[NFCB] radio bingo?

Tue May 6 12:02:57 PDT 2008

actually, we aren't thinking of anything yet...I was also thinking we 
could not do games of chance on the radio, my games manager asked me to 
send out the request to see if there is anything that we CAN do on air. 
I do have experience doing off-air fundraising bingo, but there is 
interest in doing something with the airwaves, so just curious what may 
be allowed...sorry for the vagueness folks!

Ginny Z. Berson wrote:
> It might be helpful to find out from Shawna exactly what KGNU is
> thinking of.  Are you talking about broadcasting bingo?  Do listeners
> have to be members in order to get a card and play?  Or how do they get
> cards?  Are there prizes with cash value?  
>
> Ginny Z. Berson
> Vice President and Director of Federation Services
> National Federation of Community Broadcasters (NFCB)
> 510 451-8200 ext. 305
> 1970 Broadway, Suite 1000
> Oakland, CA 94612
> www.nfcb.org
>
>
>
> -----Original Message-----
> From: nfcb-bounces at mailman.lmi.net [mailto:nfcb-bounces at mailman.lmi.net]
> On Behalf Of Dave Downing
> Sent: Tuesday, May 06, 2008 11:21 AM
> To: nfcb-bounces
> Cc: NFCB
> Subject: Re: [NFCB] radio bingo?
>
> When commercial stations did bingo - listeners would go into one of the
> sponsoring businesses to pick up a playing card and then the station
> would periodically announce B-9, or whatever. The businesses liked it
> because it drove customers to their location(s) to pick up playing
> cards. And to get around anything that may remotely violate the state
> lottery laws, stations would offer cards to anyone who stopped by the
> station or requested one in the mail. 
>
> In that case it didn't cost the listener anything to play - 
>
> For non-commercial stations telling listeners to stop by one of the
> underwriters of radio-bingo might be considered 'call to action' to go
> to a particular business location... wouldn't it? 
>
> Dave Downing
> WLNZ
> Lansing, MI 
>
> -----Original Message-----
> From: nfcb-bounces at mailman.lmi.net [mailto:nfcb-bounces at mailman.lmi.net]
> On Behalf Of Ken Freedman
> Sent: Tuesday, May 06, 2008 1:58 PM
> To: Read, Aaron
> Cc: NFCB
> Subject: Re: [NFCB] radio bingo?
>
> I don't know about the legality of broadcasting a bingo game, but lots
> of not-for-profts do hold (non-broadcast) charity bingo games. The
> rules on those vary state by state, but in states where it is legal
> for charities to hold bingo events, you need to get a gaming license.
>
> -Ken
>
> On Tue, May 6, 2008 at 1:09 PM, Read, Aaron <READ at hws.edu> wrote:
>   
>> I'd defer to anyone with direct knowledge, but I think that
>>  might...might...very easily fall under the definition of a lottery.
>>     
> See
>   
>>  the fourth paragraph below.
>>
>>  - Aaron
>>
>>  ________________________________________
>>  Aaron Read / WEOS 89.7 General Manager
>>  Hobart & William Smith Colleges
>>  Geneva, NY 14456
>>  read at hws.edu  315-781-3811
>>
>>  (from
>>
>>     
> http://www.prss.org/producers/preparing/laws/broadcast_obligations.cfm#l
>   
>>  otteries)
>>
>>  Section 1304 of the Federal Criminal Code (18 U.S.C.) makes it a
>>     
> crime,
>   
>>  punishable by fine and/or imprisonment, for any licensee of an AM,
>>     
> FM,
>   
>>  or television broadcast station to broadcast any advertisement or
>>  information concerning any lottery, gift enterprise or similar
>>     
> scheme,
>   
>>  or any list of prizes awarded from any such lottery, gift enterprise
>>     
> or
>   
>>  scheme.
>>
>>  The FCC has authority to revoke a license for violation of this
>>  provision (47 U.S.C. section 312 (a)(6)). However, in June 1999, the
>>  U.S. Supreme Court held that Section 1304 may not be applied to
>>  advertisements of private casino gambling broadcast by a station in a
>>  state where such gambling is legal.
>>
>>  Furthermore, as of May 1990, broadcasters are allowed to provide
>>  information about or advertise lotteries conducted by nonprofit
>>  organizations, governmental organizations and some commercial
>>  organizations under limited circumstances (47 C.F.R. section 73.1211
>>  (1999)). There are some state laws which are more stringent than this
>>  new FCC rule, and care should be taken that programs do not offend
>>     
> state
>   
>>  law provisions.
>>
>>  The FCC defines a "lottery" as a game, contest or promotion which has
>>  these elements: a prize, chance, and consideration. Stations may also
>>  broadcast information about certain state lotteries (including the
>>  District of Columbia and Puerto Rico), certain Indian gaming
>>  information, or information about certain fishing contests. (18
>>     
> U.S.C.
>   
>>  Sections 1305 and 1307; 47 C.F.R. section 73.1211 (1999).) Even if a
>>  particular promotion constitutes a contest rather than a lottery,
>>     
> there
>   
>>  are specific requirements regarding the disclosure of material terms.
>>  (See 47 C.F.R. section 73.1216 (1999).) Because of the complexity of
>>     
> the
>   
>>  FCC's rules, it is advisable to consult counsel regarding the
>>     
> specific
>   
>>  parameters of a proposed lottery contest or other promotion.
>>
>>
>>
>>
>>
>>  > -----Original Message-----
>>  > From: nfcb-bounces at mailman.lmi.net
>>  > [mailto:nfcb-bounces at mailman.lmi.net] On Behalf Of Shawna Claiborne
>>  > Sent: Tuesday, May 06, 2008 12:10 PM
>>  > To: NFCB
>>  > Subject: [NFCB] radio bingo?
>>  >
>>  > Is anyone out there doing bingo over the airwaves? My games
>>  > manager was asking me about it, I have no experience in that
>>     
> realm..
>   
>>  >
>>
>>
>>
>> _______________________________________________
>>  NFCB mailing list
>>  NFCB at mailman.lmi.net
>>  http://mailman.lmi.net/mailman/listinfo/nfcb
>>
>>     
>
>
>
> --
> ~~~~~~~~~~
> Ken Freedman
> WFMU
> PO Box 2011
> Jersey City, NJ 07303-2011
>
> (201) 521-1416 ext 225
> ken at wfmu.org
> http://wfmu.org
> ~~~~~~~~~~~
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>
>
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>   

-- 
Shawna Claiborne
Membership Director
KGNU Community Radio
4700 Walnut Street
Boulder, CO 80301
303-449-4885
shawna at kgnu.org