We’re not communications lawyers at RW; but the lesson of this case out of the FCC seems to be that if you discover something in your station records that violated commission rules, it’s better to report it than wait for it to be discovered.
Fisher Broadcasting in Seattle has settled a case with the FCC involving a contest that aired on KVI(AM) and a former employee later convicted of theft. Fisher will pay $7,000 and adopt a compliance plan. But in agreeing to the decree, the commission said it took into account the broadcaster’s self-disclosure and history of compliance.
In 2008 Fisher notified the commission that an audit had turned up a problem with its “Secret Listener Salute” contest the year before. It said its promotions coordinator at the time may have manipulated the outcome by adding friends to a list of names to be announced on air, thus making them potential winners, and that the winnings may have been shared with her. Fisher said it discovered the problem after she left and that it subsequently contacted Seattle police.
The FCC said former promotions coordinator Ryan Keeley was convicted by a King County court and ordered to pay $14,000 in restitution after pleading guilty to second-degree theft for her role in the contest.
Fisher contends that her actions violated its code of conduct and conflict of interest policies; it told the FCC it will create added oversight to future contests and monitor their implementation. The Enforcement Bureau announced a consent decree ending its investigation. Fisher agreed to pay $7,000 and adopt a compliance plan that includes designation of a compliance officer and creation of a compliance plan that covers contest rules and staff training.