BROADCAST AND 

CABLE TELEVISION

Requirements for 

Identifying Sponsored 

Programming Should 

Be Clarified

Report to Congressional Requesters

January 2013

GAO-13-237

United States Government Accountability Office

GAO
United States Government Accountability Office

Highlights of GAO-13-237, a report to 

congressional requesters 

January 2013

BROADCAST AND CABLE TELEVISION 

Requirements for Identifying Sponsored 

Programming Should Be Clarified

Why GAO Did This Study

The FCC is responsible for ensuring

that the public knows when and by 

whom it is being persuaded. 

Requirements direct broadcasters to 

disclose when a group or individual 

has paid to broadcast commercial or 

political programming. Political 

advertising must also comply with 

requirements overseen by the FEC.

Recognition of sponsored 

programming has become increasingly 

difficult because of new technologies 

and increased access to sponsored

programming such as video news 

releases. GAO (1) describes 

requirements for sponsorship 

identification and federal election 

disclaimers and stakeholders’ views of 

the requirements and (2) assesses

how and to what extent FCC and FEC

address complaints. To conduct the

work, GAO reviewed relevant laws,

guidance, and enforcement 

procedures, and interviewed agency 

officials and stakeholders about

enforcement processes and actions.

What GAO Recommends

FCC should, among other things, 

update its sponsorship identification 

guidance and consider providing 

additional examples relevant to more 

modern issues and communicate the 

resolution of an investigation to the 

target of the investigation when a letter

of inquiry has been sent, and develop 

goals for resolving all sponsorship 

identification cases within a specified 

time frame. GAO provided FCC and 

FEC with a draft of this report. FCC 

indicated it will consider the

recommended actions and how to 

address the concerns discussed in the 

report. Both FCC and FEC provided 

technical comments.

What GAO Found

Sponsorship identification statutes and regulations, overseen by the Federal 

Communications Commission (FCC), require broadcasters to identify commercial 

content–-usually an advertisement, an embedded advertisement, or a video 

news release—that has been broadcast in exchange for payment or other 

consideration. A written or verbal sponsorship announcement must be made at 

least once during any sponsored commercial content except when the sponsor is 

obvious. For content considered political or that discusses a controversial issue, 

broadcasters must follow all requirements for commercial content and additional 

requirements, such as identifying officials associated with the entity paying for an 

advertisement. In addition, the Federal Election Commission (FEC) enforces 

federal election law that requires all political communications for a federal 

election, including television and radio advertisements, to include a disclaimer 

statement. FEC also oversees requirements to report campaign funding and 

expenditures, including funding for political advertising. FCC has guidance that 

helps broadcasters determine when a sponsorship announcement is needed, 

such as when a deejay receives a payment for airing specific content. While 

broadcasters consider this guidance useful, it addresses older technology that in 

some cases is no longer used. Furthermore, some broadcasters indicated that it 

would be helpful for FCC to clarify how the guidance applies in some situations, 

such as when a video news release or product is used during programming. 

According to FCC, it opened 369 sponsorship identification cases representing 

just over 1 percent of the Investigations and Hearings Division’s total cases 

opened from the beginning of 2000 through 2011. In 22 of these cases, FCC 

issued enforcement actions with varying types of violations and enforcement 

actions. While FCC follows standard procedures when addressing complaints, it 

does not inform the broadcaster named in the complaint of the outcome of the 

investigation in many cases. Most broadcasters we spoke with confirmed that 

FCC does not inform them of the status of investigations, and some indicated 

they currently do not know the status of several investigations. According to FCC, 

it does not communicate status with broadcasters named in complaints because, 

among other reasons, it has no legal obligation to do so. Broadcasters reported

the lack of information about cases and FCC decisions creates uncertainty about 

the propriety of their past actions. As a result broadcasters might not have 

sufficient information to determine whether they should modify their practices. 

This can result in stations’ editing content because of unwritten regulatory policy

or what they assume the policy to be. Moreover, these investigations can be 

lengthy, taking from 10 months to over 5 years to complete when an enforcement 

action is involved. From 2000 through May 2012, FEC opened 301 cases based 

on complaints alleging violations of political advertisement disclaimer 

requirements. FEC assessed civil penalties in 29 cases, 7 of which were related 

to television or radio advertisement disclaimers. Unlike FCC, FEC provides 

status updates to those involved in investigations and issues reports explaining 

investigation findings. FEC also issues reports explaining case dismissals.

These reports can clarify acceptable and unacceptable practices for the 

regulated community. View GAO-13-237. For more information, 

contact Mark Goldstein at (202) 512-2834 or 

goldsteinm@gao.gov. 
Page i GAO-13-237 Sponsored Programming Requirements

Letter 1 

Background 3

Sponsorship Identification Requirements Are Manageable, but FCC 

Guidance Could Be Clarified 9

FCC and FEC Follow Standard Procedures When Addressing All 

Complaints, but FCC Does Not Update Broadcasters Named in 

the Complaint 20

Conclusions 29

Recommendations 31

Agency Comments and Evaluation 31

Appendix I Objectives, Scope, and Methodology 33

Appendix II Comments from the Federal Communications Commission 35

Appendix III GAO Contact and Staff Acknowledgments 38

Tables

Table 1: Advertising Subject to Sponsorship Identification 

Requirements 6

Table 2: FCC Sponsorship Identification Cases within the 

Investigations and Hearings Division, 2000 through 2011. 22

Table 3: Length of Time for the Investigations and Hearing Division 

to Close Cases Involving a Letter of Inquiry and Resulting 

in an Enforcement Action. 25

Table 4: FEC Outcomes for Disclaimer Cases, January 1, 2000, 

through May 14, 2012 28

Figures

Figure 1: FCC Investigation and Enforcement Process for 

Sponsorship Identification Complaints 21

Figure 2: FEC Investigation and Enforcement Process for 

Disclaimer Complaints 26

Contents 
Page ii GAO-13-237 Sponsored Programming Requirements

Abbreviations

CATV community antenna television

CELA Office of Complaints Examination and Legal Administration

CGB Consumer and Governmental Affairs Bureau

FCC Federal Communications Commission

FEC Federal Elections Commission

VNR video news release

This is a work of the U.S. government and is not subject to copyright protection in the 

United States. The published product may be reproduced and distributed in its entirety 

without further permission from GAO. However, because this work may contain 

copyrighted images or other material, permission from the copyright holder may be 

necessary if you wish to reproduce this material separately.
Page 1 GAO-13-237 Sponsored Programming Requirements

United States Government Accountability Office 

Washington, DC 20548

January 31, 2013

The Honorable Nancy Pelosi

Democratic Leader

House of Representatives

The Honorable Henry Waxman

Ranking Member

Energy and Commerce Committee

House of Representatives

As broadcasters facing budget constraints make greater use of 

commercially sponsored content, such as commercial products as part of 

entertainment programs, some members of Congress are concerned that 

broadcasters are not properly disclosing sponsorship information to the 

public. The Federal Communications Commission (FCC) holds television 

and radio broadcasters to a basic principle, embodied in the 

Communications Act of 1934,1 as amended, that the public is entitled to 

know when and by whom it is being persuaded.2 Sponsorship 

identification statutes and regulations, overseen by FCC, require licensed 

broadcasters operating television and radio stations, as well as cable 

operators that originate programming, to disclose on-the-air when a party 

gives money or a payment in-kind for the broadcast of programming 

content.3

 

1

Act of June 19, 1934, ch. 652, 48 Stat. 1064, (Communications Act) (codified in title 47, 

United States Code).

In many cases, such as a standard 30 second product 

commercial, the sponsor of the content is obvious. However, as 

consumers make greater use of digital video recorders and other 

technologies that allow viewers to bypass commercials, advertisers turn 

to different approaches. For example, a news program may accept 

money to broadcast a pre-recorded segment on an allergy medication, or 

2

47 U.S.C. § 317. As we use the terms in this report, “broadcaster” means persons 

engaged in over-the-air transmissions as defined in 47 U.S.C.A. § 153(7); “cablecasting” 

refers to the widespread dissemination of content over a cable television or radio system 

but does not include the retransmission of broadcast content. 47 C.F.R. § 76.5(o). The 

origins of the sponsorship identification rules date from the beginning of licensing of radio 

transmissions in the Act of Feb. 23, 1927, ch. 169, § 19, 44 Stat. 1162, 1170, sometimes 

referred to as the Radio Act. 

3

An in-kind payment refers to goods or services provided in lieu of cash payment. 

 
 

Page 2 GAO-13-237 Sponsored Programming Requirements

a sitcom or reality show may accept money to prominently feature a 

brand of soft drink. In these situations, the product may be stated or 

obvious, but the fact that the product sponsor paid to have it included in 

the show may not be obvious. Similarly, FCC requires broadcasters to 

identify the individual or group truly responsible for funding an 

advertisement with political or controversial content. Thus, FCC’s 

sponsorship identification requirements apply to both commercial and 

political advertisements, but the requirements differ for each. In addition, 

all political advertising for federal elections must meet rules enforced by 

the Federal Election Commission (FEC). Similar to the changes 

broadcasters face with commercial advertising practices, recent changes 

in election campaign laws have had an impact on political advertising.

Although the FCC and FEC requirements serve different purposes—

protecting the radio and television listening and viewing public, on the one 

hand, and protecting the election process on the other—both direct 

disclosure of television and radio advertising sponsorship. Given the 

increase in use of sponsored content and changing rules associated with 

political content, you asked us to review FCC enforcement of sponsorship 

identification, federal election disclaimer requirements and other 

information that must be reported to FEC, and current industry practices. 

