Federal Communications Commission DA 17-14
Before the
Federal Communications Commission
Washington, D.C. 20554
In the Matter of Complaints Involving the Political 
Files of
WCNC-TV, Inc., licensee of Station 
WCNC-TV, Charlotte, NC
Scripps Media, Inc., licensee of Station 
KMGH-TV, Denver, CO
Fox Television Stations, Inc., licensee of Station 
KMSP-TV, Minneapolis, MN
New World Communications of Tampa, Inc., 
licensee of Station WTVT(TV), Tampa, FL
Media General Communications Holdings, LLC, 
licensee of Station WFLA-TV, Tampa, FL 
NBC Telemundo License, LLC, licensee of Station 
WTVJ(TV), Miami, FL
WTVD Television, LLC, licensee of Station 
WTVD(TV), Durham, NC
CBS Broadcasting, Inc., licensee of Station 
WWJ-TV, Detroit, MI 
Scripps Media, Inc., licensee of Station KNXV-TV, 
Phoenix, AZ
Hearst Properties, Inc., licensee of Station 
WMUR-TV, Manchester, NH; and
Graham Media Group, Michigan, Inc., licensee of 
Station WDIV-TV, Detroit, MI
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File No. 140502J
File No. 140502H
File No. 140502K
File No. 140502F
File No. 140502E
File No. 140502C
File No. 140502L
File No. 140502G
File No. 140502B
File No. 140502D
File No. 140502A
MEMORANDUM OPINION AND ORDER
Adopted:  January 6, 2017  Released:  January 6, 2017
By the Chief, Media Bureau:
I. INTRODUCTION
1. In this Memorandum Opinion and Order (Order), we resolve 11 complaints that were 
filed jointly by Campaign Legal Center and Sunlight Foundation (Complainants) against each of the
Federal Communications Commission DA 17-14
2
captioned commercial television broadcast station licensees.
1
  The complaints allege that the licensees 
violated Section 315(e) of the Communications Act of 1934, as amended (the Act), and/or Section
73.1212(e) of the Commission’s rules,
2
by failing to maintain certain information in their political files.  
Because the complaints raise similar issues, we consolidate our consideration of them.    
2. Before addressing the individual complaints, we clarify certain disclosure obligations that 
the Act and the Commission’s rules impose on broadcast licensees with respect to the purchase of 
broadcast time by legally qualified candidates for elective office and issue advertisers.
3
  We believe this 
guidance will facilitate licensees’ compliance with the political file requirements and improve public 
access to information about political matters of national importance.  Specifically, we clarify that:
? For each request to purchase broadcast time that triggers disclosure obligations under 
Section 315(e)(1)(B) of the Act, licensees must include in their political files the names 
of all candidates (and the offices to which they are seeking election), all elections, and all
national legislative issues of public importance to which the communication refers.
? Under Section 315(e)(2)(G) of the Act and Section 73.1212(e) of the Commission’s rules,  
licensees must disclose all of the chief executive officers or members of the executive 
committee or board of directors of any person seeking to purchase broadcast time under 
Section 315(e)(1)(B).  In cases where a station initially is given the name of a single 
official of a sponsoring entity, or otherwise has a reasonable basis for believing that the 
information initially provided is incomplete or inaccurate, the station is obligated to 
inquire whether there are any other officers or members of the executive committee or of 
the board of directors of such entity.  
? We will consider context in determining whether an advertisement constitutes a “political 
matter of national importance” that triggers record-keeping obligations under Section 
315(e)(1)(B) of the Act.  A broadcast message must be “political” in nature and must be 
of “national importance” to trigger a licensee’s record-keeping obligations under Section 
315(e)(1)(B).  For purposes of Section 315(e)(1)(B), an issue need not be subject to 
pending or proposed legislation in order to be considered a “national legislative issue of 
public importance.” This term also encompasses other political issues that are the subject 
of continuing controversy or discussion at the national level.
3. Although some of the above-captioned licensees failed to make disclosures in a manner 
that was consistent with these clarifications, we do not take enforcement action with respect to those 
instances.  We place entities subject to these requirements on notice that, going forward, they will be 
subject to enforcement action for willful and/or repeated failure to comply with their political file 
obligations, as clarified here.  In addition, we admonish the licensees of nine stations for their willful 
and/or repeated violations of Section 315(e) of the Act for actions not implicated by the clarifications we 
                                                     
