Sponsorship & Advertising FAQ

MarketingMarch 26, 2019

Frequently Asked Questions

Can we accept Defense Contractors as sponsors for our events?

Although we generally should solicit from companies that produce consumer products, we can accept sponsorship from defense contractors as long as they do not promote their products but rather a patriotic theme or their support for the military.

Can I accept sponsorship from educational institutions?

Generally spoken, yes; but all agreements with educational institutions must be coordinated with the Education Services Officer (ESO) at the garrison's Army Education Center.  

Please read OPORD 15-014 in the Sponsorship and Advertising Desk Reference at Appendix M and Annexes A - C at Appendix L.

Why does my lawyer always correct me when I say sponsorship contract.

Upon checking with the IMCOM attorney, there needs to be a distinction between "contracts" with NAF Contracting and Commercial Sponsorship.  NAF Contracting is not to be involved with commercial sponsorship and advertising agreements, although they can provide support in form of passing on names of companies they have contracts with.  A "contract" would automatically be associated with NAF Contracting.

To avoid this, Commercial Sponsorship and Advertising managers submit "agreements".  The IMCOM attorney advises to never use the word "contract" in conjunction with the sponsorship and advertising agreement.

Complete Question:

My lawyer always corrects me when I say sponsorship or advertising contract.  Why does he do that?

My attorney questions on what is sponsorship and what is advertising?

Your attorney probably thinks that because of the product samples it should be a sponsorship agreement.  It could be either.  Advertising is without any interaction, just static display; while sponsorship involves interaction.  You could say there is interaction if people pick up the samples and brochures which have to be replenished by the program manager.  In the end, it does not matter whether you call it sponsorship or advertising in this case.

Complete Question:

I submitted an advertising agreement for review to our legal office.  The advertiser wants to put brochures, banners and product samples in the Auto Crafts Shop.  

My attorney said it has to be a sponsorship agreement but this is not tied to any event.  Should this be a sponsorship agreement?

Can I solicit sponsorship for our Bingo program?

You couldn’t solicit sponsorship from an off-post bingo place or a gambling venue but you can get sponsorship for your MWR Bingo program.

Who needs to sign the sponsorship designation memorandum?

The designation memo should be signed by the DFMWR.

Complete Question:

I just wanted to reconfirm the signature of the sponsorship memorandum authorizing us to solicit sponsors/advertisers.  It just has to be signed by our DFMWR, correct?  Or, does my Garrison Commander need to sign off on it?

Does the Gold Star Program qualify for sponsorship? My Gold Star Program Manager wants me to solicit

At this time, the Gold Star program does not qualify for sponsorship.  It is not an MWR program.

Other garrisons get donations under the Army's gifts and donations program but the donors cannot receive any exposure for their donation, other than a Thank You Letter (or verbal thank you) for their contribution.  Donations may not be solicited!

Not all programs that have a NAF component are eligible for sponsorship.  Only MWR programs/events qualify for sponsorship.  Under ACS only AFAP and AFTB are authorized for limited sponsorship (light refreshments and mementos).  The Volunteer program is no longer mentioned in AR 215-1 Chapter 11, however, in chapter 5 there is mention that non-appropriated funds can be used for light refreshments and mementos for volunteers.

Complete Question:

Does the Gold Star Program qualify for sponsorship? My Gold Star Program Manager wants me to solicit for food/flowers for an upcoming event?

But I wasn't sure if the Gold Star Program falls under the NAF component category for ACS.

Can First Command sponsor Newcomers Briefing and provide financial education?

Financial education/counseling is under ACS and Financial Readiness.  Their contract with the on-post banks and credit unions includes financial counseling/education, therefore, this is not something we can promise a potential sponsor.  You need to contact your Financial Readiness Officer and the BLO prior to discussing with your sponsor.

Complete Question:

First Command is interested in sponsoring Newcomers Briefing and provide financial education. Can they do that?

Can foreign car dealers sponsor MWR Events and what are the limitations?

Foreign car dealers can now sponsor MWR events, however there are time limitations.  Any display and advertising of the car dealership cannot exceed 10 consecutive days.  It does not matter if the sponsorship is for different events/campaigns, there must be a break between the exposure time frames, to not give the impression that the car sponsor has a year-round agreement.

What is our responsibility when we see banking institutions as part of events by POs?

You should contact your legal office.  Per AR 210-22, private organizations are not allowed to duplicate Army activities; therefore, they are not allowed to give sponsors exposure on the garrison.  They may obtain sponsors for their events and give them exposure only to their members in the room where they meet.

Complete Question:

What is our responsibility when we see banking institutions as part of events by private organizations?

How does the financial institution issue apply overseas? Do we have to go through our BLO?

This regulation applies to all garrisons, no matter if they are CONUS or OCONUS.  If it is your on-post bank/credit union that wants to sponsor your events, they are treated like any commercial sponsor.  There is no need to get approval from the banking liaison officer for an on-post financial institution but it certainly would help to let them know that the bank/credit union is actively supporting garrison events.

Complete Question:

How does the financial institution issue apply overseas? Do we have to go through our Banking Liaison Officer’s even if the banks are the ones on the installation?

Do you have a list of nation-wide sponsors who would be interested in sponsoring overseas events?

We don’t have a list of sponsors for overseas events.You can consult IEG’s Sourcebook that is part of the IEG Access provided to the garrisons by IMCOM G9.