This report (1) describes the sponsorship identification requirements and 

guidance for commercial and political content, the federal election 

disclaimer requirements, as well as stakeholders’ views of these 

requirements and guidance, and (2) assesses how and to what extent 

FCC and FEC address sponsorship complaints through each agency’s 

enforcement process.

To describe the sponsorship identification requirements and guidance 

and obtain stakeholders views on these requirements and guidance, we 

reviewed sponsorship identification and disclaimer statutes and 

regulations enforced by FCC and FEC and interviewed officials from both 

agencies responsible for administering their respective requirements. We 

also reviewed relevant literature as far back as the Radio Act of 1927 and 

interviewed agency officials to understand the history of the statutes and 

regulations, their purposes, and how they differ for various media 

platforms and for different types of advertising. We interviewed over a 

dozen stakeholders that are subject to sponsorship identification 

requirements, have monitored broadcasters’ compliance with sponsorship 

identification requirements, or contributed research to the topic. These 

stakeholders included television and radio network officials, consumer 

representatives, academics, and trade associations to obtain their views 

of the effect of statutes and regulations and possible changes to them.
 

Page 3 GAO-13-237 Sponsored Programming Requirements

To determine how and to what extent FCC and FEC address sponsorship 

identification complaints, we interviewed FCC and FEC officials 

responsible for receiving, processing, and investigating complaints and 

analyzed relevant FCC and FEC documents describing agency methods 

and processes for identifying violations of sponsorship identification 

statutes and regulations, receiving sponsorship identification complaints, 

communicating with the complainant and subject of the complaint, 

initiating and conducting investigations, and taking enforcement action. In 

addition, we analyzed relevant FCC and FEC databases to describe 

sponsorship identification and disclaimer complaints, investigations, and 

enforcement actions from 2000 through 2011. We also analyzed FCC and 

FEC strategic plans and data describing the agencies’ respective goals 

for sponsorship identification and disclaimer statement complaint 

processing and enforcement and the agencies’ progress toward meeting 

their goals.

We conducted this performance audit from March 2012 through January 

2013 in accordance with generally accepted government auditing 

standards. Those standards require that we plan and perform the audit to 

obtain sufficient, appropriate evidence to provide a reasonable basis for 

our findings and conclusions based on our audit objectives. We believe 

that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our audit objectives. See appendix I for a more 

detailed explanation of our scope and methodology.

Federal law has required broadcasters to identify sponsors of radio 

program content since 1927.4

• In 1934, the Communications Act established FCC and gave it 

authority to administer sponsorship identification requirements for 

broadcasters, among other responsibilities, as well as creating 

additional sponsorship identification requirements.

Since that time, sponsorship identification 

requirements have been amended to expand and further define the 

requirements.

• In 1944, FCC adopted rules implementing the sponsorship 

identification requirements created in 1934. These rules, which 

 

4

The Act of Feb. 23, 1927, ch. 169, § 19, 44 Stat. 1162, 1170, sometimes referred to as 

the Radio Act.

Background
 

Page 4 GAO-13-237 Sponsored Programming Requirements

required a full and fair disclosure of the sponsor’s identity, remain 

largely unchanged.5

• In 1960, the Communications Act was amended to redefine the 

situations in which broadcasters must identify program sponsors.6 The 

need for this change arose due largely to the payola scandals of the 

late 1950s. The conference report accompanying the 1960 act 

included 27 case examples that were included to provide guidance on 

how the committee believed the sponsorship identification 

requirements should be applied.7

• In 1963, FCC adopted regulations implementing the 1960 

amendments8 and provided 36 sponsorship identification case 

examples as guidance.9

• In 1969, FCC adopted regulations applying sponsorship identification 

requirements modeled on the broadcast rules to cablecasting by 

community antenna television systems (CATV). Cablecasting was 

defined as “programming distributed on a CATV system which has 

been originated by the CATV operator or by another entity, exclusive 

of broadcast signals.”10

 

5

In the Matter of Promulgation of Rules and Regulations under Section 317 of the 

Communications Act,9 Fed. Reg. 14734 (1944).

6

Pub.L. No. 86-752, § 8(a), 74 Stat. 889, 895(1960). The House Report illustrated the 

revised rule by providing 27 examples. H. Rept. 1800, reprinted at 1960 U.S.C.C.A.N. 

3516, 3527-3532.

7

H. Rept. 1800, 86th Cong.

8

Amendment of Sections 3.119, 3.289, 3.654 and 3.789 of the Commission’s Rules, 34 

F.C.C. 829 (1963), amending 47 C.F.R.., §§ 3.119, 3.289, 3.654 and 3.789, which were 

subsequently reclassified by 28 Fed. Reg. 13,572, 13,672 (Dec. 16, 1963).

9

In Re Application of Sponsorship Identification Rules, 40 F.C.C. 141 (rel. May 6, 1963; 

pub. 1965. The 36 case examples included 27 that appear in the conference report and 9 

new examples created by FCC.)

10In the Matter of Amendment of Part 74, Subpart K, of the Commission’s Rules and 

Regulations, 20 FCC 2d 201, 223 (1969).
 

Page 5 GAO-13-237 Sponsored Programming Requirements

• In 1972, FCC updated its regulations to apply sponsorship 

identification requirements to programming under the exclusive 

control of cable television operators.11

• In 1975, FCC clarified the meaning of its 1944 requirement for full and 

fair disclosure of the identity of the sponsor, modifying its regulations 

to make clear that broadcasters and cablecasters12 are expected to 

look beyond the immediate source of payment where they have 

reason to know (or could have known through the exercise of 

reasonable diligence) that the purchaser of the advertisement is 

acting as an agent for another, and to identify the true sponsor.13

• In 1991, FCC adopted rules requiring visual and audible sponsorship 

identification announcement for televised advertisements concerning 

political issues.

14

• In 1992, FCC amended the requirements for advertisements 

concerning candidates by removing the requirement for an audible 

announcement and adopting specific criteria for a visual 

announcement.15

 

11In the Matter of Amendment of Part 74, Subpart K, of the Commission’s Rules and 

Regulations (Cable Television Report and Order), 36 F.C.C.2d 141, 215, 239-241 (1972). 

These rules, codified at 47 C.F.R. § 76.1615 apply to programming generated by a cable 

operator engaged in what the rule refers to as “origination cablecasting.” According to 

FCC official, FCC has never ruled on whether sponsorship identification rules apply to 

programming on cable networks. See In Re Request of A&E Television Networks for 

Declaratory Ruling, 15 FCC Rcd. 10796, 10800 n.2 (2000). 

The visual sponsorship identification announcement 

consist of letters at least 4 percent of the vertical picture height and 

that the statement be shown for at least 4 seconds.

12We use the term cablecaster to be synonymous with cable operators that create original 

cablecasting. Throughout the report references to cablecasting should be understood as 

references to origination cablecasting, i.e., the cablecasting subject to section 76.1615. 

The term “origination cablecasting” refers specifically to cablecasting on a cable television 

system over one or more channels subject to the exclusive control of the cable operator. 

47 C.F.R. § 76.5(p).

13In the Matter of Amendment of the Commission’s Sponsorship Identification Rules, 52 

FCC 2d 701, (1975), reiterating FCC’s earlier intention and rejecting the interpretation of 

its rule in United States v. WHAS, Inc., 385 F. 2d 784 (6th Cir. 1967), affirming United 

States v. WHAS, Inc., 253 F. Supp. 603 (D.Ky.1966).

147 FCC Rcd. 678 (1992).

15 7 FCC Rcd. 1616 (1992) (rule is codified at 47 C.F.R. §1212(a)(2)(ii)).
 

Page 6 GAO-13-237 Sponsored Programming Requirements

There have been no changes to the sponsorship identification statutes or 

regulations since 1992, although there have been more recent FCC 

cases affecting their interpretation and application.16

These sponsorship identification requirements generally apply to different 

types of advertising. Table 1 shows the range of different types of content 

that often require a sponsorship announcement, including commercial 

advertising where the sponsor is not typically apparent and political or 

controversial issue advertising where an announcement must meet 

additional requirements.

Table 1: Advertising Subject to Sponsorship Identification Requirements

Type of advertising Description

Commercial advertising Any programming intended to promote any service, 

facility or product offered.

Embedded advertising Showing or mentioning commercial products, through 

placement or integration into the dialogue or plot of a 

program in exchange for payment, products, or other 

inducement.

Video news releases Video programming that can be included as part of 

news programming. Such programming may use 

actors to play reporters or include suggested scripts 

for broadcasters and cablecasters to use when 

introducing stories and are provided to them without 

cost by outside entities.

Political advertising Any programming supporting or opposing any 

candidate for political office or discussing a political 

issue.

Advertising about a controversial 

topic

Any programming addressing a controversial matter 

of public importance or interest.

Source: GAO analysis. 

