Understanding if Credit Copy Is Governed by FCC Regulations or Station/Other Policy

Federal Communications Commission, credit copy, FCC, Corporate Support

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At Greater Public we get many questions about FCC copy regulations, and sometimes those questions actually relate to station policy rather than the FCC guidelines themselves. But which guidelines are enforced by the FCC and which are ones restricted by individual station policy may surprise you.

Test your knowledge about a few of these rules with the questions below.  Are these FCC restrictions or are they implemented by the public media station or its university (or other licensee’s) policy?

1. Is it ok for a nonprofit underwriter to mention their own calendar year-end or other seasonal fundraising campaign?

 ܏ Governed by FCC regulations
 ܏ Governed by station/other policy

2. Are there special provisions for nonprofit underwriters?

 ܏ Governed by FCC regulations
 ܏ Governed by station/other policy

3. Can factual statements of awards be mentioned in a credit?

 ܏ Governed by FCC regulations
 ܏ Governed by station/other policy

4. Are announcements for alcohol, and tobacco, and/or e-cig/vaping companies allowed?

 ܏ Governed by FCC regulations
 ܏ Governed by station/other policy

5. Are personal pronouns allowed?

 ܏ Governed by FCC regulations
 ܏ Governed by station/other policy

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Answers to Most-Asked Questions From the PMDMC19 Underwriting Basics Cohort

PMDMC, credit copy, Corporate Support

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When a group of sales reps and managers gathered at this year's Public Media Development and Marketing Conference (PMDMC) to explore and reconnect with the essentials of underwriting, these were the questions they felt were most urgent to their daily work:

How do I get underwriting renewals or increases?

  • Think of how well your membership department has converted members into sustainers. Instead of treating sponsors simply as renewals, steward them like public media marketing-campaign sustainers. Also, weave in components that are valuable to them like digital media, or sponsorship of a station event.

How long should I wait to follow up with an underwriter? How long is too long to not talk with them personally?

  • When your underwriter has signed an annual agreement, ask how often he/she would like to meet with you. Whatever the underwriter says, increase it by one or two times.
  • When a new underwriter signs up for a year, your first follow-up should be two to three weeks after the schedule begins.

How can I close faster?

  • Make sure you’re talking from the start with the person who has the authority and the budget to make a buying decision.
  • Do they have a need?
  • Do they have a time frame?
  • Assess up front: Are their company’s mission and/or vision statements compatible with those of your station?

How can I identify new underwriting prospects?

Check out Greater Public’s Underwriting Category Study for the categories that offer the most potential for stations.

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Why an FCC Copy Violation Is Never Worth the Risk

PMDMC, credit copy, FCC, Corporate Support

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Underwriting credit copy is hard to get right. FCC copy guidelines are rarely black and white and evaluating copy closely can take time and thoughtful discussion. The blurry middle ground of sponsor messaging can result in tricky conversations with sponsors, many of whom have strong preferences about how their spot is worded. Some sponsors want to walk right up to the edge of the FCC’s guidelines. And some misunderstand public media underwriting altogether. For as appealing as public media underwriting is compared with traditional advertising, navigating the restrictions of credit copy can be just plain hard. 

It may be tempting to look past these complexities in the interest of keeping sponsors happy and saving time. But two experts who specialize in FCC law, Garvey Schubert Barer Principal and Managing Director Brad Deutsch and PBS Director of Funding Policy Dan O'Melia, emphasized during a recent session at the 2019 Public Media Development and Marketing Conference that the long-term financial and time costs of being found out of compliance by the FCC can be crippling for some organizations.

This was a timely discussion as all public broadcasters will be up for license renewal over the coming two to five years. Brad pointed out that there is no FCC “Big Brother” watching; The FCC doesn’t have compliance officers checking stations around the country. FCC complaints are issued by our listeners and community. Every station up for license renewal must air messages essentially saying that if anyone has any problems with the station, they should call the FCC to complain. Those announcements may be heard by disgruntled past employees, competitors, or simply listeners who believe we are getting too commercial-sounding. So, it is important to get our ducks in a row.

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Tips for Getting the Best Copy on the Air, Every Time

credit copy, halo effect, Corporate Support

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We all know that the most successful credit copy - for stations and sponsors - is brief, concise, uncluttered, and consistent with the public radio tone. And yet some of our copy on-air isn’t hitting all of those marks. Sometimes it’s because we need to write better copy from the start. And sometimes good copy gets questioned before it gets to air. So how do we write the best copy and make sure that’s what our audience hears? Here are some tips.  