You may also look for local sponsors provided the garrison.  

Can we still only accept commercial sponsorship from USAA?

Generally, that’s correct.  Having said that, if USAA is only promoting their insurance services or drivers education, advertising is allowed.  Any contact information must go directly to the insurance branch.

Complete Question:

Regarding USAA, is the current guidance still that garrison sponsorship offices can only accept commercial sponsorship, rather than commercial advertising?  This was clear guidance the last couple years, but now we are seeing Digital TV Ads on the ARMP Network.  Please advise.

What about companies like Intervest International and First Command.  Are they acceptable?

If your on-post financial institutions don’t offer investments, it is OK to accept sponsorship from Intervest International or any other investment company.  They may not promote their banking or loan services.

First Command can sponsor if they have a product that does not compete with those offered by the on-post bank and credit union.  Please remember that it is the decision of the Garrison (Commander or DFMWR), if they want such companies to sponsor events.  If in doubt, always check with ACS, the banking liaison officer and, of course, your JAG.

Can I share your guidance regarding off-post financial institutions with the potential sponsor?

No, absolutely not.  Guidance from IMCOM G9 is internal guidance and not meant to be shared with any potential or existing sponsors.  You can refer them to the Financial Management Regulation but there is no need to give them the website.   It can be found through Google.

Is there documentation from G-9 regarding First Command/OMNI/Pioneer Sponsors?

There is no documentation other than what’s in the Financial Management Regulation and the desk reference.  The best way to go about this is to discuss with your financial readiness coordinator and the banking liaison officer at ACS.  They will let you know if there is a problem.  It is up to the Garrison (Commander, DFMWR) whether you can accept such a sponsor.Of course, the sponsors must have a product that is not in competition with the on-post financial institutions.

Complete Question:

Regarding First Command, OMNI Financial, and Pioneer Services - is there any documentation from G-9 that states Family and MWR will not accept sponsorship from these companies?  Although there is no regulatory guidance on these companies, it is understood that these companies' services are predatory and not in the best interest of the Soldiers and Families. Since this topic requires more of a Garrison-specific answer from the DFMWR and Command, what is your recommendation on how the Garrison Sponsorship Personnel should communicate this to these companies?

Who can sign the sponsorship/advertising agreements?

There is no specific policy, however, this is common business practice and a matter of internal controls. The sponsorship/advertising manager negotiates the agreement.  To avoid any perception of wrongdoing and for the sponsorship/advertising manager’s protection someone else should sign the agreement such as the DFMWR or your supervisor.

This is also outlined in the Sponsorship Desk Reference 4th Edition.

Complete Question:

Can you please send out the policy where it states who can sign the sponsorship/advertising agreements.

 

Do private organizations include Officer Spouses Club, Enlisted Spouses Club, etc.?

Yes, those are considered private organizations.  Each private organization operating on an installation must be approved by the Garrison Commander.  There is a specific regulation for Private Organizations: AR 210-22, that private organizations must follow.  Chapter 3-1 b.(3) states that private organizations “will not duplicate and/or compete with authorized Army or NAFI activities”

 

 

Complete Question:

Do the private organizations include Officer Spouses Club, Enlisted Spouses Club, etc.   How will the private organizations be informed of the rules?

Are Spouse Appreciation and Commander’s Cup are command functions not permitted sponsorship?

That is correct.  Only MWR Events are eligible for sponsorship.

 

Complete Question:

Clarify again: Spouse Appreciation and Commander’s Cup are garrison/command functions and are not permitted sponsorship solicitation?

Can we get sponsorship for Military Spouses Appreciation Dinner thru volunteer program?

No. The volunteer program is not an MWR program/event, it still is considered ACS and refreshments for the volunteer program are only authorized to cover the cost for the volunteer appreciation events.

Many garrison MWRs host events for military spouse appreciation.  MWR provides the food and sponsorship money is used to offset the expenses for MWR.

Complete Question:

If the volunteer program hosts the Military Spouses Appreciation Dinner, can we get sponsorship to offset the cost of the meal for the spouses?

How do we define the entire post community, anyway?

The entire military (or post) community includes Soldiers, Families DoD Civilians and Retirees.  Even contractors with common  access cards may attend events.

Complete Question:

How do we define the entire post community, anyway?  Does that include all Soldiers, Families, Retirees and DoD/DA civilians?  Or is having it open to all Soldiers and Families enough to meet that need?

Has there been any change regarding the guidance on off-post financial institutions?

No, there is no change.  The relevant regulation for off-post financial institutions is the FMR

7000.14R. Per Volume 5, Chapter 34 paragraph 0404 Advertising is not permitted.

Off-post financial institutions may sponsor MWR events/programs but can only promote services and products that are not offered by the on-post financial institutions, such as insurance.  My advice is to go to your installation bank and credit union and check out what they offer.  Those products are prohibited.  Also, all sponsorship agreements have to be coordinated with the Banking Liaison Officer, who is under ACS.

Off-post financial institutions may not list phone numbers and web addresses they can only list the name or logo, neither can include anything relating to financial (like Navy Federal but not Navy Federal Credit Union; First Command, not First Command Financial Services etc.)

Complete Question:

I am writing to inquire if there has been any change regarding the guidance on off-post financial institutions.

