What You Might Not Know About Recruitment Underwriting

credit copy, Federal Communications Commission

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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. 

Lastly, the phrase "learn more" may seem like it’s a call to action. However, it was deemed acceptable as an alternate way of saying, “for more information…” The phrase "learn more" was used in a credit from Microsoft to indicate where listeners could find additional information on the Internet. The phrase is educational in their use, matching the psychographics of public radio listeners who exhibit the desire to learn and grow. So “learn more” is acceptable.

Here’s an acceptable edit to copy example #1:

Support comes from Smith Subaru, with new Subarus in stock. Smith Subaru also provides maintenance service. Learn more at Smith Subaru dot com.

Copy example #2:

Support comes from Visiting Angels Home Care Nurses - now recruiting nurses to join their team of nursing professionals. Information on applying can be found at visiting Angels dot com slash jobs.

Because this underwriter is not in the recruitment business as an employment agency, headhunter, or a temporary recruiter, for guidance on the underwriting copy I reached back to 1999. That was the year that Ken Scheibel, the senior attorney advisor in the FCC’s Mass Media Bureau's Enforcement Division, was on a panel at the National Public Radio Conference in Washington, D.C. When asked if public radio stations can do recruitment underwriting, here’s how Ken replied.

“The FCC has not directly addressed this point, and we continue to receive informal inquiries about it. While a case can be made that the inclusion of such messages may be deemed inconsistent with the "identification only" purpose of underwriting acknowledgements, because they appear to benefit a business aspect of the for-profit underwriter -- "recruiting," many noncommercial educational broadcasters believe that these announcements are a public service to listeners, and that their inclusion within underwriting announcements should be deemed discretionary and permissible.”

Given those options, it’s up to the management of each station to determine whether or not they’ll accept recruitment underwriting.

If your station’s policy is to allow recruitment underwriting, this would be acceptable:

Support comes from Visiting Angels Home Care Nurses, now recruiting nurses to join their team. Information on applying is online at Visiting angels dot com slash jobs.

But what if the underwriter is an employment agency, headhunter, or a temporary recruiter? Is the following copy acceptable?

Support comes from ABC Headhunters, announcing new job openings for engineers at Google, Microsoft, and Facebook. Info on qualifications, pay, and benefits at ABC Headhunters dot com.

A company whose main business is a recruitment or related business can underwrite with a message about job openings. They can identify the type of job it is and the company that has the job opening. That’s allowed because it’s acceptable for a business to identify their inventory. In this case the headhunter’s inventory is “Google, Microsoft, and Facebook” positions. It’s also acceptable to include the wording  "qualifications, pay, and benefits at ABC Headhunters dot com," since it is identifying where additional information about the open positions can be accessed.

Therefore, the copy is acceptable as written.

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