Presently, the Communications Act, as implemented by FCC, requires 

broadcasters and cablecasters to disclose to their listeners or viewers if 

content has been aired in exchange for money, services, or other 

inducement. For commercial content, such as advertisements, embedded 

 

16See, e.g., In the Matter of Sponsorship Identification Rules and Embedded Advertising,

23 FCC Rcd. 10682 (2008).
 

Page 7 GAO-13-237 Sponsored Programming Requirements

advertisements, and video news releases,17 the announcement must be 

aired when the content is broadcast and can be either a visual or an 

audible announcement. Political and controversial content must also have 

either type of announcement when aired on television, but candidate 

advertisements have specific visual requirements. In addition, when 

anyone provides or promises to provide money, services, or other 

inducement to include programming in a broadcast, that fact must be 

disclosed to the broadcaster or cablecaster. Both the person providing or 

promising to provide the money, services, or other benefits and the 

recipient must make this disclosure so that the station can broadcast the 

sponsorship identification announcement.18

The general public and to a lesser extent other sources, such as media 

public interest groups, file complaints with FCC about violations. Because 

of the high number of broadcasters and cablecasters, FCC relies on the 

public as an important source of information about compliance with 

requirements.19 The public is able to assist in monitoring broadcasters’ 

compliance with requirements because, as we will describe later in our 

finding on requirements, broadcasters are required to maintain a publicly 

available inspection file. This publicly available file lists pertinent 

information, such as quarterly issues and programs list, which describes 

the programs that have provided the station’s most significant treatment 

of community issues during the preceding 3 months.20

As part of its enforcement process, FCC investigates complaints about 

potential violations by broadcasters and cable operators of the statutes 

and rules it administers, including sponsorship identification complaints. 

Two bureaus within FCC—the Consumer and Governmental Affairs 

Bureau (CGB) and the Enforcement Bureau—are primarily responsible 

The public can 

access the public inspection file to check and monitor broadcasters’ 

compliance and service.

 

17Embedded advertisements, as well as, video news releases could contain political or 

controversial content. In this report, we discuss both only as they relate to commercial 

content because FCC and stakeholders, such as broadcasters and trade associations, 

primarily discuss both types of advertisements as related to commercial products.

1847 C.F.R. §§ 73.1212; 76.1615.

19FCC is not a monitoring agency but does conduct some on-site investigations and 

inspections in response to complaints and in support of its operations.

2047 C.F.R. § 73.3526(e)(12).
 

Page 8 GAO-13-237 Sponsored Programming Requirements

for developing and implementing procedures for processing complaints, 

conducting investigations, and taking enforcement actions. As part of its 

role of responding to consumer complaints and inquiries, CGB initially 

processes the majority of the complaints FCC receives. To the extent that 

a complaint is defective, for example, for failing to identify a particular 

broadcast, including its date, time of day, and the station on which it was 

aired, CGB will dismiss the complaint as incomplete and advise the 

complainant accordingly, providing guidance as to what information 

should be included in a complaint. CGB forwards most complaints

deemed complete to the Enforcement Bureau, but some complaints, 

including political sponsorship identification complaints go to the Media 

Bureau for further investigation.21

According to FEC, political committees buying political advertising 

supporting or opposing candidates for federal office must also meet 

requirements set by Federal Campaign Finance law. Advertisements paid 

for and authorized by a candidate, political committee, or their agents, 

must clearly state who has authorized and paid for the advertisement. 

Advertisements authorized by a candidate but paid for by someone else 

must identify who paid for and authorized the advertisement. 

Unauthorized advertisements must also identify the person who paid for 

the advertisement and must state that the communication is not 

authorized.

When FCC discovers violations it can 

take various enforcement actions dependent on the seriousness of the 

violation, such as admonishment, monetary forfeiture, or not renewing a 

broadcaster’s license.

22 FEC oversees the financing of elections for federal office23

 

21According to FCC officials, if a petition to deny a broadcast station’s renewal application 

raised questions regarding sponsorship identification rule violations (a rare occurrence), 

the Media Bureau would be responsible for the investigation, which would be similar to the 

process followed by the Enforcement Bureau. 

and ensures organizations and individuals authorizing political 

advertisements place the required statements, known as disclaimers, on 

222 U.S.C. § 441d.

23In 1975, Congress created FEC to administer and enforce the Federal Election 

Campaign Act of 1971, as amended. FEC is governed by six commissioners who 

are appointed by the President and confirmed by the Senate. Federal Election Campaign 

Act of 1971, Pub. L. No. 92-225, 86 Stat. 3 (1972), (codified as amended at 2 U.S.C. ch. 

14). The Federal Election Campaign Act was amended by the Bipartisan Campaign 

Reform Act of 2002, Pub. L. No. 107-155, 116 Stat. 81 (2002). All references to the 

Federal Election Campaign Act are to the 1971 act as amended.
 

Page 9 GAO-13-237 Sponsored Programming Requirements

the advertisements.24 The disclaimer requirements apply to any kind of 

communications media carrying public political advertising and are not 

limited to broadcast or cablecast advertisements.25

Similar to FCC, FEC initiates most enforcement activity pursuant to 

complaints received from the general public, including individuals and 

organizations associated with federal political campaigns. Complaints are 

filed with the Office of Complaints Examination and Legal Administration 

(CELA), which reviews the complaint to determine if the complaint states 

facts, identifies the parties involved, and provides or identifies supporting 

documentation. If the complaints are deemed sufficient, CELA informs the 

complainants that they will be notified once the case has been resolved. If 

FEC discovers violations, enforcement can include negotiated corrective 

action, including civil penalties, or other Commission initiated legal action 

seeking judicially imposed civil penalties or other relief.

As previously stated, sponsorship identification statutes and regulations 

require broadcasters and cablecasters to identify commercial content—

usually an advertisement, an embedded advertisement, or a video news 

release (VNR) that has been broadcast in exchange for money or 

payment in-kind. According to most broadcasters we spoke with, 

commercial content is fairly straightforward to identify, and they are 

accustomed to dealing with such content and report that compliance is 

manageable. For content considered political or discussing a 

controversial public issue, requirements, enforced by FCC and FEC, are 

more extensive and require more detailed on-air announcements and 

tracking of all related communications and agreements in a public file for 

FCC.26

 

242 U.S.C. § 441d. Identification of funding and authorizing sources is required for 

advertisements run over any broadcasting station, newspaper, magazine, outdoor 

advertising facility, mailing, or any other type of general public political advertising media. 

This includes Internet advertising, provided the posting of the advertisement is paid for by 

a disbursement of funds.

2511 C.F.R. § 100.26.

26Public files must be maintained by both broadcasters and cablecasters and contains 

information other than just materials related to political and controversial content. 47 

C.F.R. §§ 73.3526 (commercial), 73.3527 (noncommercial), and 76.79 (cable public file 

requirements, generally). 

Sponsorship 

Identification 

Requirements Are 

Manageable, but FCC 

Guidance Could Be 

Clarified
 

Page 10 GAO-13-237 Sponsored Programming Requirements

According to FCC, commercial advertisements do not always require a 

sponsorship announcement. FCC does not require an announcement 

when an obvious connection exists between the content and sponsor, 

such as with a standard commercial advertisement. For all commercial 

advertisements where the true sponsor is not apparent, even for 

infomercials that may be 30 minutes or longer, FCC requires a written or 

verbal announcement to occur only once during the program.27 This 

announcement must fully and fairly disclose the true identity of those who 

are paying for the advertisement.28 In addition, whenever an individual, 

such as a deejay, receives money or payment in-kind for airing specific 

content or favorably discussing a specific product a sponsorship 

announcement must be made. Therefore, station employees must 

disclose such transactions to the station.29 Thus, if a record company or 

its agent pays a deejay to play records or talk favorably about an artist or 

record on the air, and he does so, the result is considered sponsored 

content. FCC guidance directs that the deejay must reveal the payment to 

the broadcaster and a sponsorship announcement must be made when 

the content goes on-the-air.30

Embedded advertisements—typically, when a commercial product is 

provided without charge to use in entertainment programming—may not 

require a sponsorship announcement if they are reasonably related to the 

show. Since many consumers now record shows or change the channel 

during commercials, broadcasters have increased their use of embedded 

advertising. However, a sponsorship announcement is not required every 

time a product appears in a program. For example, FCC’s guidance 

describes scenarios in which a manufacturer provides a car to a television 

show for a detective to chase and capture the villain, and states that the 

use of the car alone would not require a sponsorship announcement. In 

According to broadcasters, industry trade 

groups, and others we spoke with, compliance with these standards and 

requirements is not a problem because the requirements are part of their 

standard review process.

 

2747 C.F.R. § 73.1212(f) and see Application of Sponsorship Identification Rules to 

Political Broadcasts, Teaser Announcements, Governmental Entities and Other 

Organizations, Public Notice, 66 FCC. 2d 302 (1977).

2847 C.F.R. §§ 73.1212(e) (for broadcast material), 76.1701(e) (for cablecast material).

2947 U.S.C. §508(a)-(c). 

3040 F.C.C. 141, 145, example 4. 

FCC’s Sponsorship 

Identification 

Requirements for 

Commercial Content
 

Page 11 GAO-13-237 Sponsored Programming Requirements

this scenario the use of the car could be considered “reasonably related” 

to its use in the show. However, in the same scenario, if a character also 

made a promotional statement about the specific brand—such as its 

being fast—FCC requires a written or verbal sponsorship announcement 

sometime during the program.31

VNRs are another type of commercial content which may require a 

sponsorship announcement. VNRs are pre-packaged news stories that 

may include only film footage or may also include suggested scripts. 

However, broadcasters do not always use a VNR in its entirety but may 

use portions of the video. For example, if a news story about car 

manufacturing could benefit by showing video from inside a 

manufacturing plant, a broadcaster may use footage from a VNR because 

it cannot easily access the interior of a plant during its operations.