I will be getting a lot of push back from a few of my current sponsors (whose agreement will finish in January). Currently, I am being asked to produce a regulation and or a policy and as it stands I have nothing to provide them.  A current financial institution sponsor is attempting to do everything she can to continue our partnership and I am meeting with her to further discuss the current situation.  Please advise me as to what I can provide them at this point.

Do you have an IMCOM guidance regarding sponsorship appreciation events

Our attorney said that it certainly will be better to set out specifically in AR 215-1 that sponsor recognition ceremonies are permissible.  He agrees that paragraph 5-13d basically implies that such ceremonies are okay and that the paragraph provides sufficient support to conclude that there is a legal basis for holding recognition ceremonies.  He said he was fine with my proposed paragraph 11-19 (see below) and says it makes sense and provides explicit authorization for these ceremonies.

Following is the suggested language for the relevant paragraph of AR 215-1:

"Expense Accounts

11-19. Eligible personnel and facility use

a. MWR marketing, sponsorship, and advertising managers may have monthly expense accounts to purchase meals and nonalcoholic beverages when hosting potential commercial sponsors or advertisers.  MWR facilities will be used for hosting. If they are not readily available, commercial facilities may be used.  The expense account will not be used for the managers' meal/beverage.

b. The expense account is authorized for official business with the potential of benefiting MWR programs.

c. Garrisons are authorized to conduct annual sponsor recognition events to recognize the sponsors/ advertisers for their contributions and should budget for it in their operating budget.  Garrison Commanders should be invited to these events to thank the sponsors/advertisers personally and, if applicable, to present certificates and/or mementos.  The garrison commander's presence does not imply Army, DoD or Federal endorsement of the sponsors/advertisers; it demonstrates the garrison's appreciation of the community's support of Soldiers and their Families in accordance with the Army Community Covenant.

(1) The purchase of food and beverages (to include alcoholic beverages) is authorized from NAFs for distinguished visitors and official guests as outlined in Chapter 5-13 of this publication."

Complete Question:

We are trying to plan our annual Sponsor Appreciation Golf Tournament.  Our new GC is adamant on everything we do running through legal.  Do you have an IMCOM guidance regarding sponsorship appreciation events from your lawyers? That they are encouraged and are completely in regulation.....  I have what is in the desk reference, but I am thinking I will need more than that....  If I get a reading from IMCOM legal, my local lawyer has no issue.  This is preemptive on our part, to get the IMCOM guidance before we approach the GC and legal here, to avoid any delays....

Do you see in issue with placing MetLife Program advertisements in MWR facilities

There is no issue working with Military Marketing.They have worked with many garrisons and HQ on advertising and sponsorship campaigns and always delivered; paid on time and as agreed upon; and are an established marketing agency having worked with all Services.

 

Complete Question:

We have been approached by Military Marketing to place MetLife Program advertisements in MWR facilities. Apparently this is something ongoing on other installations. If approved by the facility managers, do you see an issue in moving forward?

What are the rules on allowing sponsors to participate as a goodwill-make-up gesture?

There is no problem with that at all.  This is simply good business practice and ensures that your sponsors come back for other events.

Complete Question:

I have an automobile dealership and a motorcycle dealership, which both were "rained out" at last year's Independence Day Celebration.

Needless to say, they were upset.  What are the rules on allowing them to participate this year as a goodwill-make-up gesture?

Looking for an Army Regulation similar to 215-1 that speaks to sponsorship of events at the Region.

Per AR 215-1 only MWR events are eligible for sponsorship.Command events are not MWR events.

AR 215-1 and DoDI 1015.10, Enc 11 and 12 are the only regulations for Commercial Sponsorship.  Your legal office should be able to help you with this.

Complete Question:

Looking for an Army Regulation similar to 215-1 that speaks to sponsorship of events at the Regional Command level.

I understand that official command events (i.e. Change of command ceremonies, etc.) cannot be sponsored, however, there must be a mechanism or process for

USARPAC to secure sponsors for events that fall under the USARPAC (US Army Pacific) umbrella rather than the USAG-HI (US Army Garrison Hawaii) umbrella.  Are there different guidelines or army Regulations that regulate the sponsorship of Command level events or is it all covered by AR 215-1

A German financial instituion wants to sponsor an event.  Is that allowed?

There is no issue with the German bank sponsoring an event, as long as they don't promote their financial services that compete with the services the on-post banks/credit unions offer.  It is important to get your garrison commander's approval for solicitation of non-US firms per AR 215-1, paragraph 11-18; and that the solicitation is not in violation of the SOFA agreement.

In any case, as always, the agreements should be routed through the installation BLO and Staff Judge Advocate (SJA) for final approval.

 

 

Complete Question:

A German financial institution would like sponsor an event to promote their company to local nationals and contractor employees.  What is your take on this?

VA Mortgage approached us to sponsor some of our events.  Can we accept them?

The answer from the Army’s BLO is as follows:

From our perspective as long as they were not advertising or distributing competitive materials, they could sponsor.  This would allow their logo to be displayed at the event, but that's about it.  I would recommend getting something in writing from the on-base FIs.

In addition to this answer, please always check with your local Banking Liaison Officer before proceeding with the sponsorship agreement.

Is our organizational day authorized sponsorship if all of MWR attends?

Organizational days, unit functions, military balls etc. are not authorized for sponsorship.  Organizational days are not MWR events, they are for employees and like for unit functions, the same rules apply for employee functions.

Complete Question:

Every year I am asked to provide sponsorship support for our MWR organizational day.  Is this event authorized sponsorship if all of MWR attends?

