[BC] LPFM Operations

[Black, Mike]

> Actually, this is incorrect. You can run commercial continuity for
501c3
> organizations, complete with all the trimming. HOWEVER, you and they
> will likely have to pay tax on the announcements.

>>It's not commercial continuity when it promotes the tax 
>>exempt purposes of a tax exempt organization.

>>Commercial continuity is continuity of and for a for profit 
>>entity.

>>RH

In relationship to what the FCC defines as "commercial continuity", as
compared to permissible language of a donor acknowledgment, or
underwriting announcement, a commercial is a commercial, for-profit or
not. There is a big difference in the content of an underwriting
announcement for a non-profit entity and a commercial for a non-profit
entity. A paid announcement on your NCE or LPFM station by a 501 c3
recognized church, promoting an event with promotional language,
comparative descriptions, price, and call to action is a commercial. The
same paid announcement of support for the station and its programming,
sticking to the language the FCC outlines as acceptable to underwriting
copy, is not. 

If the station airs a PSA or community calendar announcement, for the
same 501c3 at no charge, that is an entirely different matter. However,
we have been advised to make sure that there is consistent language and
guidelines for any PSA or community calendar, so as not to get into
either legal issues or cause confusion when it comes to the
underwriting/support issue. 

Mike