REMINDER: STATION
ADVERTISING SALES CONTRACTS MUST CONTAIN NON-DISCRIMINATION LANGUAGE
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This is a reminder that every
station advertising sales agreement must contain provisions stating
that the station does not discriminate on the basis of race or ethnicity. Every station licensee will
be required to certify as a part of the FCC license renewal application that
its station does not discriminate and that the station’s sales agreements
contain a non-discrimination clause. The cycle of license renewal
filings begins June 1, 2011 for radio stations in Maryland, Virginia,
Washington, DC, and West Virginia. Radio stations in other states will
file license renewal applications scheduled through April 1, 2014, and
television stations will file renewal applications on a schedule beginning
June 1, 2012 through April 1, 2015. The FCC did not specify the
language that must be included in advertising contracts, but we recommend the
following: NONDISCRIMINATION
POLICY: [Licensee] and its station(s) do not discriminate in
advertising contracts on the basis of race or ethnicity, and will not accept
any advertising which is intended to discriminate on the basis of race or
ethnicity. Advertiser represents and warrants that it is not purchasing
advertising time from [Licensee] or its station(s) that is intended to
discriminate on the basis of race or ethnicity. Each station licensee and
its sales staff should be particularly careful not to accept an order for
advertising that contains written or implied unwritten “no urban/no Spanish”
dictates, as these instructions have been specifically criticized by the
Commission. If you have any questions
concerning these non-discrimination provisions, please contact an attorney in
our office at (202) 429-8970. February 16, 2011 |
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This memorandum is intended only as a general discussion of these issues and should not be regarded as legal advice. We would be pleased to provide additional details or advice about specific situations if desired. Copyright © 2011, Lerman Senter PLLC 2000 K Street NW,
Suite 600 | Washington, DC 20006-1809 To Unsubscribe: Unsubscribe | To Update Client Info: Update Client Info |
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