Some of our events are pretty small and I have a hard time finding sponsors for them.

To maximize exposure for sponsors at small events, offer them a package deal, where they get exposure at several small events or include some of the small events with a larger event sponsorship.  If your sponsor tells you they are not interested at all in exposure at the small events, you could just ask for a little more money for the large events and take part of that income for the small events.

Complete Question:

Some of our events are pretty small and I have a hard time finding sponsors for them.What do you suggest I should do?

Some of our facility managers allow local business to put flyers in their facilities.  What can I do

The best way to go about it is to ask your DFMWR for support.  You might put together a small presentation outlaying your advertising program with prices etc. and show how much money you could make by selling advertising to these companies.  No facility manager should allow companies to put their material in facilities but rather should refer them to your office.

You could also arrange for meetings with your program managers and give a presentation of the sponsorship and advertising program.  Make sure you have your financials included, so these program managers realize what they lose out on by allowing free advertising.

The presentation should also include what events are authorized sponsorship and which are prohibited from receiving such support.  A sample/template for such a presentation with notes is included in the Sponsorship Desk Reference on www.MWRBrandCentral.com.

In FY14 the Army-wide sponsorship and advertising revenue was almost $16.1 million.

Lastly, if you let one company/organization advertise for free, you have to give all of the companies the same treatment to avoid appearance of endorsement.  If that happens, the sponsorship and advertising program could be shut down completely.

Complete Question:

Some of our facility managers allow local business to put flyers in their facilities.What can I do to stop them from giving free advertising?

Can our local tattoo parlor advertise or sponsor with MWR?

Tattoo Parlors are also a sensitive category.  This is something that should be discussed with your chain of command.  Should you enter into an agreement with such a business, make sure you provide them with the Army rules concerning tattoos for Soldiers.

Can we accept electronic cigarettes manufacturers or vapor shops as sponsors or advertisers?

This is a sensitive category, therefore prior to getting into discussions with such a potential sponsor, please discuss with your legal office and your chain of command.

What are the sponsorship rules regarding alcohol and tobacco sponsorships?

Alcohol sponsorships must be unsolicited.  Please reference AR215-1, chapter 11-11 b. for additional information.  Also, remember that thelocal command has the final say as to as whether or not alcohol or any commercial sponsor or advertiser is accepted on an Army installation.

Generally it is advised to stay away from promoting tobacco products considering the Army’s non-smoking policy.

A charity approached one of our resorts and asked for donation of a room night.

This is an unauthorized use of NAFs.Below is the language in AR 215-1 that applies to this question:

“c. Support of POs. NAFs or NAF assets will not be transferred to POs as dividends or other distributions. NAFIs/entities will not provide NAF financial assistance in the form of contributions, repairs, services, dividends, or other donations of money or other assets to private organizations or individuals unless authorized by other regulations, DOD policies, or law.  For assistance to Scouting organizations, see DODI 1015.9.

d. Distributions to charities. NAFIs/entities will support only those programs and functions for which the NAFI/entity is organized.  NAFIs/entities do not contribute to or engage in fundraising activities for charities, foundations, and similar organizations nor collect or disburse donations of private or personal nature.”

Can a Brigade partner with MWR for an event?  Can a business co-sponsor the event?

A brigade can partner with MWR, as long as the event is a true MWR event and open to the military community.  Partnering with MWR does not mean that the event is automatically an MWR event; all sponsorship funds must go to MWR.

And yes, a business can sponsor an MWR event.

How do I calculate the value for in-kind sponsorship?

For a value you should use what the garrison would pay for the porta-potties; labor and material for painting the value as if you would buy these services; the NFL announcer can be valued at the price that would have to be paid if you hired him.

Complete Question:

An event has been brought to us to augment our intramural football program and has great merit, I am needing to write an in-kind sponsorship agreement for this and have been asked to run the amenities by you to see if there is any thoughts you have on the trade values.

The Sponsor will:

  • Provide porta-potties adequate to support 2,000 attendees.
  • Provide labor and materials for custom field paint.
  • Provide professional NFL-style announcers for the game.

What is the regulation for giving sponsors a certificate of appreciation?

AR 215-1, Chapter 11 and DoDI 1015.10, Enclosure 11) don't specifically mention certificates of appreciation, however, they state that public recognition is authorized as long as there is a statement that "No Army or Federal Endorsement is Implied" is added. Here are the relevant paragraphs:

DoDI 1015-10 Enc 11, para 1-b.

(5) Special concessions or favored treatment are not provided to sponsors, with the exception of public recognition and advertising entitlements addressed in the agreement, and individuals or entities not providing sponsorship are not treated with disfavor or suffer any form of reprisal.

(7) The contents of all public recognition and advertising media to be used by or for the sponsor and that refer to any part or program of the Department of Defense are reviewed by the DoD Components for consistency with DoD and DoD Component policies and are otherwise appropriate to the agreement.

AR 215-1:

 

It is common industry practice to recognize companies that contribute to Family and MWR events, thus either enhancing the event with in-kind product or providing cash either with a certificate or a memento at the event they sponsor or at a sponsor recognition/appreciation luncheon or dinner.  Ideally, the garrison commander should present the certificates.  This does not imply any endorsement of the companies.

 

Complete Question:  

If possible, could you please send me the regulation that states FMWR is allowed to provide companies a certificate of appreciation?