According to FCC’s guidance, in this 

second scenario, the specific mention of the brand may go beyond what 

would be “reasonably related” to its use in the show. The reasonably 

related standard requires some assessment of the content. Broadcasters 

told us they have processes in place to review content on their networks 

to determine if a program needs a sponsorship announcement for an 

embedded advertisement.

According to FCC, it requires broadcasters to air a sponsorship 

announcement when using VNRs, even when they are provided free of 

charge, under the same circumstances as it would require a sponsorship 

identification for other programming. When a film or a story was provided 

by a third party and it conveys value to the station, it must have either a 

verbal or written sponsorship announcement, if it is furnished in 

consideration for identification of a product or brand name beyond what is 

reasonable related to the broadcast.

32

 

3140 F.C.C. 141, example 17, (1963). 

This is an update to the guidance 

FCC issued in its 2005 Public Notice concerning the use of VNRs. In that 

Public Notice, FCC reminded broadcasters of their obligation to comply 

with sponsorship identification requirements when using VNRs and that 

there must be an announcement to the audience about the source and 

3247 C.F.R. § 73.1212(a)(2). FCC guidance for political or controversial materials directs

that any free content must still have a sponsorship announcement. 47 C.F.R. § 73.1212(d) 

(for broadcast material), § 76.1615(c) (for cablecast material). For recent case law in this 

area, see e.g.,In the Matter of Fox Television Stations, Inc., 26 FCC 3964 (2011).
 

Page 12 GAO-13-237 Sponsored Programming Requirements

sponsorship of the VNR.33

Most broadcasters we spoke with indicated the sponsorship identification 

requirements are generally manageable as part of their review processes. 

As previously indicated, broadcasters told us they have processes in 

place to review the different types of advertisements and other 

programming aired. These reviews check to ensure the advertisement or 

programming meets FCC requirements, including the sponsorship 

identification requirements. Since it is part of the standard content review 

process and the sponsorship identification requirements have not 

changed for many years, broadcasters told us the requirements were not 

difficult to meet.

Nevertheless, some broadcasters disagree 

with FCC’s position and believe it should treat VNRs similar to press 

releases and not require a sponsorship announcement if a broadcaster 

did not pay for the material and uses only a portion of its content. For 

example, in the previous illustration, a broadcaster may use VNR footage, 

because it does not have access to the interior of a car manufacturing 

plant. In such instances, FCC requires broadcasters to make an 

announcement that could appear on the screen during the footage 

stating, “Footage furnished by ABC Motor Company” or as a verbal or 

written announcement at the end of the program. Broadcasters we spoke 

with had differing opinions on whether to use VNRs. While one 

broadcaster believes it should be up to the news program to determine if 

an announcement is needed, others we spoke with were divided about 

whether to use VNRs with a sponsorship announcement or to never use 

VNRs at all. Some broadcasters and others reported the use of VNRs has 

been increasing, in part, because of tighter news budgets and the need to 

fill airtime. In recent years, instances of VNR use without proper credit 

have been reported and investigated by FCC; we will discuss these 

instances later in our report.

 

33Federal Communications Commission, Public Notice: Commission Reminds Broadcast 

Licensees, Cable Operators and Others of Requirements Applicable to Video News 

Releases and Seeks Comment on the Use of Video News Releases by Broadcast 

Licensees and Cable Operators, 20 FCC Rcd. 8593 (2005). 
 

Page 13 GAO-13-237 Sponsored Programming Requirements

Political content and content discussing a controversial issue of public 

importance are subject to all requirements that commercial content must 

follow but have additional on-air and public file sponsorship identification 

requirements. Advertisements that contain political content or involve 

public discussion of a controversial issue must include a sponsorship 

announcement at the beginning or end of the program. If the program is 

longer than 5 minutes, the announcement must be made at both the 

beginning and end of the program. For broadcast television and political 

content discussing a candidate, a visual announcement must be made 

that is at least equal to 4 percent of the screen height must exist and lasts 

4 seconds. For broadcast radio, there must be an audible 

announcement.34

In addition to the requirement for on-air disclosure of the identity of those 

who are paying for the advertisement, broadcasters and cablecasters are 

also required, where payment is not being made by an individual, to 

maintain a list of the Chief Executive Officers, or members of the 

Executive Committee or Board of Directors of the corporation or other 

entity who paid for the advertisement.35

 

3447 U.S.C. § 315; 47 C.F.R. §§ 73.1212 (for broadcast material), 76.1615 (for cablecast 

material).

 These lists are kept as part of the 

public inspection files broadcasters and cable operators are required to 

maintain, which includes a file for political advertising information known 

as the “political file.” The political file also documents information 

pertaining to candidate-purchased advertisements. This includes 

communications and agreements to air political advertisements and 

programming, including information on times agreed to and rates paid by 

advertisers. Most of the public inspection file is information that is 

available only at the station or operator’s place of business, although 

since August 2012, FCC has required that some television stations post 

their political file at an FCC-hosted website and that all television stations 

3547 C.F.R. §§ 73.1212(e) (for broadcast material), 76.1701(e) (for cablecast material). 

FCC Sponsorship 

Identification 

Requirements for Political 

and Controversial Content
 

Page 14 GAO-13-237 Sponsored Programming Requirements

post a majority of their public file on this website by February 2013, 

making the file more easily accessible to the general public.36

According to FEC, paid political communications supporting or opposing 

candidates for election to federal office, which include radio and television 

advertisements, are required to contain what are called “disclaimer 

statements.”37 FEC enforces these election advertising disclaimer 

statutes and regulations. Television and radio political advertisements 

authorized and paid for by a federal candidate or his or her campaign 

committee or another organization must include a disclaimer spoken by 

the candidate identifying him or herself and stating that he or she 

approved the advertisement, as well as a statement identifying the 

organization that paid for the advertisement. Television advertisements 

must either show the candidate making the disclaimer statement or show 

a clearly identifiable image of the candidate during the statement. They 

must also include a clearly readable written statement similar to the 

verbal statement that appears at the end of the advertisement for at least 

4 seconds. Certain advertisements not approved by a candidate or his or 

her committee must identify who paid for the advertisement, state that it 

was not authorized by any candidate or candidate’s committee, and list 

the permanent street address, telephone number, or World Wide Web 

address of the person who paid for the communication.

 

36In May 2012, the National Association of Broadcasters filed a petition with a Federal 

District Court seeking relief from the FCC requirement for broadcasters to file political 

advertising information on-line in their public files. National Association of Broadcasters v. 

FCC, filed May 21, 2012 (DC Dir. No. 12-1225). An National Association of Broadcasters 

request for a stay delaying the implementation of the requirements was denied. National 

Association of Broadcasters v. Federal Communications Commission (D.C. Cir. No. 12-

1225, July 27, 2012). On September 18, 2012, the court granted NAB’s request to defer 

the briefing schedule for its petition for review, and on January 18, 2013 NAB filed a 

further motion to hold its case in abeyance. (D.C. Cir. No.12-1225). As of issuance of this 

report, the case was not resolved. The public file and political file data are available on an 

FCC hosted website (last accessed January 23, 2013) https://stations.fcc.gov/. 

372 U.S.C. § 441d. Identification of sources funding and authorizing advertising is required 

for advertisements run over any broadcasting station, newspaper, magazine, outdoor 

advertising facility, mailing, or any other type of general public political advertising.

FEC Disclaimer 

Requirements
 

Page 15 GAO-13-237 Sponsored Programming Requirements

In addition to monitoring compliance with these disclaimer requirements, 

FEC serves as a repository for campaign finance data for candidates for 

political office.38 Just as stations licensed by FCC are required to 

preserve records to establish that they are meeting their responsibility, 

among others, to treat political candidates running for the same public 

office equally, FEC oversees requirements to report campaign funding 

and expenditures. Individuals, political committees, and other 

organizations supporting or opposing candidates for federal office are 

required to report campaign funding and expenditures for certain

activities, which can include payments made for purchasing political 

advertising and information on the funds they receive for 

advertisements.39 This reporting is done to assure that money is being 

collected and spent in accordance with federal election campaign law.40

The reporting requirements vary according to the purpose of the 

advertisement, who paid for the advertisement, and whether it is the 

product of a coordinated effort between political committees and others.

41

 

38The January 21, 2010, Supreme Court ruling in Citizens United v.FEC, 558 U.S. 310, 

overturned a portion of the Bipartisan Campaign Reform Act, holding that the government 

may impose disclaimer and disclosure requirements but may not suppress corporate 

political speech by restricting corporations’ and labor organizations’ funding certain 

political advertisements. 

The political committees are always subject to the reporting requirements 

and must submit itemized reports to FEC showing all of their 

expenditures, including advertising. Political committees must also submit 

itemized reports to FEC showing contributions received, including 

contribution amounts, dates, and contributor names and addresses. FEC 

has also required organizations and individuals to report expenditures for 

political advertisements and donations of $1,000 or more made for certain 

political advertisements, called “electioneering communications,” which 

39Federal Election Commission, FEC and Federal Campaign Finance Law Brochure, 

(Washington, D.C.: February 2011) and Federal Election Commission, Coordinated 

Communications and Independent Expenditures Brochure, (Washington, D.C.: February 

2011). 

4011 C.F.R. §§ 104.3, 104.20. 

41A coordinated effort between organizations means two organizations getting together to 

fund political advertising, such as political action committees. 

