What are FCC guidelines regarding underwriting credits on public television?
The FCC requires that all underwriters must be identified by their name and/or logo. If a logo by itself does not adequately disclose the identity of the funder, then the funder’s name must be stated in audio or video. An underwriter MAY NOT be anonymous.
From the FCC’s standpoint, the purpose served by underwriting credits is to identify the funder in the interests of full disclosure, not to promote the funder or its products and services. In the late 80s, the FCC relaxed its noncommercial policy to allow public broadcasters to expand or “enhance” the scope of donor and underwriter acknowledgements to include 1) logograms or slogans which identify and do not promote, 2) location information, 3) value neutral descriptions of a product line or service and, 4) brand and trade names and product or service listings.
In the past the FCC has indicated that it will rely on the good faith determinations of public broadcasters in interpreting the FCC’s noncommercialization guidelines. However, the FCC’s interest in underwriting credit content may change over time with changes in the political environment. The existence of industry guidelines (both national PBS and local station guidelines) helps to establish the reasonableness and good faith of broadcaster judgments with respect to issues that fall in the “gray” areas of the FCC’s rules.
For PBS’ part, PBS guidelines require that the on-air appearance and overall effect of each credit and credit sequence must be in keeping with the noncommercial nature of public television. PBS refers to this holistic view of credits as “Rule One.”