Should we accept sponsorship that only comes by way of a “discount” to MWR?

It is best to consult your legal office and your contracting office.  Generally, it is difficult to track any revenue in the sponsorship program and sponsorship cannot involve any cost for the sponsorship to the government.

Complete Question:

A sponsorship inquiry that has been sent to me from our Youth Sports Director.  He is over the Youth Swim team that falls under CYSS division. They are inquiring that webring on "Speedo" brand swim gear as a sponsor of the swim team.  But, with that said, Speedo has their own sponsorship program and sponsorship guidelines as well. Their sponsorship program packet discusses the conditions and also the incentives that we receive. To sum it all up, the reason I want your opinion is because most of the sponsorship only comes by way of a "discount" to MWR. The only thing provided to us for free is (2) Polo shirts to outfit the coaches, and $250 cash to support the team.  Everything else is discount, but has to include a purchase.

Can a GS employee solicit sponsorship and advertising?

Normally, only NAF employees are authorized to solicit sponsorship.  A GS employee can solicit, if the sponsorship/advertising duties do not exceed 25 % of their time.

This is not directly laid out in a regulation but a GS employee has an obligation to ensure that APF is spent wisely and appropriately, and a best practice would thus be to limit their involvement to 25% of their workload.

Should we provide MWR Support to a National Guard Unit at our garrison?

The same rules apply for Army Reserves and Army National Guard as for the Army.Only MWR events are eligible for sponsorship.  If they are on an installation by themselves and have an MWR division, the person who will be allowed to solicit sponsorship has to take the same training as Army MWR personnel and provide the designation memorandum to IMCOM G9 Marketing/Sponsorship.  Otherwise, they may attend the events at the installation where they are stationed.

Complete Question:

We were visited by an army reservist today - new unit(Reserve.)  They are just setting up from scratch and want to know who they go to for sponsorship support for them.  Should he just research through his higher ups?

Should we give a sponsor category exclusivity for an event?

We always were very reluctant to give a sponsor category exclusivity, unless they paid a lot of money.  It is OK to give a sponsor category exclusivity, but that limits you in selecting sponsors for your events.  Legally there is not a problem.  You just need to weigh the amount towards who are your potential other sponsors and how likely are they to sponsor a specific event and with how much money.  You have to decide if category exclusivity is warranted for each event.

That said, if you have a sponsor for one of your programs, even if you don’t give them category exclusivity, it is smart to not solicit sponsors in the same category.

Where do I find the Ethics Course?

Is FMWR allowed to provide companies a certificate of appreciation?

AR 215-1, Chapter 11 and DoDI 1015.10, Enclosure 11) don't specifically mention certificates of appreciation, however, they state that public recognition is authorized as long as there is a statement that "No Army or Federal Endorsement is Implied" is added. Here are the relevant paragraphs:

DoDI 1015-10 Enc 11, para 1-b.

(5) Special concessions or favored treatment are not provided to sponsors, with the exception of public recognition and advertising entitlements addressed in the agreement, and individuals or entities not providing sponsorship are not treated with disfavor or suffer any form of reprisal.

(7) The contents of all public recognition and advertising media to be used by or for the sponsor and that refer to any part or program of the Department of Defense are reviewed by the DoD Components for consistency with DoD and DoD Component policies and are otherwise appropriate to the agreement.

AR 215-1:

It is common industry practice to recognize companies that contribute to Family and MWR events, thus either enhancing the event with in-kind product or providing cash either with a certificate or a memento at the event they sponsor or at a sponsor recognition/appreciation luncheon or dinner.  Ideally, the garrison commander should present the certificates.  This does not imply any endorsement of the companies.

Complete Question:

If possible, could you please send me the regulation that states FMWR is allowed to provide companies a certificate of appreciation?

Are sponsors authorized to conduct sales at the MWR event that they are sponsoring?

No.  For example, a car dealership could be permitted to display vehicles and discuss vehicle features with interested patrons; however, the dealer could not at any time discuss financing options, nor conduct negotiations of any kind.

The installation could choose to permit vendors to sell merchandise at the MWR event.  NAF contracting procedures must be followed and NAF concessionaire contracts would be required.

What is the sponsorship and advertising coordination requirement with the local JAG/SJA office?

Working with the local JAG office on the installation sponsorship and advertising program is required to ensure proper compliance with Army regulations. All sponsorship and advertising agreements must be legally approved by the installation JAG office or legal counsel prior to submission to a client.

Complete Question:

What is the sponsorship and advertising coordination requirement with the local JAG/SJA offce?

Can an MWR sponsorship and advertising manager solicit sponsorship and/or advertising for FRGs?

No.  As an official program of the Department of the Army, FRG mission activities must be supported using appropriated funds (APF) to the same extent as any other Commander's program.  The FRG is not a Morale Welfare and Recreation activity.  FRG activities authorized APFs may not be supported with non-appropriated funds.  In accordance with DoDI 1015.10, Programs for Military Morale, Welfare, and Recreation, and AR 215-1, commercial sponsorship is generally only authorized for MWR programs and events.

FRGs are not established for the purpose of being a fund-raising organization and they have no authority to engage in external fundraising on or off post.

Where can I find a list of off-limits sponsors and advertisers?

A list of off-limits companies can normally be found at the installation's Consumer Affairs Office; Provost Marshal's office; or the SJA office.  You might also want to check with your contracting office.