Reporting Political 

Advertising Financing
 

Page 16 GAO-13-237 Sponsored Programming Requirements

are related to elections for federal office and broadcasts within specified 

time frames before the elections.42

As described in FEC’s guidance, FEC administers specific reporting 

requirements for those making electioneering communications, which can 

include political advertisements on television or radio. Specifically, 

electioneering communications refers to any broadcast, cable, or satellite 

communication that refers to a candidate for federal office and is 

distributed within specific time frames before a federal general election or 

federal primary election.43 Political advertisements that do not meet these 

specifications are not subject to these reporting requirements. Once 

payments for electioneering communications, including television or radio

advertisements, exceeds $10,000 in any calendar year, those responsible 

for them must report payments and the sources of funds used to FEC 

within 24 hours of each broadcast.44

• the person or organization that made the payments, including their 

principal place of business;

Each report must, among other 

things, identify:

• any person sharing or exercising direction or control over the activities 

of the person who made the payments;

 

4211 C.F.R. § 104.20. FEC requires corporations or labor organizations that make 

electioneering communications to disclose the name and address of each person who 

made a donation aggregating $1,000 or more to a corporation or labor organization, but 

only those made for the purpose of furthering electioneering communications. 11 C.F.R. § 

104.20(c)(9). This regulation was challenged in Van Hollen v. FEC, 851 F.Supp.2d 69 

(D.D.C. 2012). The plaintiff alleged that the regulation is inconsistent with a provision of 

the Bipartisan Campaign Reform Act (BCRA), § 201, codified at 2 U.S.C. § 434(f). Van 

Hollen v. FEC, Civil Action No. 11-0766 (ABJ) (D.D.C. 2011) (“complaint”). The plaintiff 

contended that the BRCA provides that all electioneering communications must be 

disclosed and that there are no terms limiting that requirement to those who expressly 

stated that their contribution was to be used to fund electioneering contributions. Van 

Hollen, 851 F.Supp.2d, at 80. On plaintiff’s motion for summary judgment, the District 

Court found that “Congress spoke plainly [and] did not delegate authority to the FEC to 

narrow the disclosure requirements through agency rulemaking.” Van Hollen, 851 

F.Supp.2d, at 89. The United States Court of Appeals for the D.C. Circuit disagreed, 

reversed the lower court’s summary judgment and remanded the case to that court. See

Center for Individual Freedom v. Van Hollen, 694 F.3d 109 (DC Cir. 2012). As of January 

11, 2013, the litigation was ongoing. For more information, see 

www.fec.gov/law/litigation/van_hollen.shtml (last visited January 11, 2013). 

43These rules apply for certain radio and television advertisements within 60 days of a 

general election and within 30 days of a primary election. 11 C.F.R. § 104.20(b); 100.29. 

442 U.S.C, § 434(f)(1); 11 C.F.R. § 104.20(b).
 

Page 17 GAO-13-237 Sponsored Programming Requirements

• the amount of each payment in excess of $200, the payment dates, 

and the payee;

• all candidates referred to in the advertisements and the elections in 

which they are candidates; and

• the name and address of each person who donated $1,000 or more 

since the first day of the preceding calendar year to those responsible 

for the advertisement.45

According to FEC, “coordinated communications” are contributions for 

communications that are coordinated with a candidate or party 

committee. These contributions are subject to amount limitations, source 

prohibitions, and reporting requirements under the Federal Election 

Campaign Act.46

• their names, mailing addresses, occupations, and employers;

Expenditures for communications that are not 

coordinated, also known as independent expenditures, have 

requirements to report itemized payments for the advertisements that are 

triggered if they expressly advocate the election or defeat of a clearly 

identified candidate. While independent expenditures are not subject to 

spending limitations, they are subject to the reporting requirements. 

Those responsible for the payments must report:

• the name and mailing address of the person to whom payments were 

made;

• the amount, date, and purpose of each payment;

• a statement indicating whether each payment was in support of, or in 

opposition to, a candidate, together with the candidate’s name and 

office sought; 

• the identification of each person who made a contribution in excess of 

$200 for the purpose of making a coordinated advertisement; and

• a verified certification as to whether such expenditure was made in 

cooperation, consultation, or concert with, or at the request or 

suggestion of a candidate, a candidate’s authorized committee, or its

agents, or a political party committee or its agents.47

 

452 U.S.C, § 434(f)(2); 11 C.F.R. § 104.20(c).

46Corporations, labor unions, individuals and businesses with federal government 

contracts, foreign citizens, and qualified non-profit corporations are prohibited from 

coordinating these advertisements. 

4711 C.F.R. §§ 104.3(b)(3)(vii) and 109.10(e). 
 

Page 18 GAO-13-237 Sponsored Programming Requirements

FCC provides guidance on meeting sponsorship identification 

requirements, which broadcasters we spoke with generally report to be 

helpful. Broadcasters we spoke with told us they apply the sponsorship 

identification requirements many times a day during reviews of programs 

and when preparing news programs. This process involves network 

employees viewing all content, and if a program appears to focus too 

much on a product, then the broadcaster will ask the producer of the 

content for a sponsorship announcement. Broadcasters we spoke with 

indicated they tend to be cautious in reviewing and identifying sponsored 

content in order to avoid enforcement actions.

The guidance issued in FCC’s 1963 report and order has remained 

substantially unchanged,48 and while many broadcasters indicate the 

guidance is still useful, it addresses issues with older technology that may 

no longer be relevant and does not discuss how the rules apply to newer 

technologies. Specifically, one case example discusses a broadcaster’s 

use of a kinescope recording of a congressional hearing provided by a 

third party.49 The guidance states that “expensive kinescope prints 

dealing with controversial issues are being paid for by someone,” and 

therefore the broadcaster should determine who and make a sponsorship 

announcement. While this case example provides guidance for the use of 

content discussing a controversial issue, which clearly falls under the 

sponsorship identification requirements, the cost of creating such content 

is less of an issue today. We have previously reported on the benefits of 

revisiting provisions of regulatory programs to determine if changes might 

be needed to better achieve the program’s goals.50

 

48In 1975, FCC revised one case example to reflect changes to FCC’s rules. Applicability 

of Sponsored Identification Rules, 53 F.C.C.2d 368 (1975).

Current technologies, 

such as digital video equipment and the Internet, allow similar content to 

be created and distributed and it is often publicly available at no cost and 

the rules are not clear how the rules apply in these situations. FCC 

officials told us the agency has not updated the guidance because there 

has been no need to update it. Rather, FCC officials said they have relied 

on case law and public notices, among other devices, to provide guidance 

to broadcasters and cablecasters.

49A kinescope is a recording of a television program made by filming the picture from a 

video monitor.

50GAO, Regulatory Reform: Prior Reviews of Federal Regulatory Process Initiatives 

Reveal Opportunities for Improvements, GAO-05-939T (Washington, D.C.: July 27, 2005). 

FCC Guidance for 

Commercial, Political, and 

Controversial Content
 

Page 19 GAO-13-237 Sponsored Programming Requirements

However, some broadcasters indicated that FCC could clarify how the 

guidance applies in specific situations, such as when a VNR or product is 

used but the broadcaster was not paid. In its Public Notice issued in 

2005, FCC reminded broadcasters and cablecasters of their sponsorship 

identification obligations and indicated that VNRs generally need a 

sponsorship announcement. 51 According to FCC’s enforcement reports, 

its enforcement actions against broadcasters’ and cablecasters’ use of 

VNRs have involved cases where the footage and script of a VNR 

focused too much on a specific brand or product, beyond what was 

reasonably related to the story. FCC told us these cases indicate that 

VNRs should be following the same rules regarding sponsorship 

identification as other programming. However, some stakeholders argue 

VNRs are similar to press releases because they are often provided for 

with no money or payment in-kind including no understanding or 

agreement that they will be broadcast on-the-air. According to FCC 

guidance, a press release does not need a sponsorship announcement.52

Some broadcasters indicated they remain unsure of when there needs to 

be a sponsorship announcement as part of a VNR. As a result, FCC’s 

interpretation and the broadcasters’ interpretation of how the 

requirements apply to VNRs remain vastly different, in-part because no 

payment is made to the broadcaster to air the VNR. The Public Notice in 

2005 sought comment on a number of issues related to the use of VNRs 

and also indicated FCC intends to issue a report or initiate a formal 

proceeding based on the comments received.53 As of the issuance of this 

report, however, FCC has taken no further action in response to the 

comments received.

 

51 Public Notice (20 FCC Rcd. 8593). 

5240 FCC 141. 

53Public Notice (20 F.C.C. Rcd. 8593). 
 

Page 20 GAO-13-237 Sponsored Programming Requirements

FCC’s investigation and enforcement process generally begins with a 

complaint to the agency that will be reviewed by the CGB and may be

forwarded to the Enforcement Bureau if the complaint is complete. As 

previously indicated, FCC receives complaints primarily through the CGB. 

Since 2003, FCC has received over 200,000 complaints of all types 

annually through CGB, some of which it dismisses as incomplete. Others, 

including sponsorship identification complaints deemed to be complete 

are forwarded to the Enforcement Bureau for possible investigation and 

enforcement. Complaints involving non-political sponsorship identification 

issues are forwarded to the Enforcement Bureau; but complaints raising

political sponsorship identification issues go to the Media Bureau.

