Re: Why would you?

>
> But that is part of what we are talking about.
>
No it wasn't, it was about the legality of the description.
 
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