What underwriting copy is unacceptable to the FCC?
FCC policy statements, rulings, advisory opinions, and letters applying its rules and policies to specific underwriting announcements (credits) have cautioned against the use of certain types of language, phrases, and visuals, such as the following, which it deems promotional:
- Calls to action (“Come in today and take a test drive”)
- Superlative description or qualitative claim about the company, it’s products, or its services (“The best service in the industry” or “The most intelligent car ever built”)
- Direct comparison with other companies, their products or services
- Price or value information (“7.7% interest rate available now” and “affordable,” “discount,” or “free”)
- Inducements to buy, sell, rent, or lease (“Six months free service when you buy” or “lifetime guarantee”)
- Endorsements (“recommended by 4 out of 5 doctors”)
- Demonstrations of consumer satisfaction
Some of the words and phrases that the FCC has found unacceptably promotional include:
Quick and clear
The FCC has also advised that credits may be considered promotional even if they include statements of fact or longstanding slogans. For example, a business that is the “award-winning” retailer of a product in the area should not include that information in their underwriting credit, even if it is true and serves to identify the retailer, because the statement is promotional in nature.