When the Enforcement Bureau receives a complaint, the bureau 

conducts several reviews prior to being classified as a sponsorship 

identification complaint and prior to contacting the broadcaster named in 

the complaint, as shown in figure 1. First, if a complaint is related to an 

alleged sponsorship identification violation, the complaint goes to the 

Investigations and Hearings Division where a manager conducts a review 

of the complaint. If the manager determines the subject of the complaint 

to be sponsorship identification related or related to another topic handled 

by the Investigations and Hearings Division, then the complaint is 

assigned to an attorney. The attorney enters it into the database at which 

time it is considered a case and can be classified as related to 

sponsorship identification. A case may be linked to numerous complaints, 

or a case may be opened even though FCC received no complaints.54

 

54An FCC case may be opened because of its own research or a congressional inquiry.

For 

FCC and FEC Follow 

Standard Procedures 

When Addressing All 

Complaints, but FCC 

Does Not Update 

Broadcasters Named 

in the Complaint

FCC Investigation and 

Enforcement Process
 

Page 21 GAO-13-237 Sponsored Programming Requirements

example, in 2007, FCC received over 18,000 complaints and opened 3 

sponsorship identification cases in response to a single incident wherein 

a nationally syndicated radio and television host discussed the “No Child 

Left Behind” program and did not disclose that the discussion was 

sponsored.

Figure 1: FCC Investigation and Enforcement Process for Sponsorship 

Identification Complaints

As shown in table 2, according to FCC, it opened 369 sponsorship 

identification cases from the beginning of 2000 through 2011, 

representing just over 1 percent of the total cases the Investigation and 

Hearings Division opened during that time period.55

 

55These are cases that were directly received by the Enforcement Bureau, reviewed by 

the Investigative and Hearings Division, and entered into the database. This may miss 

some complaints if they came through another division of FCC and were never entered 

into the database.

According to FCC 

officials, after opening a case, the attorney conducts a more substantive 

review to determine if the allegations in the complaint, if true, would 
 

Page 22 GAO-13-237 Sponsored Programming Requirements

constitute a possible violation of any statutes or regulations. If warranted, 

the attorney may contact the complainant for more information. If it is 

determined that no violation occurred or can be supported, the case may 

be closed following the substantive review, by making a note in the case 

file. If this substantive review determines a violation may have occurred, 

then FCC will send a letter of inquiry to the broadcaster named in the 

complaint initiating an in-depth investigation. As shown in table 2, 101 

cases were closed following a substantive review and prior to a letter of 

inquiry being sent.

Table 2: FCC Sponsorship Identification Cases within the Investigations and 

Hearings Division, 2000 through 2011.

Conclusion of sponsorship identification cases Number of casesa

Cases with a letter of inquiry sent 242

Closed cases with no letter of inquiry sent 101

Total sponsorship identification cases 369

Source: FCC Data.

a

According to FCC, the number of cases closed without a letter of inquiry (101) and the number of 

cases for a letter of inquiry has been issued (242) does not add up to the total number of cases 

identified as sponsorship identification cases (369) because some cases may be consolidated for the 

purposes of a letter of inquiry and other cases may not yet be closed in the database, although no 

letter of inquiry has been issued. 

If a case proceeds to a letter of inquiry being sent, the letter serves as a 

notification to the broadcaster named in the complaint that it is under 

investigation. The letter of inquiry requests specific information 

concerning the complaint, such as a video of the broadcast. As shown in 

table 2, from 2000 to 2011, FCC sent 242 letters of inquiry for 

sponsorship identification cases. Next, FCC reviews the information 

provided by the broadcaster named in the complaint in response to the 

letter of inquiry. If FCC determines that a violation of the sponsorship 

identification requirements did not occur or cannot be proven, it can close 

the case. As with the process of closing a case prior to sending a letter of 

inquiry, FCC closes the case by making a note in the case file but 

typically does not inform the broadcaster named in the complaint. From 
 

Page 23 GAO-13-237 Sponsored Programming Requirements

2000 through 2011, FCC reported it closed 195 cases with no 

enforcement action following a letter of inquiry.56

In other cases, following the letter of inquiry, FCC may determine that a 

violation occurred and seek an enforcement action. Since 2000, FCC has 

issued enforcement actions in 22 sponsorship identification cases with 

varying types of violations and enforcement actions. For example, in 2011 

FCC issued a notice of apparent liability to KMSP-TV in Minnesota, for 

airing a VNR without identifying the sponsor of the release. KMSP-TV 

was fined $4,000. In 2007, FCC issued a notice of apparent liability to 

Sonshine Family television for airing five different episodes of programs 

on ten separate occasions, during which an individual discussed the 

federal “No Child Left Behind” program. Sonshine was fined $40,000 

because the station failed to identify the sponsor of the content. Since 

2000, FCC has also agreed to 10 consent decrees with different 

broadcasters that include the broadcaster’s adopting a plan for 

compliance and making a voluntary contribution to the United States 

Treasury. The voluntary payments to the Treasury have varied in 

amounts, from as little as $12,000 for a pay-for-play incident to as much 

as $4 million a separate but similar incident.

While most complaints do not end with an enforcement action, FCC 

generally does not communicate with the broadcaster named in the 

complaint when it closes sponsorship identification investigations. As 

previously indicated, the letter of inquiry notifies the broadcaster named in 

the complaint that an investigation is under way but following that 

communication FCC does not provide any information on the 

investigation unless the case results in an enforcement action. GAO has 

previously reported that FCC enforcement actions can help correct 

identified compliance problems and deter future noncompliance.57

 

56According to FCC, the number of cases closed with a letter of inquiry sent and closed 

with no enforcement action (195) and the number of cases with a letter of inquiry sent and 

closed with an enforcement action (22) does not add up to the total number of cases with 

a letter of inquiry sent (242) because cases may be merged when being resolved.

Similarly, informing a broadcaster under investigation that a matter has 

been closed could help inform broadcasters about compliant activities. 

Furthermore, while not specifically related to sponsorship identification 

issues, in an effort to promote open government and public participation, 

57GAO-08-125 (p.20).
 

Page 24 GAO-13-237 Sponsored Programming Requirements

the administration has developed a plan to increase openness in the 

government.58

According to FCC officials, they do not communicate with the broadcaster 

named in the complaint because, among other reasons, FCC has no legal 

obligation to do so. In addition, FCC officials identified several other 

factors as to why it does not communicate with the broadcaster named in 

the complaint. First, FCC officials told us it does not want to inform the 

broadcaster named in the complaint a case was closed because it may 

want to reopen the case if new evidence presents itself. Second, officials 

also said that FCC does not want closing a case to be inaccurately 

interpreted as an endorsement of the action being investigated even if the 

investigation does not result in a finding of a violation. Finally, officials 

indicated informing the broadcaster named in the complaint about closure 

of an investigation would require crafting a letter tailored to fit the unique 

set of facts and requirements for each case. This would be resource 

intensive, and according to FCC officials, FCC does not have sufficient 

resources to implement such practices.

The plan includes an initiative to enhance enforcement of 

regulations through further disclosure of compliance information. This 

builds on previous guidance to use increased disclosure to provide 

relevant information to help make decisions. It further directs agencies to 

develop plans for providing greater transparency about their enforcement 

activities and for making such information available online. However, 

broadcasters we spoke with confirmed that FCC does not inform them of 

the status of investigations, and some indicated they currently do not 

know the status of several investigations. They reported the lack of 

information about cases and FCC decisions creates uncertainty about the 

propriety of their past actions. In addition, this practice of not informing 

broadcasters about the results of investigations does not align with the 

administration’s goals to disclose compliance information to help 

regulated entities make decisions. As a result, broadcasters might not 

have sufficient information to determine whether they should modify their 

practices. This could result in stations unnecessarily editing content 

because of unwritten regulatory policy or what they assume the policy to 

be.

 

58The Open Government Partnership: National Action Plan for the United States of 

America, September 20, 2011.
 

Page 25 GAO-13-237 Sponsored Programming Requirements

FCC sponsorship identification investigations can be lengthy, according to 

FCC data, taking from 10 months to over 5 years to complete. As shown 

in table 3, the shortest time period for resolution of a case with an 

enforcement action, was 10 months. The process to negotiate a consent 

decree takes longer because it often involves complex negotiations 

between FCC and a broadcaster. Even when the investigation sends a 

letter of inquiry and results in no enforcement action, according to FCC 

officials, the median length of time to close investigations was 38 months 

for approximately 200 cases. In 2011, FCC set a performance goal to 

resolve 90 percent of sponsorship identification cases within 15 months. 

According to FCC officials, FCC missed its goal by a few days although 

officials could not provide data to support this. Specific goals about 

timeliness of investigations provide better service for regulated entities, 

but in 2012 and 2013 FCC removed this goal.

Table 3: Length of Time for the Investigations and Hearing Division to Close Cases 

Involving a Letter of Inquiry and Resulting in an Enforcement Action.

Enforcement action

Total 

cases

Shortest case 

(total months)

Longest case 

(total months)

Notice of apparent liability 4 10 52

Consent decree 10 20 61

Source: FCC data. 

As previously stated, paid political advertisements require disclaimer 

statements and FEC’s enforcement process begins typically with a 

complaint to CELA. FEC receives most disclaimer complaints from the 

public. As shown in figure 2, complaints proceed through several 

procedural steps, including a review and vote by the FEC commissioners. 

CELA reviews the complaint for compliance with required criteria, 

including ensuring it identifies the parties involved, involves a violation of 

campaign finance law, and provides supporting documentation. If a 

complaint does not meet these criteria, CELA notifies the complainant of 

the deficiencies and informs them that no action can be taken pursuant to 

the complaint unless those deficiencies are resolved. If the complaint 

meets the criteria, CELA informs the complainant that they will be notified 

when the matter has been resolved. From 2000 through May 15, 2012, 

FEC opened 301 cases based on complaints alleging violations of 

disclaimer statement requirements. The cases were based on complaints 

alleging violations of the disclaimer requirements for advertisements 

using various media, including television and radio, letters, and billboards. 

