Can an LPFM utilize the FCC’s Third Party Fundraising guidelines to interrupt programming and raise funds for the Fraternal Order of Police or a labor union?

No, the FCC’s Third Party Fundraising guidelines are intended for noncommercial educational (NCE) stations and are typically used for fundraising efforts that support the station’s operations. Using these guidelines to interrupt programming for fundraising purposes on behalf of the Fraternal Order of Police or a labor union might not align with the intended use of the guidelines. Additionally, such fundraising efforts could potentially raise concerns about editorial independence and the station’s noncommercial status. It’s important to carefully consider the context and implications before interrupting programming for fundraising activities related to external organizations.

Interrupting programming to raise funds for the Fraternal Order of Police (FOP) or a labor union is not permissible. This is due to the fact that the FOP is categorized as a fraternal benefit organization under §501(c)(8) of the Internal Revenue Code, and labor unions fall under §501(c)(5) of the IRS Code. The Commission’s ruling seems to be applicable only to §501(c)(3) organizations, and as a result, interrupting programming for fundraising on behalf of the FOP or a labor union is not allowed.