May a private organization (PO) sell sponsorship?

A PO can raise funds on the installation in accordance with local guidance and consistent with the purpose statement contained in their charter, as approved by the SJA office.  A PO can raise funds or obtain cash or donated products through solicitation of businesses outside the gate (unfortunately, in competition with your MWR efforts, but perfectly OK), but cannot promise advertising exposure or public recognition on the installation to that business beyond the POs membership or outside of the activity for which the solicitation is supporting.   POs cannot conduct or compete with MWR events and, therefore, cannot solicit donations or sponsorship on behalf of MWR events, nor can they misrepresent their affiliation/relationship with the installation in such a manner that the business believes that it is the installation and not a PO that is soliciting.  POs and units may conduct a resale activity at an MWR event as prescribed in chapter 13-18 a., AR 215-1.

A resort with a casino wants to sponsor some outdoor recreation events.  Can we accept them?

AR 215-1, 11–8. j. states:  Sponsors are generally limited to firms and organizations involved with consumer products and/or services.  However, firms involved with games of chance or gambling to include casinos and Indian tribe gaming will not be permitted as sponsors.

Such offers should be discussed with your local attorney and his/her advice should be followed.

Complete Question:

A Resort Hotel wants to sponsor a few outdoor recreation activities.  They are a hotel/resort that has a casino in it and they have huge outdoor recreational opportunities: Golf, horseback riding, disc golf, zip lines, mountain biking, hiking.  Would we be able to allow them to sponsor if they strictly promoted outdoor recreational opportunities and the hotel?

Sponsorship Coordinators have a “hosting” account, correct?

Sponsorship managers should budget for their expense account in their annual operating budget.

It is authorized to pay for meals for sponsors out of the expense account and is actually good business, if you want to renew the sponsorship agreement.

You need to use the GLAC that you used to budget your expense account, most likely GLAC 744 for General Entertainment.  It also is advisable to budget for a sponsor recognition event if you plan on conducting one.  Consult your Financial Manager for the correct GLAC.

Complete Question:

Sponsorship Coordinators have a “hosting” account, correct?  We have some sponsors for the Volunteer Luncheon that will be attending the event.  Since it is a luncheon, I would like to provide them with a lunch as well but I don’t feel as if they should have to pay for it.  How is this situation handled?  Can I have the program manager charge my hosting account for the expense, and if so, what GLAC should I use for that.

Do we need to advertise for free for IHG?

IHG is a contractor and paid with appropriated funds.  In no circumstance can we provide free advertising nor use NAF resources to promote them.  If they want to purchase advertising from MWR, they are welcome to do so, just like any other advertiser.

Complete Question:

We were approached by IHG to advertise for them for free on our installation.  Is this something we need to do?

The local Mall asked us to sponsor an event off post. They want door prizes. Can we do this?

We are not authorized to use NAF (or APF) funds for non-MWR events.  Also, most of our programs are for authorized patrons only, so a cross promotion would not be very effective if the general population cannot take advantage of it.

Complete Question:

The local mall has asked our Outdoor Recreation to “sponsor” an event off post.  This is not an MWR event.  Can we do this?  They have asked us to provide a door prize in exchange for the cross promoting of ODR.

I have received e-mails from agencies for rates.  Can I give the information to these companies?

Such inquiries should be treated with caution.  There are several things to be considered:
1. No company is authorized to solicit on behalf of MWR or the Army; only the designated sponsorship manager is authorized to solicit sponsorship and/advertising for MWR events and programs.
2. If the company contacts you on behalf of a specific client, you can discuss what they are looking for and then do some research on this company (agency) via web/Better Business Bureau etc.   You may be surprised what you find if you google them.  Look at their other clients if they have a website; check their financials.  You should also go to the websites of their particular clients and check if these companies are indeed the client’s advertising or event agency.

3.  If you do the research and notice that the agency/company does not have a street address and you can’t find any information about them or about other clients, it probably is smart to stay away from them and not provide any information.

Unfortunately during the last couple of years a lot of companies (start-up companies) target the military think if they get the “in” and sell our assets, they have found a means to make a lot of money quickly.Stay away from such companies.

Complete Question:

I have received e-mails from agencies who want our rate card and want information about our events.  Can I give the information to these companies?  They say they want to help provide incremental revenues for MWR.

 
 

Can I still solicit sponsorship after I have accepted a new position?

That depends.  If there is an agreement that you remain the sponsorship POC in addition to your new position duties, your designation memo should reflect the change of your title and supervisor; if a new sponsorship coordinator is hired and designated, your designation memo must be revoked.

 

Complete Question:

I am the designated sponsorship coordinator at my garrison and accepted a new position.  Can I still continue to solicit sponsorship?

I have received requests from ACS for sponsorship for the 50th Birthday.  Is this allowed?

ACS as a program is NOT authorized sponsorship support.  There are two exemptions to policy for ACS programs: AFAP and AFTB.  The exemption was granted a long time ago by the Secretary of the Army.  To receive exemptions to policy involves a long, time-consuming process.

The first office you should go to if you get requests for sponsorship for unauthorized programs is your legal  office.  Your attorney can help you convey to the requesting manager that their program is not authorized sponsorship support (sponsorship dollars are NAF dollars and should be used for the NAFI only).  Your attorney can go up the chain to OSJA, HQ IMCOM G9 and you can always contact your Region POC or G9 Marketing.

