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Should There be a Format for Posting Contest Rules Online?

FCC asks this and other questions as the nitty-gritty of figuring out contest rule notifications begins

Now that the commission has begun a rulemaking to update broadcast contest rules comes the process of figuring out exactly how that would work.

Entercom’s petition in 2012 proposing to allow stations to place their contest rules online was unopposed, according to the FCC. Stations have long said airing contest rules on-air invites listener tune-out.

The agency is now collecting public comments on the rulemaking to allow stations a choice: to post their contest rules online or continue to voice them on-air. Entercom, and now the commissioners, believe updating the rules would bring them more in line with how people access information now. The rules stem from 1976, before the Internet was so accessible, and before the public had smartphones and other connected devices.

In its Notice of Proposed Rulemaking, the agency invites comment on whether to allow stations to post contest rules on their own websites, their parent company’s sites or on any publicly accessible site if the station doesn’t have one of its own. The agency proposes to require stations to mention the full website address each time the contest is mentioned on-air or advertised. It asks how often this should be done and for how long.

Should there be a certain online format for contest disclosures? The FCC is asking this question as the agency tries to determine if there should be specifics to make finding the rules easy for consumers. “We are sensitive to the possibility that consumers may become frustrated if they cannot readily locate a contest’s material terms on a non-licensee website,” says the commission in the NPRM.

And while the FCC intends to apply the same rule to radio and television, the commission asks whether any differences in the services merits dissimilar treatment.

Entercom had also proposed the commission allow stations to disseminate contest rules via email, phone, mail or in-person. The FCC is declining to propose all of these methods, believing that on-air and online is enough.

Comments to MB Docket 14-226 are due 60 days after Federal Register publication.

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