[NFCB] radio bingo?

Tue May 6 13:43:05 PDT 2008

And fish, too.

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 Wendy Schroell
Sent: Tuesday, May 06, 2008 1:27 PM
To: Shawna Claiborne
Cc: NFCB
Subject: Re: [NFCB] radio bingo?

I'm just in awe that KGNU has a Games Manager.

wendy

On Tue, May 6, 2008 at 2:02 PM, Shawna Claiborne <shawna at kgnu.org>
wrote:

> 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
> > ~~~~~~~~~~~
> > _______________________________________________
> > NFCB mailing list
> > NFCB at mailman.lmi.net
> > http://mailman.lmi.net/mailman/listinfo/nfcb
> >
> >
> > _______________________________________________
> > NFCB mailing list
> > NFCB at mailman.lmi.net
> > http://mailman.lmi.net/mailman/listinfo/nfcb
> >
> > _______________________________________________
> > NFCB mailing list
> > NFCB at mailman.lmi.net
> > http://mailman.lmi.net/mailman/listinfo/nfcb
> >
> >
>
> --
> Shawna Claiborne
> Membership Director
> KGNU Community Radio
> 4700 Walnut Street
> Boulder, CO 80301
> 303-449-4885
> shawna at kgnu.org
>
> _______________________________________________
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> NFCB at mailman.lmi.net
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>
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