UNDERWRITING PRINCIPLES

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PRINCIPLE A: Underwriting Sources

  1. WMOT seeks underwriters representing a broad spectrum of funding sources- corporations, foundations, individuals, government agencies, and others.                                              

  2.  All funding sources are considered under the "access" principle, which means that WMOT has no list of sources from which funding will not be accepted unless prohibited by law. However, potential conflict of interest and problems of listener misperception, confusion, or similar reasons regarding the funder's role and/or influence on programming will be considered in accepting or rejecting underwriting.                                            

  3. WMOT is legally responsible for all material aired, including programming originated by a source other than the station itself. For this reason, WMOT reserves the right to edit outside underwriting credits (e.g., National Public Radio, American Public Radio, and others) if they violate these guidelines, or if they violate the policy of Middle Tennessee State University.                                                                                                              

  4. In applying its policies and practices regarding acceptability of underwriters and underwriting announcements, WMOT will exercise good faith judgment in interpreting the Communications Act, FCC rules and Commission statutory policies.                                              

  5. WMOT reserves the right to change its policies and practices regarding the acceptability of underwriters and underwriting announcements, as required to comply with its interpretation of the Communications Act, FCC Rules & Regulations, and the policies of Middle Tennessee State University.

 

PRINCIPLE B: Identification of Underwriters

  1. Underwriters of programming on WMOT not only are legally required to be identified [Section 317 (a)(1) of the Communications Act of 1934, as amended], but also deserve credit for their support of public radio.                                                                                     
  2. All underwriting announcements must be written to clearly identify the entity making the contribution in a manner that does not violate the non-commercial nature of public broadcasting or WMOT’s own non-profit mission.                                                            
  3. Underwriter announcements may not be used as forums, advocacy platforms, or statements of belief regarding issues, concerns, lifestyles, political or religious preferences, etc.                                                                                                                        
  4. WMOT reserves the right to refuse contributions if it determines that their acknowledgement on the air might have an adverse affect on its mission or on listenership, listener support or other financial support.

 

 PRINCIPLE C: Non-Promotion of Underwriters In Acknowledgments

  1. "Acknowledgments are strictly for identification of donors and should not promote the company, products or services of the donor. Announcements which contain comparative or qualitative description of a product or company go beyond permissible limits." [MM Docket 21136 FCC Second Report & Order, April 23, 1981, paragraph 37; Memorandum Opinion and Order, March 28, 1984, paragraph 13].                                                              

  2. Acknowledgements of contributions from non-profit entities are not subject to this identification-only rule. However, due to a differing IRS rule, WMOT imposes limitations on such acknowledgements as noted in PRINCIPLE I.

 

 PRINCIPLE D: "Consideration Received" Rule

  1. No message or other programming material containing language that promotes the underwriter or its business interests shall be offered at any time in exchange for the receipt, in whole or in part, of consideration to WMOT and the University, its officers, directors, or employees. (Section 399 B of the Communications Act of 1934, as amended.)      

  2. This rule, which can be stated simply "no promotion for consideration," is at the heart of WMOT's underwriting principles.

 

 PRINCIPLE E: Program Content/Editorial Control

  1. All program content and all editorial decisions related to program content and scheduling on WMOT are the sole responsibility of the WMOT staff.                                              

  2. No underwriting will be accepted which compromises WMOT's program and editorial policies.

 

 PRINCIPLE F: Program Preemption, Substitution or Cancellation

  1. The nature of broadcasting, particularly public broadcasting, is such that it may require the preemption, substitution or cancellation of any program at any time without prior notice to the funder. WMOT reserves the right to make such program decisions.          

  2. In the event that a program is deleted from the schedule or a scheduled underwriting announcement is missed for any reason, WMOT will provide make-good announcements of equivalent value as determined by WMOT staff.

 

PRINCIPLE G: Non-Intrusiveness of Underwriter Identification

  1. Underwriting acknowledgments should not interrupt the flow of programs or district from the quality or sound of the programs with which they are associated.

 

 PRINCIPLE H: Application of Underwriting

  1. All types of WMOT programming may be underwritten.    

  2. When national programs are underwritten, such underwriting must be explicitly identified as "local."

 

 PRINCIPLE I: Non-Profit Exception

  1. FCC rules regarding underwriting by bona fide not-for-profit entities permit some relaxation of the "non-promotion" and "consideration received" rules (see C and D above). In general these principles and procedures are intended to apply to all underwriters.                                                           

  2. Due to a differing IRS rule, WMOT must require Non-Profits to meet the same requirements as for-profits in order to avoid Unrelated Business Income Tax (UBIT) issues.