Complete Question:

I have received requests from ACS for sponsorship for the 50th Birthday.  Am I allowed to get sponsorship for them?

Can I solicit sponsorship to provide golf carts to first responders at an MWR event?

Yes, you can solicit golf carts for your First Responders.Police and First Responders have to be part of the event and MWR must make sure that they get to where they might be needed.

Complete Question:

We work with Club Car which is a big sponsor for our Marine Mud Challenge event. They allow us 10+ golf carts (of variety) for anywhere from 4 days to 2 months at no cost.  Working with them is always a pleasure.  I have been approached to solicit sponsorship from them for our Independence Day Celebration for the Military Police and other First Responders.  As this is a MWR event and these units are here to secure and make safe the environment before, during and afterwards, is this okay for me to do although the first responders are being tasked to be there and are not a part of the event in such a way as sponsors are?

Can we name a building or a room in a building after a sponsor?

Naming buildings and/or rooms in the buildings fall under AR 1-33;  The Army Memorial Program.http://www.apd.army.mil/pdffiles/r1_33.pdf.  Buildings, rooms etc. can only be named after deceased persons.  Instead, title sponsorship of MWR events may be offered to sponsors whose contributions are significant.

 

Complete Question:

Coca-Cola wants to sponsor our 4th July event with a significant amount.Can we name a building or a room in a building the Coca-Cola Recreation Center?

May Army MWR Sponsorship managers sell sponsorship for officially hosted command sponsored events

No, except when the individual has specifically authorized the release of such information in writing.The attendee could fill out a request for information card, if such a benefit is provided the sponsor, or in the case of an authorized sweepstakes, the entry form could include an "opt-in" box which the attendee could elect to check, thereby authorizing/requesting additional information or requesting to be contacted by the sponsor.

An example of an opt-in clause is:Yes, I wish to receive additional information regarding the sponsor's line of products.

Complete Question:  

May Army MWR Sponsorship managers sell sponsorship for officially hosted command sponsored events (reference chapter 5-14 i., AR 215-1)?

What do I need to do if an agreement changes after it is signed?

If a sponsorship or advertising agreement is changed after all parties signed, you need to prepare an addendum to the original agreement.   An example is in the Desk Reference in Appendix J.  Only the terms that have been changed need to be in it.   You need to go through Legal prior to sending it to the sponsors/advertiser for signature.  Same process as the original agreement.

When do I need to write a Memorandum of Agreement (MOA) and when do I need a Sponsorship Agreement.

A sponsorship agreement generally is used for a commercial sponsor.  If there is a change to it after both parties signed, you need to write an amendment to the agreement, stating the change only and both parties have to sign again.  A MOA is usually written between government agencies.  An example was when the National Guard or SHARP sponsored the Soldier Show.  An MOA contains the same clauses as the sponsorship agreement, the only difference is that the sponsor is a government agency.  The same applies to advertising agreements.

Complete Question:

When do I need to write a Memorandum of Agreement (MOA) and when do I need a Sponsorship Agreement.  What if the agreement changes after it is signed?

Can our Accounting Technician record sponsorship income for Military Spouse Luncheon in GLAC 501?

Commercial sponsorship or advertising funds received from sponsors for events for which MWR partners with ACS are treated like any other sponsorship funds/income and have to be recorded in GLAC 553.  MWR is authorized to partner with ACS on events and may solicit sponsorship funds as long as the money stays with MWR in the MWR NAFI in GLAC 553 (or 557 for advertising).  The money received is not a donation - the sponsors receive exposure at these events which is prohibited for donations.

Many garrison MWRs partner with ACS on events such as Newcomer Briefings, Military Spouse Appreciation etc. and solicit sponsorship for the events.  That money cannot go to ACS but remains in MWR.  ACS is not authorized to receive sponsorship dollars.

Complete Question:

Our Accounting Technician insists to record sponsorship income for the Military Spouse Luncheon hosted by MWR in GLAC 501 under Donations instead of in GLAC 553 for sponsorship.  Can he do that?

Can I enter into an agreement with a company based out of Canada?

 
If we were talking about a foreign firm that had zero presence in the United States, then that the firm should not be solicited for sponsorship because that would clearly not be a U.S. firm.  DoDI 1015.10 and AR 215-1 only mention that sponsorship can be accepted from foreign firms at overseas garrisons, if the garrison commander approves.  Your case is more of a grey area since the regulation does not explicitly prohibit foreign firms from sponsoring.  Companies like Toyota, Hyundai, Bosch who have many offices in the US and the car manufacturers have US plants where they employ US workers, so we should be able accept (and have done so in the past with Scion basketball tournaments and Hyundai test drives) sponsorship from such companies.    Again, this is a grey area and the final decision is up to the local counsel.  Nowhere in a relevant regulation does it say that we cannot accept sponsorship support from foreign companies that have legitimate offices and pay taxes in the US.

Complete question:

I have a legal question before I get too far involved with a potential advertiser. I would like to be sure there is not a legal objection for MWR to enter into an advertising agreement with a company based out of Canada? The company is xxx and from what I have read they are a Canadian multinational information technology consulting, systems integration, outsourcing, and solutions company headquartered in Montreal, Quebec.  Their advertising would be patriotic in nature and would be sent to us for approval first.

Is a garrison authorized to have programs pay for their materials?

This is something you need to bring up with either your NAF Support Services Manager or your DFMWR.

