It's that time of year again. BPA's committees around the globe are starting to review existing rules for possible amendment as well as new rules that may affect BPA's membership. BPA's Board of Directors will make the final decisions at its semi-annual meeting on December 10, 2009 in New York City.
Below I have listed the rules being considered followed by summaries of those rules. I ask that you submit your opinions and questions regarding those rules that may affect your organization by using the "Comment" section found after this blog entry.
- AGE AND SOURCE REPORTING
- DIRECT REQUEST
- DIGITAL EDITIONS: PHYSICAL ADDRESSES
- DIGITAL EDITION CONVERSIONS
- DIGITAL EDITION REPORTING
- BARTER TRANSACTIONS
- CHANGE OF FREQUENCY
- PRODUCTION STATUS
- PARAGRAPH 8 – BUSINESS PUBLICATION STATEMENTS
- CHARITABLE DONATIONS
- PUBLICITY
- QUALIFIED SHOW COPIES
- SPONSORED CIRCULATION
- AUDIT REPORTS
During the economic crisis of this year, BPA has experienced a higher rate of membership attrition than normal.
When we speak to our members we learn it is not the BPA fees that prompt them to resign, but the cost to maintain the BPA circulation statement, specifically, paragraph 3b, Age and Source. One ADAC (Audience Development Advisory Committee) member resigned several magazines due to costs related to attempting to maintain a high rate of one year request circulation as reported in paragraph 3b. It was suggested BPA make age and source reporting optional. In markets where age and source are important, allow the publishers the option to continue reporting. In markets where age and source are not important, give publishers the option not to report.
Relaxing reporting requirements is always tricky for BPA. Half of the membership applauds the change, and half of the membership perceives that such a change is a weakening of standards and removes a competitive advantage. How do you feel about optional age and source reporting?
DIRECT REQUEST
At its May 2009 meeting, the BPA Board of Directors agreed to change “personal direct request from recipient” to “direct request.” This change was made because many subscriptions are requested by authorized assistants, not the actual subscribers.
It may be possible to bring further transparency to the category. A BPA publisher member noted the individual may not “directly” request the subscription; often the subscription is requested by an authorized assistant. The publisher proposed to change “direct request” to “individual request.” The publisher believes this more accurately describes the interaction with the subscriber, or the subscriber’s authorized assistant.
DIGITAL EDITIONS: PHYSICAL ADDRESSES
As the number of magazines reporting digital editions continues to rise, more publishers are experiencing the challenge of subscribers without physical addresses, either because they were not asked or declined to provide the information. How are such recipients to be reporting in the geographic table?
Current BPA rules do not allow individuals without physical addresses to be included in qualified circulation. Should BPA create an “email address only” category in our geographic table?
DIGITAL EDITION CONVERSIONS
In May 2009, the Board approved a rule change allowing publishers to convert requested print subscriptions to digital subscriptions. Rule B7.29 states, “Publishers may convert requested print edition subscriptions to electronic edition subscriptions, provided the subscriber who requested the publication receives advance notice of the conversion and is given the option to refuse the conversion. Evidence of the original request and the notice of the conversion shall be available at the time of the audit.”
A request was made to define the “advanced notice” period, and establish standard text for the conversion notice. Members have been advised the “advanced notice” period must give the publisher enough time to convert or not to convert the subscription, based on the subscriber’s response to the notice. While it is difficult to define a fixed period for the advanced notice (since it varies from pubisher to publisher), BPA could amend the rule to state the advanced notice must provide the publisher enough time to stop the conversion if the subscriber refuses to convert.
Regarding standard text, as long as the subscriber is given the option to refuse the conversion, the rules have been satisfied. However, we are currently developing samples for review.
DIGITAL EDITION REPORTING
At least one publisher member feels the current reporting format for digital copies--columns within the current tables--does not provide enough separation. The publisher claims the reporting format confuses advertisers.
BPA requires digital editions be reported separately throughout the report. Digital and print copies are combined in paragraph B1/C1, Average Qualified Circulation, on page 1, but must be reported in a separate paragraph B1/C1 on the back of the report. Paragraph B2/C2, paragraph B3a/C4, paragraph B3b/C5, and paragraph B4/C6 all report separate columns for digital and print editions. Digital copies have been reported in this manner for many years. What's your opinion?
BARTER TRANSACTIONS
In the Spring 2009, the BPA advisory committees reviewed a proposal to allow barter transactions to count towards paid circulation. The U.S., Canadian, and European committees voted not to allow barter transactions to count toward paid circulation. The Middle East advisory board voted to conduct more research on barter transactions, and develop rules and report formats for barter transactions at the next meeting.
BPA’s Canadian newspapers have eliminated the need for barter transactions with their new report format that combines “sponsored by third party and free circulation.”
Do you think barter transactions should count toward paid circulation?
CHANGE OF FREQUENCY
Publishers are dealing with the challenging economic environment in many ways. Some publishers are reducing circulation sizes, others are maintaining circulation size, but reducing frequency.
One publisher that has not changed circulation size is concerned a competing publisher that had a similar circulation size but reduced frequency as a way to cut cost has an advantage when it comes to BPA reporting. On the December statements, both publishers will report similar circulation figures but based on different frequencies. The publisher that reduced frequency will report the maintained Total Qualified Circulation figure on page one, but a lower frequency.
Will the buyers notice the reduced frequency when evaluating circulation? Changes in frequency are disclosed several places on the BPA report. Is that enough?
PRODUCTION STATUS
The BPA Worldwide website includes the following notifications for circulation statement production: at press, BPA hold, filed, proof sent, shipped, and typesetting. In practice, however, we are only using the “filed” status.
