Broadcasting Commission Letter addressed to Dominic Bell (Sonème (2007) Inc.)

Ottawa, 4 June 2019

BY EMAIL

Mr. Dominic Bell
Directeur Général
Sonème (2007) Inc.
456 Pont St.
Mont-Laurier, Québec   J9L 2R8
dbell@cflo.ca

Re: Audit of Sonème (2007) Inc. (Sonème) tangible benefit requirements for the 2012-2013 and 2013-2014 broadcast years

Dear M. Bell:

As part of its annual audit of Sonème’s radio tangible benefit contributions, the Commission recently reviewed the licensee’s contributions for the 2012-2013 and 2013-2014 broadcast years imposed on Sonème as a result of the ownership transaction approved via administrative letter dated 10 September 2007.  During this audit, Commission staff identified issues with several expenditures claimed towards meeting Sonème’s CCD tangible benefit requirements.  You were notified of this apparent non-compliance by Commission staff letter dated 27 July 2017 and responded by email dated 7 August 2017.

This letter is to inform you that the Commission finds that certain expenditures made by Sonème towards meeting its tangible benefit obligations in the 2012-2013 and 2013-2014 broadcast years were ineligible based on the Commercial Radio Policy, 2006. Footnote1

The Commission does not necessarily dispute the eligibility of any of the initiatives or CCD recipients below; rather, the non-compliance stems from a lack of supporting documentation and the self-serving nature of some of the expenditures.

Below is a breakdown of the ineligible expenditures:

Lack of Documentation: The licensee did not provide sufficient documentation regarding the live performances, the artists who performed, or the eligibility of the expenses in order to demonstrate that the expense met the criteria outlined in the Commercial Radio Policy, 2006.

Broadcast year Recipient Amount ($)
2012-2013 Lumi-son 120
2012-2013 Lumi-son 200
2012-2013 Lumi-son 300
2012-2013 Lumi-son 100
2012-2013 MC MusiClairage 280
2013-2014 Lumi-son 1,250
  Sub-total 2,250

Self-serving expenditures: Expenditures for artists solely performing on the licensee’s station are not eligible. Performances must be public and a performance on the station is self-serving because CCD funds are being used to improve the station’s ongoing programming. In addition, some expenditures were related to paying on-air talent to travel to interview Canadian artists and the interviews were then aired on the station.

Broadcast year Recipient Amount ($)
2012-2013 Carburant de Karim Ouellette 82
2012-2013 restaurant St-Hubert 83
2012-2013 Carburant 30
2012-2013 Repas [Le Faim Gourmet] 201
2013-2014 Repas de Clément Jacques 53
  Sub-total 449
  Total 2,699

As a result of these findings, the Commission directs Sonème to pay the total shortfall of $2,699 within 30 days of the date of the letter, as follows:

In addition, the Commission directs Sonème to file proof of payment for the total tangible benefit shortfall ($2,699), with the Commission, within 60 days of the date of this letter.

Further information on CCD contributions and eligible initiatives can be found on the CRTC website: http://www.crtc.gc.ca/ENG/GENERAL/ccdparties.htm

The Commission reminds Sonème that failure to supply sufficient documentation to support the eligibility of Sonème’s contributions for future broadcast years may result in the Commission finding those contributions ineligible and may affect its compliance with regulatory obligations. 

Lastly, it should be noted that the determinations set out in this letter address only the 2012-2013 and 2013-2014 broadcast years and do not relate to any subsequent broadcast years. 

Yours sincerely,

Claude Doucet
Secretary General

c.c.

Ms. Julie Prévost
administration@cflo.ca

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