Brushing Up
On Compliance
It’s
happening again. The Federal Trade Commission (FTC) has
sent “mystery shoppers” into your theatres
to check on your compliance with the movie rating system.
Children ages 13 to 16 are attempting to purchase tickets
to “R”-rated movies, and are recording the
results. The FTC will take these results, compile a comprehensive
report, and release it to members of Congress, the press
and the public at large.
Later this fall, the FTC will hold
a public “workshop” on
the topic of retailer enforcement of voluntary entertainment
industry rating systems. NATO (along with a few lucky
members) will give testimony at that time.
Given these recent activities, I thought
it wise to focus this month on the rating system and
our industry’s
commitments thereunder. We could all use a “refresher
course.” Please work with your managers to
ensure that they understand these basic principles.
ID Checks. In 1999, the NATO membership
adopted a policy that requires photo identification checks
of patrons
who appear too young to purchase tickets for films
rated “R” and “NC-17.” Each
theatre company should take steps to reaffirm that
policy, and to examine its operations and training
procedures
to improve compliance with the policy.
Managerial Personnel Checks. In November
2000, the NATO board of directors adopted a 12-point
initiative
regarding
ratings enforcement and education. (Please contact
the NATO offices if you need another copy.) One
of those
initiatives involves managerial personnel checks.
Specifically, each theatre company should assess
current practices whereby managerial personnel
visit company
locations for other reasons, and should endeavor
to add ratings enforcement compliance inspection
to the
duties
of said personnel.
Ratings Compliance Officers. Also under
the initiatives adopted in 2000, each theatre company
should appoint a
senior executive compliance officer(s) to review on a regular
basis the company’s ratings enforcement practices.
Most NATO companies have appointed such personnel, and
they are in regular contact with the NATO offices. For
example, ratings compliance officers and NATO staff meet
twice a year to review compliance efforts and to discuss
additional steps that can be taken. Throughout the year,
NATO sends ratings compliance information to these officers.
If you have not appointed a compliance officer for your
company, please do so immediately.
Auditorium Checks. Under the policies,
each theatre company should endeavor to post personnel
at the auditorium entrance
for particular, extreme “R”-rated films, and
for all “NC-17” rated films. For films so designated,
individual companies will seek financial assistance from
the distribution company responsible for the film to help
defray labor costs.
Education. In addition to these enforcement
mechanisms, NATO and its members also focus on ratings
education. For
example, theatre companies have included ratings information
in their Websites, and have linked those sites to other
locations that contain additional ratings information.
Similarly, exhibitors have found numerous ways to include
ratings information in the box office, call centers and
other information sources for patrons. Theatre company
personnel have also encouraged newspapers with whom they
do business to include the reasons for the ratings in their
movie reviews.
Likewise, as part of the 12 points,
NATO members agreed to display posters or other materials
in each theatre complex
that explain the ratings system. NATO supplies these posters
to its members upon request.
If you have any questions regarding
these policies, or would like to share particular ratings
enforcement or education
efforts, please contact the NATO offices. 
