Fcc political file

For issue ads that do not address issues of national importance, stations must simply document the fact that the ads were aired and maintain a list of the chief executive officers or members of the executive committee or of the board of directors of the entity buying the time.

Information about rate, class, and air times is not required. A request for time by a legally qualified candidate federal, state, or local or on behalf of that candidate by his or her authorized campaign committee, is a candidate ad.

Candidate ads must include the information above, plus:. In an October order resolving political file complaints against 11 licensees, the FCC clarified the scope of issue ad regulations and gave more guidance on what needs to be documented in station public files for those ads.

How do you know if the issue ad rules arising under BCRA are triggered when a request for time comes in the door? Ask whether the ad is about 1 a federal candidate, 2 a federal election, 3 an issue on which legislation is pending in front of Congress or 4 any other matter of national political controversy.

If the answer is yes to any or all of the above, the BCRA issue ad rules are applicable. For such issue ads, the station must document in the public file — in addition to the information above related to rates, class, and scheduling — the following:. Their ad copy describes the impeachment of President Trump, alleges corruption in the Senate, discusses economic inequality, and implores the listener to vote for Democrats on Super Tuesday.

The ad arguably also references the Senate and the Democratic Presidential primary, so both of those primary elections should be listed as well. Next, the documentation should list economic inequality as the issue of national political importance. Yes, there is some ambiguity here, but you cannot go wrong being over-inclusive in listing candidates, elections and issues discussed, even if some are only obliquely mentioned.

Similarly, the FCC acknowledges that, while a station cannot be fully responsible for ensuring that the officers and board members provided to it are complete and accurate, the licensee must nonetheless make a reasonable effort to determine the completeness of the information. The second aspect of the reconsideration was a statement that the FCC is looking for good-faith efforts of stations to comply.

The October decision had some troubling language that suggested that the FCC was expecting stations to provide uniformity of public file disclosures as to the issues discussed in this advertising, which suggested some sort of strict compliance requirement. In fact, even lawyers have been disagreeing about how to characterize some of the issues discussed in some of these federal issue ads.

For example, if an ad discusses both the Border wall and immigration, is that a discussion of two aspects of the immigration issue or are they two separate issues that must be listed separately on the disclosure form?

What about issues that are addressed only by implication without being specifically mentioned — or candidates who are being attacked subtly, without use of their name? Recognizing that there is room for judgement on many of these issues, the reconsideration order indicates that the FCC is looking for good-faith efforts at compliance by licensees.

The FCC also indicates that good faith is the standard for the use of acronyms in public file disclosures. In some cases, the public will clearly know to whom an abbreviation refers — like the NRA. In such circumstances, where the licensee in its good faith judgment determines that the abbreviation will be known to most reasonable people, the abbreviation can be used instead of the full name, e.

But it seems prudent for stations to be cautious and use full legal names wherever possible, even though the FCC decision now allows good faith judgements as to when abbreviations may be appropriate.