Rules & Resources
Newspaper Support Center

Third-Party Sales Guidelines and Rules

(U.S. and Canadian Newspaper Publications)

BARTER

The ABC board of directors adopted a guideline that defines acceptable items that may be used as barter payment for third-party sales.

The following forms must be completed and maintained for the auditor's review for all barter sales:

Lists of Goods or Services To Be Received As Payment

On the Notification Form (Microsoft® Word® Document), each item the newspaper plans to receive as payment for third-party sales must be listed. A brief description must also be provided.

Acceptable barter items are those that meet all of the following criteria:

  1. Per unit value that does not exceed $25,000

  2. Sold in the public domain over a sufficient period of time as to have a clearly identifiable and established marketplace value
    • If the item is generally available for free in the public domain, it is would not be an acceptable form of payment for third-party sales circulation

  3. Redeemable without any additional purchase requirements

  4. Redeemable within the newspaper’s market
    • Defined as 100-mile radius of publisher’s central office (Newspapers reporting on ABC’s ‘National’ format are exempt)

    If tickets are the barter item, then the following criteria must also be met:
    • Face value must exist
    • Event attendance must be limited - a ‘sold out’ situation could occur
    • Event must be within 100-mile radius of publisher’s central office location (Newspapers reporting on ABC’s ‘National’ format are exempt)
Examples of acceptable barter items include, but are not limited to, the following:
  • Gift cards or gift certificates (with a clearly identifiable value)
  • Tickets to events such as a theater production, music concert, or sporting event wherein only a limited number of attendees are allowed (e.g., stadium seating)
  • Radio/TV/billboard advertising
  • Sponsorships for an event (e.g., gold package, silver package, etc.)
Examples of unacceptable barter items include, but are not limited to, the following:
  • House (exceeding $25,000)
  • Car (exceeding $25,000 sticker value)
  • Any item not sold in public domain
  • Cents off / dollars off coupons
  • Percent off coupons
  • Tickets to sporting event that is located outside 100-mile radius of publisher’s office
  • Tickets to a local fair/festival (no set limit on attendance)

Marketplace Value

As stated above, each item intended to be received as barter must be available for sale in the marketplace (public domain) by the purchaser.

These values should be supported by documentation. This documentation may be a rate card, price sheet, or Web site listing of the items and prices.

Use of Barter Items Received As Payment

Once received as payment, the newspaper may use the barter items in a variety of ways.

The use of barter items received may include, but is not limited to, the following:

  • Carrier contests
  • Subscriber contests
  • Subscription/single-copy premiums
  • Client gifts (except back to the purchaser)
  • Employee gifts
The ABC board of directors adopted a guideline that prohibits the barter items received as payment to be distributed with the third-party sale (inserts, samples, etc.). In that situation, the newspaper is simply acting as a distribution agent for the product; the items received are not considered as payment for the newspapers.

Attestations

An audit trail supporting the receipt of barter items as payment must be present within the newspaper’s accounting records. The value represented as ‘received’ for full payment of the balance due resulting from a third-party sales transaction must be reflected in the newspaper’s accounting records as payment received (at fair market value), in accordance with Generally Accepted Accounting Principles (GAAP).

ABC requires that a representative of the newspaper’s financial management who is familiar with the newspaper’s financial recordkeeping process sign an Barter Attestation from Newspaper (Microsoft® Word® Document). This attestation must:

  • Be completed at the end of each audit period (one per audit period)
  • List all barter items received and their fair market value
  • Certify the full barter payment will be recorded at fair market value in accordance with GAAP
The third-party sales purchaser’s accounting records must reflect bartered items as an expense. A representative of the third-party sales purchaser’s financial management who is familiar with the company’s financial recordkeeping process shall be required to sign an Barter Attestation from Purchaser (Microsoft® Word® Document) This attestation must:
  • Be completed for every purchaser whose payment for third-party sales is made via barter
  • List all barter items provided as payment and their fair market value
  • Certify the full barter payment will be recorded at fair market value in accordance with GAAP




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