Generally, yes, you can charge other programs.  The money should be transferred via TBA.

Am I allowed to solicit sponsors for Newcomer Briefings?

Generally speaking: No.

At some garrisons MWR uses the Newcomer Briefings to introduce new patrons to the services that MWR offers.  In that case, commercial sponsorship is authorized for the MWR part of the newcomer briefings only.  All sponsorship/advertising funds have to go into the NAFI.

Can I solicit sponsorship for ACS?

In general, ACS programs are not authorized for commercial sponsorship.  This includes the Newcomers’ Briefings, SOS, and SFAC.  However, there is a limited exemption for AFAP and AFTB where sponsorship is permitted.

Can I progress with communication with a university if they already work with the ESO?

If they are working with the education center, they most likely have already filled out the necessary forms with the ESO.  You still need to go to the education center and confirm with the ESO that it is OK for the university to sponsor your event.

Unless the agreement already includes all the events the school wants to sponsor, you should check for every agreement.

Complete Question:

A university representative has shared that they are currently involved with the Army Education Center and always look for other high-profile opportunities to share the information with the public.  Shall I progress with communication with the ESO and have them fill out this form prior to signing on the sponsor for any of our events.

Have you ever experienced that an on-post financial institution provided very little or no support ?

Yes, there are some garrisons where the on-post banks and credit unions have no desire to sponsor our events.  There is really nothing you can do.  They are encouraged to participate in events but don’t have to.

Many of the on-post banks and credit unions, however, provide support to the wounded warrior programs.  They see this as supporting the garrison.

Complete Question:

Have you ever experienced that an on-post financial institution provided very little or no support to the installation?

If we have an event off-post, can an off-post financial institution sponsor that event?

Yes, the policies only apply to events that happen on post.

Can I sell advertising to an off-post financial institution?

No.  Off-post financial institutions are prohibited from advertising, whether it is on the web, digital signage or through print per the Financial Management Regulation.

Only on-post financial institutions may purchase advertising from MWR.

Caution:  Ignoring the regulation might lead to also lose the right to solicit sponsorship from off-post financial institutions.  All agreements have to be coordinated with the local Banking Liaison Officer (BLO).

Complete Question:

A credit union approached our office and wants to advertise on our website.  Can you tell me if and what is allowed?

May an MWR sponsorship manager sell advertising and sponsorship to banks and credit unions?

Yes, but only to on-post financial institutions (banks, credit unions or savings and loans.)  On-post banks and credit unions are granted a certain level of protection from competition by DoD Directive 1000.11.  If there is no on-post financial institution, solicitation is permissible.

Promotions focusing around the Chase/Bank One Army MWR Club Card Program, or the Exchange charge card are permissible.

What are the sponsorship rules regarding alcohol sponsorships?

Alcohol sponsorships must be unsolicited.  Please reference AR 215-1, chapter 11-11 b. for additional information.   Also, remember that the local command has the final say as to as whether or not alcohol or any commercial sponsor or advertiser is accepted on an Army installation.

What type of companies should not be solicited for sponsorship?

  • Off-post financial institutions defined as banks, credit unions, and savings and loa institutions when there is an existing on-post financial institution
  • Alcohol and tobacco companies (we can work with alcohol and tobacco companies, however offers must be unsolicited)
  • Companies on your installation’s off-limits list
  • Companies on the Army banned list of sources
  • Generally companies that are not focused on consumer products (i.e. business to business, defense contractors) as described in chapter 11-8 j, AR 215-1.
  • Firms in direct competition with the Exchange; Commissary; or other Army/DoD activities 

May a private organization (PO) sell sponsorship?

Answer: A PO can raise funds on the installation in accordance with local guidance and consistent with the purpose statement contained in their charter, as approved by the SJA office. A PO can raise funds or obtain cash or donated products through solicitation of businesses outside the gate (unfortunately, in competition with your MWR efforts, but perfectly OK), but can not promise advertising exposure or public recognition on the installation to that business beyond the PO's membership or outside of the activity for which the solicitation is supporting. POs cannot conduct or compete with MWR events/activities and, therefore, cannot solicit donations or sponsorship on behalf of MWR events, nor can they misrepresent their affiliation/relationship with the installation in such a manner that the business believes that it is the installation and not a PO that is soliciting. POs and units may conduct a resale activity at an MWR event as prescribed in chapter 13-18 a., AR 215-1.

Which programs are MWR sponsorship and advertising managers authorized to sell?

Only MWR programs and events as recognized by AR215-1 may be sponsored or display advertisements and benefit from Commercial Sponsorship or Advertising. Refer to figure 3-1 MWR Programs, Section II Funding Categories in AR 215-1 for a list of MWR activities. However, the Department of Defense has permitted limited sponsorship for two non-MWR programs: Army Family Team Building (AFTB) and Army Family Action Plan (AFAP).

Who is authorized to sell sponsorship and advertising on the installation?

Only MWR sponsorship and advertising personnel who completed the online Marketing, Sponsorship and Advertising training; completed the annual ethics training; and who have been appointed in writing by an authorized installation command representative (such as the MWR Director) and who have a signed designation letter on file with IMCOM G9 Marketing are authorized to solicit and sell on behalf of Army MWR programs and events.

To maximize sponsorship support, it is prudent to only nominate the sponsorship and/or advertising manager to solicit sponsorship.  Program managers should not be designated for solicitation.

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