Political File Requirements – A Brief Summary
The FCC in recent months has placed particular emphasis on compliance with its Political File requirements. The Political File is a part of each station’s Online Public Inspection File.
Basically, the FCC requires each station to upload to its Political File a record of each request to purchase broadcast time that either (a) is made by or on behalf of a legally qualified candidate for public office or (b) communicates a message relating to any issue of national importance.
Required information must be uploaded “immediately” (which the FCC has said means within 24 hours or at least by the next business day) upon receipt. In some instances that means the broadcaster may have to supplement the record for a particular buy on several occasions as additional information is received.
For each political time request, the station must report in its Political File:
• whether the request is accepted or rejected;
• the rate charged;
• the dates and times the ad aired;
• the class of time purchased;
• the name of the candidate, the office sought, the election in question (e.g., primary, run-off, general) or with respect to an issue ad, all issues to which the ad refers;
• in the case of an ad purchased by a candidate or an authorized campaign committee, the name of the candidate, the name of the candidate’s authorized committee and its treasurer; and
• in the case of any other request, the name of the person or entity purchasing the time, the name, address, and phone number of a contact person, and a list of all the chief executive officers or members of the executive committee of the board of directors of such entity.
The NAB PB-19 form covers all the required topics.
In preparing a form for the Political File, a station should not use an acronym to identify the sponsor — unless the acronym is widely used by the general public.
Note: If a third-party ad about a state or local candidate also touches on a political matter of national importance, a record of the ad request must be included in the station’s Political File.
Required materials must be retained in the Political File for two years.
September 2020
