Today’s New York Times carried an article announcing that the Mitt Romney campaign is planning to run advertising spots for his Presidential campaign in five states – at least 10 months before the first contest for delegates to the Republican presidential nominating convention.  With this first purchase of political time in what promises to be a very active political advertising cycle, broadcasters need to be ready to meet the requirements of the FCC’s political broadcasting rules.

While the lowest unit rate provisions of the rules do not kick in until 45 days before a primary or 60 days before a general election, most of the other political rules apply as soon as you have a legally qualified candidate.  A candidate for President is legally qualified in every state for FCC purposes once he or she is qualified in 10 states.  So that may very well be soon, as some states have minimal requirements for qualification on the primary ballots.

Once a candidate is qualified, equal opportunities, reasonable access (for Federal candidates), no censorship, and public file obligations are applicable to all spots purchased by that client.  Disclosure requirements as to price and other terms for spot sales also are required, so stations should be getting their political disclosure statements dusted off, updated and ready for presentation when a political candidate’s campaign committee comes calling for spots.  It seems early to start thinking of political obligations for next year – but the time is already here.