The most common causes for delayed statements are:
- Delinquent invoices
- Previous audit not completed
- Those with a history of error cannot release a circulation statement until it is audited
Late filings and extended proof of approvals also add to the delay, even if they are operating within the BPA Worldwide rules. What additional notifications should we include on the BPA website?
PARAGRAPH 8 – BUSINESS PUBLICATION STATEMENTS
Paragraph 8 on the BPA business publication statement reports “paid circulation data.” Included in this paragraph are: average annual subscription order price; issues per year; single copy sales price for the period; and renewal rate information.
Average annual subscription order price can be found in paragraph 7, average annual audited qualified circulation and current unaudited circulation statements. Issues per year can be found on page one. Very few publishers report single copy sales on business publications, and even fewer report renewal rates.
Single copy sales and renewal rate data do not warrant their own paragraph. This information would be better served reported in paragraph 9, additional data. Should BPA eliminate paragraph 8, paid circulation data, on business publication statement?
CHARITABLE DONATIONS
The BPA staff has received questions about fundraising programs where a portion of all subscriptions goes towards a school, scouts or a club. In addition, we received an inquiry regarding a non-deductible subscription tied to a charitable donation. The Board instructed staff to bring the item before the advisory committees again.
We have identified three different types of charitable contribution offers:
- “You buy, we give” offer. In this offer the subscriber purchases the magazine and the publisher makes a donation on the subscriber’s behalf.
- School/club fundraising program, where the consumer chooses from a wide variety of magazines and products, and the subscription agent returns a percentage of the sales to the school/club/organization.
- Non-deductible contribution offer. Here is an example: “In acknowledgment of your membership gift of twenty-five dollars or more you will receive a one year subscription to XYZ magazine. Your donation of twenty-five dollars or more is tax deducible less fair market value of three dollars and sixty cents for the subscription.”
Subscriptions from fundraising programs could be disclosed in the Explanatory paragraph. How do we disclose the other two offers? Promotional Incentives? Combination Sales? Or is a distinction necessary?
PUBLICITY
BPA received a request to review the following suggestions regarding publicity complaints/violations:
- In addition to posting a violation on the BPA website, the notice is listed in the “membership standing” section of the membership profile before the current statement.
- In addition to the history showing past statements and audit reports, past publicity violations are also listed. This will allow advertisers to see clearly the chronic offenders.
- A monetary penalty is assessed for those members found in violation of publicity rules. Currently a formal complaint costs $235.00, charged to the member that initiates the publicity complaint. If the complaint yields a violation, the offending member must reimburse the complainant.
- Any member with two violations in one calendar year is fined 10% of their annual audit fees.
BPA is not in favor of any of these options. What is your opinion?
QUALIFIED SHOW COPIES
BPA rule C9.9 states, “If trade show, consumer show, and convention distribution are reported as Qualified Circulation, the following comment shall be included as part of the Method of Distribution: ‘Distribution to trade shows, consumer shows and conventions are audited only to the event and not to the end recipients. An agreement from the event management has been obtained indicating that the event will accept a specified number of copies for redistribution. When the publisher exhibits and distributes copies at a show the following shall be stated: The publisher has provided a paid contract for exhibit space. Distribution to the event is supported by delivery receipts from a third party.’ ”
Current rules down not allow the publisher to transport the copies to the show themselves. Is there a way to qualify copies distributed at shows that do not use third-party distribution? Would a signed affidavit from a show manager, or senior employee of the show manager, attesting to the number of copies brought to the show suffice? Is this a practical solution?
SPONSORED CIRCULATION
Sponsored copies are reported as a sub-category of Paid circulation. On the BPA Consumer report, sponsored copies are not included in the average annual order price calculation, nor are sponsored prices and transactions detailed in paragraph 3a, Prices.
A publishing member is concerned about a competing title that has converted the majority of their circulation from Non-Paid Individually Addressed circulation to Paid Sponsored Individually Addressed circulation, while disclosing little information about the sales.
According to the BPA Consumer rules, a publisher does not need to factor sponsored prices into their average annual order price, nor do they need to note the details of the transaction or name the sponsor. Conversely, subscription sales purchased directly by end recipients are factored into the average annual order price and detailed in Paragraph 3a. Conversely, BPA Business rules require sponsored sales to be included in the average order price circulation – and be detailed in paragraph 5, Prices.
The member is concerned about the lack of reporting requirements for sponsored copies and suspects his competitor is selling sponsored copies at a very cheap unit rate. There is also concern that buyers believe the average annual order price is inclusive of all paid subscriptions, including sponsored.
Should BPA provide more disclosure on sponsored sales in consumer circ. statements and audit reports?
AUDIT REPORTS
Magazine members file two unaudited six-month circulation statements as part of their 12-month audit reporting period. If the audit reveals a material change to the claimed circulation figures, an auditor report is issued to disclose the specifics.
BPA rules prevent a circulation statement from being issued until the previous audit has been completed and released. If a statement is being held for a previous audit, as soon as the audit is released, the circulation statement is released. Once the new circulation statement is issued, the audit report moves to history on the BPA website (accessible under the VIEW HISTORY section of the web listing).
A publisher member feels audit reports become lost in our reports history, as most advertisers work from current circulation statements. Most publishers choose not to show their audit reports to media buyers as these reports often promote shifts or reductions to previously released circulation figures. This places the competing publisher in a negative selling situation.
Should those members with a history of adjustments be mandated to include their previous audit report comments on their two subsequent circulation statements, or be required to distribute the previous audit with subsequent statements (within the same pdf)?
Please use the "Comment" link below this blog entry to make your opinions known about any or all of the above items. As always, I look forward to reading your opinions.