Start by thinking about what is most important to the client.

When writing a sample script for a new client, start at their website, specifically the “About Us” page, if it exists. You’ll want to know why they are in business and how they got started. See if some of the language they use on their site is permissible for public radio.

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What You Might Not Know About Recruitment Underwriting

Federal Communications Commission, credit copy

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Every week I receive a number of questions about underwriting copy.  Some are asking about certain words or phrases and some questions are about specific topics.

I’ll share a couple of credits with you that were featured in a recent credit copy webinar I presented. 

Copy example #1:

Smith Subaru, with hundreds of new Subarus in stock. Now offering customers their Smith Care Coverage Program. Learn more at Smith Subaru dot com.

The question that accompanied this copy was whether or not the phrase “learn more” is acceptable. But there are additional issues with the copy. “Smith Care Coverage Program” sounds like it could be a warranty or service program. You need to remember that guarantees, warranties, and performance claims are considered inducements and are prohibited. Another issue with the copy is the wording “hundreds of new Subarus in stock,” which is definitely a qualitative statement. It’s possible that they may have hundreds of new vehicles available, but just because something is a verifiable fact doesn’t necessarily make the copy acceptable. 

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A Simple Formula for Writing Underwriting Copy

credit copy, Corporate Support

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Every underwriting spot contains three primary pieces of information, the same three pieces of information you’ll find in commercial advertising messages:

  • The name of the underwriter
  • The underwriter’s business, products and/or services
  • Where or how you can reach the underwriter or get more information (location, phone and/or web address)

As an example, one of the most to-the-point commercial advertisements I’ve seen was on a billboard on the Interstate.

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Creating Your Station's Underwriting Copy Approval Process

credit copy, FCC, Corporate Support

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"If you don't know where you're going, any road'll get you there."

- paraphrase of an exchange between Alice and the Cheshire Cat 
in Lewis Carroll's Alice in Wonderland

Once upon a time, underwriters were acknowledged solely by the name of their company. Now fast-forward several decades. Today some underwriting sponsors and underwriting sales people have become very good at wordsmithing for writing copy. That’s okay as long as the copy follows the FCC’s and your station’s guidelines for underwriting credits.

You must keep your destination in mind as you craft the copy that gets you there.

Be up front.

Writing copy that’s compliant with rules and guidelines is easy, especially when you’ve been proactive with underwriters about copy guidelines. This means it's essential to explain these guidelines to your new underwriter long before it’s time to write the copy. This should happen:

a) During early discussions about the uniqueness and value of public media underwriting or...

b) As part of your sales proposal. The copy should be based upon two to four descriptions of the underwriter's business that he has said he wants your listeners to know, (he'll have shared these business specifics with you during your very first meeting).

But let’s hit rewind and go back a bit. Does your station have a credit copy approval process to help you know where you’re going?

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Five Ways to Leverage the Halo Effect to Write Effective Underwriting Copy

underwriting, credit copy, Corporate Support

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It’s your first meeting with a prospective sponsor. You shared the value and benefits of underwriting as one of several aspects of your conversation.

Question: Did you talk about copy?

Credit copy is another important subject to bring up during your first meeting. Not the actual copy for the credit, but an explanation of the right kind of copy. You’ve got to help prospects understand that an appropriately worded underwriting message is one that resonates with the listeners and fits in with the sound of the station.

Just as you wouldn’t pair brown shoes with a black tuxedo to a formal event, you don’t want a message that strikes listeners like an out-of-tune piano in a symphony orchestra. You want copy that fits in with the sound of the station.

That’s where leveraging the halo effect helps you write copy that delivers. One of the challenges of working in underwriting is managing copy issues with our underwriters and prospects. Many of them aren’t accustomed to the FCC guidelines, and navigating copy issues can be tricky. Let’s take a look at what kind of copy is effective for underwriters.

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Five Ways to Avoid Negotiations About Credit Copy With Underwriters

on-air message, copy negotiation, credit copy, FCC, Corporate Support, underwriting proposal, copywriting, underwriting prospect

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We all know that underwriting provides incredible value to our sponsors. Why then, when we’re talking with a prospective underwriter about their on-air message, do we take a position of weakness by saying something such as, “We can’t say that in an underwriting credit”?

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