SSN Key Findings

Why Race Forward Corporate Language Is Not Enough

Policy field

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George Mason University

In early March 2018, just ahead of the Oscars, the National Hispanic Media Coalition staged a protest calling for more Latina/o nominees. The protest was not an isolated incident, but rather part of a broader struggle to widen the participation of minority groups in the U.S. media. As media conglomerates have merged in recent years, interest groups and social movements are challenging their growing power to shape minority representation.

In a 2011 merger between Comcast and NBC Universal, Comcast promised Latino organizations increased minority representation in a memorandum of understanding, but these promises have not be fulfilled. To ensure that companies like Comcast follow through with their promises, federal oversight must be expanded. Though racial parity in media representations is but one of many steps towards a more equal society, it makes a crucial difference. The media industry shapes social perceptions and sets an example for other industries. Federal oversight can help ensure constructive outcomes.

Comcast, Government Review, and Empty Promises to Latino Organizations

The Federal Communications Commission — known as the FCC for short — is the governmental agency where legal review of most media mergers takes place. Latina/os have been engaged in these battles for the last thirty years, as part of struggles waged in many settings to advance minority media representation and participation.

The FCC approved the 2011 merger between Comcast and NBC Universal with multiple conditions meant to uphold consumers’ rights. These conditions were couched within a memorandum of understanding — a formal, voluntary agreement between two or more parties that does not have any legal powers of enforcement. The memorandum stipulated that the merged company would provide new opportunities for communities of color and establish minority channels. Comcast also promised to include more Latina/os in multiple areas such as corporate governance, workforce development, procurement of third-party services, programming, and philanthropy.

As it worked to convince the FCC to approve the 2011 merger, Comcast consistently highlighted such promises to make their case. Certain Latina/o organizations even cited the memorandum of understanding in meetings they held with FCC officials urging the agency to approve the merger.

However, the memorandum of understanding was voluntary, even though it furthered merger. Some FCC commissioners explicitly praised the voluntary commitments, yet the FCC did not include requirements from the language or essence of the memorandum in its formal conditions for approval. By failing to include the language from the memorandum in its enforceable standards, the FCC freed Comcast of any binding obligations to diversify the media landscape. Simply put, the FCC did not require Comcast to do what they said they would do.

Racializing Media Policy

A critical dynamic at play is racialization. In short, racialization is the political process in which interest groups struggle for policy outcomes framed by racial categories. In Comcast’s case, the signal sent by the visibly racial requests from and promises to Latina/os were critical in the FCC’s approval of the merger. For Comcast, the memorandum of understanding reflected the economic interests of the company. Comcast used the “Latina/o” label to demonstrate that it was and would continue to focus on diversity. The company leaned on the racialization of the memorandum explicitly when it framed its two Latina/o -channels as part of their media portfolios, leveraging content from their other holdings to be sold to Latina/o audiences – when in reality they were showcasing recycled content rather than producing new, Latina/o-led content.

The power imbalance between Comcast and the Latina/o organizations who negotiated the memorandum demonstrates how structural inequalities are perpetuated along racial lines. Too often, when political or corporate interests are not held explicitly accountable for their promises to improve services to communities of color, those communities are left with the short end of the stick.

Comcast — and other companies in similar positions — have the power to decide the language and subject of memorandums, and frame them to suit their economic interests. As a result, Latino leaders adopted some of those goals into their strategies, which benefited Comcast in the long-run. The conversation and resultant memorandum were set on Comcast’s terms. Then, once Latino organizations signed on to the merger, Comcast championed a race-conscious commitment to diversity — a commitment to which it would never hold true, in part, because the FCC did not require it.


2016 report assessing the aftermath of the merger finds that Comcast failed to incorporate Latinos behind the camera, stereotyped portrayals increased in its film and television productions, and Latino leaders within the company were segregated and paid less. While it would seem that heightened attention to diversity and inclusion in media would be sufficient to hold companies accountable to their diversity commitments, it is clear that media policy must be reformed to include real, enforceable requirements.

Researchers must examine the role of racial frames in media mergers more closely, to help understand the extent to which companies may claim to value diversity but not invest in it.  

Media practitioners must recognize the role of racialization and racial framing and apply it to debates regarding ownership – particularly when media mergers are on the table and memorandum of understandings are used as tools to push legislative approval. Memorandums of understanding must bear stronger measures for accountability. If Comcast undergoes federal scrutiny when its conditions expire, then lawmakers must account for the lack of follow through when deciding what is valuable for its citizens.

Read more in Jason A. Smith and Randy Abreu, “MOU or an IOU? Latina/os and the Racialization of Media Policy,” Ethnic and Racial Studies 42, (2019).