For example, in 2006, a complaint alleged a television advertisement for a 

FEC Investigation and 

Enforcement Process
 

Page 26 GAO-13-237 Sponsored Programming Requirements

congressional candidate in Ohio failed to include an oral statement that 

identifies the candidate and states that the candidate has approved the 

communication. Less than 17 percent of the complaints alleging violations 

of disclaimer statement requirements involved television or radio 

disclaimer requirements.

Figure 2: FEC Investigation and Enforcement Process for Disclaimer Complaints

a

If the complaint does not meet the criteria the complaint may be revised by the complainant. In those 

situations the complaint would start the process over. 
 

Page 27 GAO-13-237 Sponsored Programming Requirements

b

At this point in the process OGC must review and recommend dismissal and the Commission must 

agree. If the Commission does not agree to dismiss it would then go to the Commission for a “reason 

to believe” vote. 

c

If a conciliation agreement is not successfully negotiated the complaint would return to the 

Commission for a vote on whether there is “probable cause to believe” and could eventually go to 

litigation. This is not a common occurrence with disclaimer complaints. 

Prior to taking any action other than dismissing a complaint, FEC 

provides the entity named in the complaint at least 15 days to respond

and demonstrate that no violation occurred. After the response period, 

FEC’s Office of General Counsel evaluates the complaint and response 

and may refer the case to the Alternative Dispute Resolution Office. This 

office provides solutions for settling cases in lieu of litigation and allows 

FEC to settle the case early in the enforcement process. While alternative 

dispute resolution avoids the litigation process, the entity named in the 

complaint must commit to terms for participation in an alternative dispute 

resolution, which include setting aside the statute of limitations and 

participating in negotiations to settle the case, among other conditions. 

Alternative dispute resolution settlements generally require entities 

named in the complaints to take corrective action, such as hiring 

compliance specialists, designating persons as responsible for disclosure, 

and attending educational conferences. Generally, FEC does not refer 

cases for alternative dispute resolution that are highly complex but does 

refer cases that could include incidents where FEC believes there was 

knowing and willful intent to commit violations or potential violations in 

areas that FEC has set as priorities.

For cases not recommended for alternative dispute resolution, FEC 

Commissioners vote before an investigation is initiated. The Federal 

Election Campaign Act requires that FEC find reason to believe that a 

person has committed, or is about to commit, a violation as a precondition 

to opening an investigation into an alleged violation.59

 

592 U.S.C. § 437g(a)(2). 

Should the 

Commissioners’ vote to find reason to believe a violation occurred, FEC 

and the alleged violator can negotiate a conciliation agreement that can 

include a monetary penalty or corrective action. If the Commission needs 

additional information prior to settling a case using a conciliation 

agreement, the Enforcement Division conducts an investigation. 

Violations not resolved with a conciliation agreement can result in the 

Commission filing suit against the respondents.
 

Page 28 GAO-13-237 Sponsored Programming Requirements

Our review of FEC data found the disclaimer cases resulted in 330 case 

outcomes that range from dismissals to civil penalties through conciliation 

agreements.60

Table 4: FEC Outcomes for Disclaimer Cases, January 1, 2000, through May 14, 2012

However, as shown in table 4, of the 38 outcomes that 

could have ended with a civil penalty—conciliation agreement, alternative 

dispute resolution agreement, and lawsuit—FEC assessed civil penalties 

in only 29 cases, 7 of which were related to television or radio 

disclaimers.

Outcome

Number of 

outcomes Notes

Percentage of 

total outcomes

Cases dismissed 168 FEC dismissed the cases with no further 

action

51%

FEC found no reason to believe that disclaimer 

rules were violated

78 Cases closed with no further action 24%

FEC found a reason to believe that disclaimer 

rules were violated but took no further action

46 Cases closed with no further action 14%

Conciliation agreement 23 22 of the 23 conciliation agreements included 

a civil penalty

7%

Alternative dispute resolution agreement 14 7 of the 14 alternative dispute resolution 

agreements included a civil penalty

4%

FEC filed law suit 1 FEC won the case but the court did not 

impose a civil penalty

Less than 1%

Source: GAO presentation of FEC data.

Unlike FCC, FEC provides status updates to those involved in

investigations and issues reports explaining investigation findings. On 

December 31, 2009, FEC issued guidelines for tracking and reporting the 

status and time frames of complaint responses, investigations, and 

enforcement actions. The guidelines require the FEC’s Office of General 

Counsel and the Office of Alternative Dispute Resolution to provide the 

Commissioners and affected parties with a status report once per year for 

cases in which the Commissioners have not yet voted on the 

recommendation made by the General Counsel or the Office of 

Alternative Dispute Resolution based on their initial reviews. These status 

reports include estimate of when the Commissioners will vote.

 

60A single case can involve allegations against multiple parties that can result in multiple 

outcomes for a single case. Thus, this is why there were only 277 disclaimer cases that 

closed during the review period but 330 outcomes.
 

Page 29 GAO-13-237 Sponsored Programming Requirements

Also unlike FCC, FEC issues reports explaining its resolution of 

enforcement cases, including case dismissals. These reports can clarify 

acceptable and unacceptable practices for the regulated community. For 

example, during 2007, FEC received a complaint alleging that a 

candidate had violated television advertisement disclaimer requirements 

by including an improper disclaimer in the advertisement. The complaint 

alleged that the printed disclaimer violated the requirements because it 

did not also state that the candidate approved the advertisement. FEC 

dismissed the case in an exercise of its prosecutorial discretion to not 

pursue a violation in part because of partial compliance with disclaimer 

requirements. In doing so, FEC observed that the verbal disclaimer 

identified the candidate and informed the public of the candidate’s 

approval of the advertisement and the printed disclaimer informed the 

public that the candidate’s committee paid for the advertisement.61

FCC receives hundreds of thousands of complaints related to all areas it 

regulates but there have only been a small number of sponsorship 

identification cases. Of the sponsorship identification cases opened by 

FCC, only a handful have resulted in enforcement actions against 

broadcasters, and many of those enforcement actions were for fines of 

less than $100,000. Most broadcasters told us they generally have no 

problems meeting the sponsorship identification requirements because 

they have processes in place to review all content and ensure it has a 

sponsorship announcement if needed.

However, FCC guidance for the sponsorship identification requirements 

has not been updated in nearly 50 years to address more modern 

technologies and applications. We have previously reported that 

retrospective reviews of regulations can change behavior of regulated 

entities.62

 

61FEC, Matter under Review 5834: Darcy Burner for Congress, June 28, 2007.

Similarly, a review and update of FCC guidance that discusses 

outdated technologies could result in changes in behavior. One example 

discusses a broadcaster’s use of expensive kinescope prints as part of a 

story on a controversial issue. The example directs such a use should 

receive a sponsorship announcement because of the controversial issue 

being discussed and the cost of the film. Yet, today, because the expense 

of providing film is no longer relevant, broadcasters may be unsure on 

62GAO-05-939T

Conclusions
 

Page 30 GAO-13-237 Sponsored Programming Requirements

whether the concern is the expense of the film or the controversial issues 

discussed in the film. FCC should clarify its guidance to clearly address 

how, when content is provided with no money or payment in-kind and it 

does not discuss a controversial issue, the situation should be treated. 

Furthermore, FCC should clarify its examples to direct broadcasters’ 

treatment of content provided with no money or payment in-kind that does 

not highlight a product or brand beyond the “reasonably related” standard, 

such as a VNR. FCC has indicated VNRs must have a sponsorship 

announcement; however, FCC’s enforcement of VNRs has not found fault 

with the use of the VNR but rather when the VNRs focus on a specific 

product. Stakeholders disagree on the use of VNRs. FCC’s enforcement 

actions and guidance do not distinguish how to act when portions of 

VNRs are used or when a VNR does not disproportionately focus on a 

product or brand. FCC indicated in 2005 that it would issue a report or 

take other necessary action regarding this issue and updating the 

guidance could serve this purpose.

Unlike FEC in its enforcement of disclaimer requirements, FCC’s 

enforcement process for sponsorship identification cases generally does 

not inform the broadcasters or cablecasters named in the complaint when 

investigations have been closed. In cases where a letter of inquiry has 

been sent, the broadcaster or cablecaster must fulfill its responsibility and 

provide FCC with the requested information. Yet, according to FCC, 

because they have no legal obligation to inform broadcasters that an 

investigation has concluded, it typically does not provide that information. 

By providing this information, for cases in which FCC conducts a full 

investigation and determines the broadcaster’s actions not to be a 

violation of requirements, the outcome could provide guidance to the 

broadcaster of allowable activities. Even in cases where FCC closed a 

case with no investigation, informing the broadcaster that the case is 

closed, even if it may be reopened in the future, would support 

government-wide goals of greater transparency and sound oversight 

practices.

Finally, while in 2011 FCC had specific goals related to the timeliness of 

completing sponsorship identification investigations, it was unable to 

provide data supporting how it met those goals, and in subsequent years 

it withdrew the goals. In an effort to achieve greater openness, the 

timeliness of reporting and publishing information has been identified as 

an essential component. By re-establishing goals about completing 

sponsorship identification investigations in a timely manner, FCC would 

support broader government goals of completing actions in a timely 

manner to better serve its constituencies and regulated entities.
 

