Rate Analysis Reporting for Political Advertising Compliance

FCC Rules About Rates for Political Ads

The FCC’s Political Programming division defines the rules and regulations regarding broadcast campaign advertising. It applies only to direct advertising from a “legally qualified candidate.” The rules address pricing, “class” dayparts and providing reasonable access. It is not related to ads for PACs (political action committees).

Who Is a Legally Qualified Candidate?

In short, it’s someone who has completed all the qualifications to ​run for public office. That can encompass filing documents with ​state or local election boards and gathering necessary signatures.

This definition can also include write-in candidates who make a public statement that they are running for office and engaging in an active political campaign.​

What Are the Advertising Rate Rules for Candidates?

Specific areas of the FCC rules address pricing. The ​regulations state, “A candidate shall be charged no more per unit ​than the station charges its most favored commercial advertisers ​for the same classes and amounts of time for the same periods.” So, what does that mean?

What Are Classes of Time?

A “class” is a spot with specific rights and ​characteristics. Classes are typically ​dayparts, but some classes can be a subset ​of this. You may also have unique segments of rates because of things like the levels of perceptibility and makegoods.​

Stations may establish their own definitions around reasonable classes of immediately preemptible time.​

What Is Reasonable Access?

The FCC rules include a section on ​reasonable access, which means candidates ​can demand access to all classes and dayparts available. However, that applies only to federal candidates.​

For state and local candidates, stations that sell to one must also sell to others in the race. You must make equal amounts of time available. That doesn’t have to include all your inventory; you decide what dayparts are available to whom.​

The bottom line is that you must treat all legally qualified candidates for the same race in the same way.

What Are Lowest Unit Rates?

The lowest unit rate (LUR) applies to candidates. It includes any advertising sold to the ​candidate within 60 days before the general election ​or 45 days before a primary. The price they receive must be the lowest unit rate in any class of advertising. In other words, they benefit from volume discounts regardless of the amount of ad time they purchase.​

So, what is your lowest unit rate? Most media companies have more than one. That’s because you price spots differently depending on those classes mentioned above.

The question becomes, how do you determine those lowest rates? You’ll need a rate analysis reporting feature in your traffic system.

Other Pricing Rules for Political Ads on Radio

• A broadcast company cannot favor one candidate over another with rates.​
• Organizations cannot charge more than the regular rate for comparable advertising.​
• Stations can offer volume or other discounts as long as they are equally available to all candidates.

Rate Analysis Reporting in Traffic Systems

To simplify compliance with pricing, stations will need a robust rate analysis feature to avoid manual work. The functionality of the tool should provide the ability to:

• Evaluate orders subject to rate analysis with instant reporting.
• Set filters for dates, days of the week, times, stations and spot lengths.
• Include zero-rate spots, revenue sources or sponsorships.
• Export the results of the report.

The most effective rate analysis tools deliver a simple, streamlined way to manage order entry to determine the LUR. With such capabilities, managing rates throughout the political cycle is seamless. You can be more confident in your compliance with FCC rules without creating extra work.