Re: Sean Hannity’s violations of Payola and Sponsorship Indentification – SPONSID
Dear Sir or Madam:
I believe Sean Hannity violated Section 317 of the Communications Act of 1934, as amended, 47 U.S.C. § 317. That law requires broadcasters to disclose to their listeners or viewers if matter has been aired in exchange for money, services or other valuable consideration. The law says that an announcement must be aired when the subject matter is broadcast. The supporting rule is 47 C.F.R. § 73.1212.
After the raid of New York attorney Michael Cohen on April 9, 2018, by the U.S. Attorneys and the FBI in Southern District of New York, Mr. Sean Hannity of Fox News condemned the raid of Michael Cohen without disclosing that he was one of three clients of Mr. Cohen. Mr. Hannity only disclosed that he was a client after a judge ordered his name be spoken in public court.
Fox News, Sean Hannity, and Mr. Hannity’s TV and radio programs should be investigated for fines, civil, and criminal sanctions regarding this matter.
Sincerely,
[Your Name]
Send your letter to
Federal Communications Commission
Enforcement Bureau
Investigations & Hearings Division
445 12th Street, SW
Washington, DC 20554
SLOW BOAT SAILING 
The way I read the affected paragraphs, it doesn’t specifically state that broadcasters need to disclose conflicts of interest, but that, specifically, they need to disclose situations in which material is aired to the public as a matter of payment for private services rendered. Hannity could argue that his bringing Cohen on air 10 times on Fox was because of his friendship, and that his denouncements of the FBI raid were the result of an admitted conflict of interest. It would be highly unethical, but not technically illegal as it pertains to this law, as long as it wasn’t “in payment” to Cohen.
Oooonnnnn the other hand, Hannity himself has said he paid no money to Cohen for his real and actual legal services, which he believed to be under attorney-client privilege. And given Cohen’s alleged payoffs TO other parties (e.g. Daniels) FOR other parties (e.g. Trump)[and possibly using campaign finance money or a bank loan obtained under false pretenses], it would be perfectly in line with Cohen’s public “fixer” M.O. if he requested (or was offered) Fox air time in exchange for [said legal services offered to Hannity]. Daniels, for her part, publicly announced on April 16th, outside of the court, that her opinion of Cohen is that Cohen believes he is outside the law, which also more-than-conveniently fits the description of the kind of sketchy person who would deal in “favors” — particularly the kind of favors that leave a smaller paper trail (e.g. no financial records between Hannity and Cohen).
If a court were to be willing to hear a case accusing Hannity and Cohen of a pre-arranged and illegal agreement whereby material would be broadcast to a national public in payment for a private service, then presumably, the only way for either Hannity or Cohen to defend against the accusation would be to open up more material (e.g. emails and/or other correspondence) that would likely further incriminate both parties for other possible crimes or otherwise reveal further embarrassing connections.
So, as a minor suggestion, I would re-word the letter to focus less on the technical ethical claim (re: conflict of interest) and more on the very real possibility that Cohen’s appearances on the show were an actual payment from Hannity, and not just a friendly gesture. Hannity (not being a lawyer) probably thought he was being slick in “helping” a friend while avoiding the burdensome need to produce legal tender to pay for services rendered. Cohen, being a lawyer, may have understood this relationship better than Hannity, causing him to declare Hannity as his client.
It all fits.
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