Page 31 GAO-13-237 Sponsored Programming Requirements

We recommend that the Chairman of the FCC take the following three 

actions:

• To provide clarity on how sponsorship identification requirements 

apply to activities not directly addressed by FCC’s current guidance, 

such as the use of video news releases, and to update its guidance to 

reflect current technologies and recent FCC decisions about video 

news releases, FCC should initiate a process to update its 

sponsorship identification guidance and consider providing additional 

examples relevant to more modern practices.

• To improve its transparency concerning which investigations are 

ongoing or have been concluded and to provide guidance on 

allowable activities, FCC should communicate the closure of all 

sponsorship identification investigations with the broadcaster named 

in the complaint after a letter of inquiry was sent. The letter should 

indicate the case has been closed, but in doing so, FCC could note 

that closing the case does not signify an endorsement of the actions 

that were being investigated and that the case could be reopened. 

• To improve timeliness of investigations and ensure, when possible, 

that investigations are completed in an expeditious manner, FCC 

should develop goals for completing sponsorship identification cases 

within a specific time frame and develop a means to measure and 

report on how well it meets those goals.

We provided a draft of our report to FCC and FEC for review and 

comment. FCC provided comments in a letter dated January 23, 2013, 

that is reprinted in appendix II. Overall, FCC indicated that it will consider 

our recommendations and how to address the concerns discussed in our

report. 

In response to our second recommendation—to communicate the closure 

of investigations with the broadcaster named in the complaint when a 

letter of inquiry has been sent—FCC identified a number of issues, many 

of which were cited in our report. Specifically, FCC has concerns that 

reporting the closing of a case may be misinterpreted as an endorsement 

of a broadcaster’s actions. FCC further noted its limited number of 

Enforcement Bureau staff available to work on the large portfolio of cases 

could and that it could not dedicate the necessary time to craft closing 

letters tailored to each case. However, we feel that FCC could create a 

standard letter—stating that a case has been closed, that the closing of 

the case does not endorse the actions of the broadcaster named in the 

complaint, and that the case could be reopened because of new 

evidence. We believe such a standard letter would require minimal 

Recommendations

Agency Comments 

and Evaluation
 

Page 32 GAO-13-237 Sponsored Programming Requirements

resources to create and send, yet would contribute to greater 

transparency. FCC also noted that it is reluctant to single out sponsorship 

identification matters for special treatment in terms of closure letters but 

are also concerned about the even greater impact on resources if closure 

letters are instituted on a broad basis. However, we believe that this 

could serve as a pilot program for greater adoption of closure letters for 

other types of FCC investigations. In response to FCC’s concerns, we 

updated our recommendation to demonstrate how a closure letter could 

be worded to indicate the closure did not indicate an endorsement of the 

actions being investigated and that a case could be reopened. 

Both FCC and FEC provided technical comments that were incorporated 

as appropriate. When providing its technical comments, FCC discussed 

the treatment of VNRs indicating that although the 2005 Public Notice 

states VNRs generally must have a sponsorship announcement, recent 

cases involving VNR complaints have resulted in FCC treating VNRs 

similar to other programming subject to the sponsorship identification 

requirements. We reflected this change in the report, and added a 

reference to FCC decisions about VNRs to our first recommendation. 

As agreed with your office, unless you publicly announce the contents of 

this report earlier, we plan no further distribution of it until 30 days from 

the date of his letter. At that time, we will send copies of this report to the 

Chairman of the Federal Communications Commission, and the Chair of 

the Federal Election Commission. We will also make copies available to 

other on request. In addition, the report will be available on the GAO Web 

site at http://www.gao.gov. 

If you or your staff have any question, please contact me at (202) 512-

2834 or goldsteinm@gao.gov. Contact points for our Offices of 

Congressional Relations and Public Affairs may be found on the last page 

of this report. GAO staff that made major contributions to this report are 

listed in appendix III. 

Mark L. Goldstein

Director, Physical Infrastructure Issues
Appendix I: Objectives, Scope, and 

Methodology

Page 33 GAO-13-237 Sponsored Programming Requirements

We were asked to review requirements for identifying the sponsors of 

broadcast commercial and political advertisements and to determine the 

extent to which agencies responsible for administering them address 

complaints alleging violations of the requirements. Specifically, we (1) 

describe the sponsorship identification requirements and guidance for 

commercial and political content, the federal election disclaimer 

requirements, as well as stakeholders’ views of these requirements and 

guidance and (2) assess how and to what extent FCC and FEC address 

sponsorship complaints through each agency’s enforcement process.

To describe the sponsorship identification requirements and guidance as 

well as stakeholders views on these requirements and guidance, we 

reviewed sponsorship identification statutes and regulations, including the 

Communication Act of 1934, as amended1

, and the Federal Election 

Campaign Act.2

To determine how and to what extent FCC and FEC address sponsorship 

identification complaints, we interviewed FCC and FEC officials 

responsible for receiving, processing, and investigating complaints. In 

We also reviewed relevant academic literature and 

interviewed FCC and FEC officials to gather their understanding of the 

governing statutes and regulations, how they have changed, their 

purposes, and how they apply to various media platforms, including 

conventional and embedded advertising and video news releases, and 

political and controversial advertisements. We conducted interviews with 

over one-dozen stakeholders selected because they are either subject to 

sponsorship identification requirements, have monitored broadcasters’ 

compliance with sponsorship identification requirements, or contributed 

research to the topic. These stakeholders’ interviews were conducted with 

representatives from the four major television broadcast networks as well 

as two additional groups that own television and radio stations. We also 

interviewed representatives from a consumer watchdog organization, 

academics, and trade associations that represent broadcasters and news 

directors and producers. These interviews were conducted to obtain 

views on the effect of statutes and regulations and possible changes to 

them.

 

1

Act of June 19, 1934, ch. 652, 48 Stat. 1064, (Communications Act), codified in title 47, 

United States Code.

2

Federal Election Campaign Act of 1971, Pub. L. No. 92-225, 86 Stat. 3 (1972), as 

amended, codified as 2 U.S.C. ch. 14. 

Appendix I: Objectives, Scope, and 

Methodology 
Appendix I: Objectives, Scope, and 

Methodology

Page 34 GAO-13-237 Sponsored Programming Requirements

addition, we analyzed relevant FCC and FEC documents describing 

agency methods and processes for identifying violations, receiving 

sponsorship identification complaints, communicating with the 

complainant and subject of the complaint, initiating and conducting 

investigations, and taking enforcement actions. We also analyzed 

relevant FCC and FEC data to describe sponsorship identification 

complaints, investigations, and enforcement actions. We analyzed FCC 

data showing all complaints received by FCC from 2000 through June 

2012 to determine the percentage of complaints that were sponsorship 

identification complaints, FCC actions in response to sponsorship 

identification complaints, and the time frames for resolving these 

complaints. We determined the FCC data to be sufficiently reliable for our 

purposes based on previous analysis of the FCC database and based on 

current interviews. To determine the extent to which FCC addresses 

sponsorship identification complaints, we analyzed all FCC enforcement 

actions pursuant to these complaints from 2000 through June 2012. We 

also analyzed FEC data showing all complaints received by FEC from 

2000 through May 15, 2012, to determine the percentage of complaints 

that were disclaimer statement complaints, FEC actions in response to 

disclaimer statement complaints, and the time frames for resolving these 

complaints. The FEC data were not materially relevant to our findings and 

so while we asked a series of questions about the internal controls and 

data reliability, we did not make a final determination of its reliability. To 

determine the extent to which FEC addresses disclaimer statement 

complaints, we analyzed all FEC disclaimer statement cases, including 

cases dismissed by FEC, and all FEC disclaimer statement enforcement 

actions from 2000 through May 15, 2012. We also analyzed FCC and 

FEC strategic plans describing the agencies’ respective goals for 

sponsorship identification and disclaimer statement complaint processing 

and enforcement. In addition, we analyzed FCC and FEC data and 

documents describing whether the agencies met their respective goals. 

We interviewed FCC and FEC officials about their goals and their 

progress toward achieving them.

We conducted this performance audit from March 2012 through January 

2013 in accordance with generally accepted government auditing 

standards. Those standards require that we plan and perform the audit to 

obtain sufficient, appropriate evidence to provide a reasonable basis for 

our findings and conclusions based on our audit objectives. We believe 

that the evidence obtained provides a reasonable basis for our findings

and conclusions based on our audit objectives.
Appendix II: Comments from the Federal 

Communications Commission 

Page 35 GAO-13-237 Sponsored Programming Requirements

Appendix II: Comments from the Federal 

Communications Commission
Appendix II: Comments from the Federal 

Communications Commission 

Page 36 GAO-13-237 Sponsored Programming Requirements
Appendix II: Comments from the Federal 

Communications Commission 

Page 37 GAO-13-237 Sponsored Programming Requirements
Appendix III: GAO Contact and Staff 

Acknowledgments

Page 38 GAO-13-237 Sponsored Programming Requirements

Mark Goldstein (202) 512-2834 or goldsteinm@gao.gov

In addition to the individual named above, Ray Sendejas, Assistant 

Director; Eric Hudson; Bert Japikse; Michael Mgebroff; Amy Rosewarne; 

and Andrew Stavisky made key contributions to this report.

Appendix III: GAO Contact and Staff 

Acknowledgments 

GAO Contact

Staff 

Acknowledgments

(543301)
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