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Disclosure PDF Print E-mail

Of the most common mistakes that broadcast stations make with regard to political advertising, the first is not fully disclosing how they "do business" with "most favored" commercial advertisers. The second is not complying with the disclosure statement that they publish.

To avoid confusion, misunderstanding and costly complaints, LUC has created the LUC Media "Disclosure Checklist." It is our intent to provide stations a handy measuring stick which, if applied to their disclosure documents, will eliminate most of the arguments that come up during the "heat of the campaign."

By FCC definition, a "good" disclosure statement will meet the following five criteria:

  1. A description and definition of each class of time available to commercial advertisers sufficiently complete to allow candidates to identify and understand what specific attributes differentiate each class.
  2. A description of the Lowest Unit Charge and related privileges (such as priorities against preemption and make goods prior to specific deadlines) for each class of time offered to commercial advertisers.
  3. A description of the station's method of selling preemptible time based upon advertiser demand (commonly known as "current selling level") with the stipulation that candidates will be able to purchase at these demand generated rates in the same manner as commercial advertisers.
  4. An approximation of the likelihood of preemption for each type of preemptible time.
  5. An explanation of the station's sales practices, if any, that are based on audience delivery, with the stipulation that candidates will be able to purchase this kind of time if available to regular commercial advertisers.