1
Complaints filed by Campaign Legal Center and Sunlight Foundation on May 1, 2014.  Each of the captioned 
licensees filed an Answer on May 27, 2014, and Complainants submitted a Consolidated Reply on June 3, 2014.
2
47 U.S.C. § 315(e); 47 CFR § 73.1212(e).
3
Several parties in this proceeding have asserted that the political file requirements are vague and that the 
Commission thus should issue a Public Notice or other advisory clarifying those requirements.  KMSP-TV Answer 
at 3-4; WTVD(TV) Answer at 4; WTVT(TV) Answer at 3-4. Because we clarify those requirements herein, we find 
that no further action to clarify them is warranted at this time.
Federal Communications Commission DA 17-14
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make in this Order.
4
II. BACKGROUND
4. Broadcast licensees have long been required by the Communications Act and the 
Commission’s rules to maintain political files for public inspection.
5
  The information in political files 
enables the public to obtain information about sponsoring entities and to verify that licensees have 
complied with their obligations relating to use of their broadcast facilities by candidates for political 
office and by others for specified political purposes.
6
  
5. Section 315(e) of the Act requires licensees to maintain political files for certain types of 
advertisements.  Specifically, pursuant to Section 315(e)(1):
A licensee shall maintain, and make available for public inspection, a complete record of 
a request to purchase broadcast time that –
(A)  is made by or on behalf of a legally qualified candidate for public office; or
(B)  communicates a message relating to any political matter of national importance, 
including –
(i)  a legally qualified candidate;
(ii) any election to Federal office; or
(iii) a national legislative issue of public importance.
7
As to each such request, Section 315(e)(2) requires broadcast licensees to place in their political files the 
following information:
(A)  whether the request to purchase broadcast time is accepted or rejected by the 
licensee;
(B)  the rate charged for the broadcast time;
(C)  the date and time on which the communication is aired;
(D)  the class of time that is purchased;
                                                     
4
Those stations are KMSP-TV (Minneapolis, MN); WTVT(TV) (Tampa, FL); WFLA-TV (Tampa, FL); 
WTVJ(TV) (Miami, FL); WTVD(TV) (Durham, NC); WWJ-TV (Detroit, MI); KNXV-TV (Phoenix, AZ); WMUR-
TV (Manchester, NH); and WDIV-TV (Detroit, MI).
5
Although the instant complaints involve only broadcast licensees, we note that the obligation to maintain political 
files for public inspection also applies to cable television system operators engaged in origination cablecasting (see
47 CFR § 76.1701); Direct Broadcast Satellite providers (see 47 CFR § 25.701(d)); and satellite radio licensees (see
47 CFR § 25.702(b)).  The guidance provided in this Order is intended to assist all such entities in complying with 
their political file record-keeping obligations.
6
In the Matter of Review of the Commission’s Rules Regarding the Main Studio and Local Public Inspection Files 
of Broadcast Television and Radio Stations, Report and Order, 13 FCC Rcd 15691 (1998).
7
47 U.S.C. § 315(e)(1).  Congress adopted the current version of Section 315 as part of the Bipartisan Campaign 
Reform Act of 2002 (BCRA), Pub. L. No. 107-155, 116 Stat. 81 (2002), which was signed into law in 2002.  The 
BCRA, among other things, amended Section 315 by codifying the Commission’s already-existing record-keeping 
requirements for any request to purchase broadcast time that “is made on or behalf of a legally qualified candidate 
for public office.”  The BCRA further amended Section 315 by expanding record-keeping requirements to include 
any request to purchase broadcast time that “communicates a message relating to any political matter of national 
importance including (i) a legally qualified candidate; (ii) any election to Federal office; or (iii) a national legislative 
issue of public importance.”  Id.
Federal Communications Commission DA 17-14
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(E)  the name of the candidate to which the communication refers and the office to which 
the candidate is seeking election, the election to which the communication refers, or 
the issue to which the communication refers (as applicable);
(F)  in the case of a request made by, or on behalf of, a candidate, the name of the 
candidate, the authorized committee of the candidate, and the treasurer of such 
committee; and
(G) in the case of any other request, the name of the person purchasing the time, the 
name, address, and phone number of a contact person for such person, and a list of 
the chief executive officers or members of the executive committee or of the board 
of directors of such person.
8
6. In addition, Section 315(e)(3) of the Act provides, among other things, that “[t]he 
information required by [Section 315(e)] shall be placed in a political file as soon as possible.”
9
  Section 
73.1212(e) of the Commission’s rules requires that, when a station broadcasts material that is “political 
matter or matter involving the discussion of a controversial issue of public importance and a corporation, 
committee, association or other unincorporated group, or other entity is paying for or furnishing the 
broadcast matter, the station shall . . . [maintain] a list of the chief executive officers or members of the 
executive committee or of the board of directors of the corporation, committee, association or other 
unincorporated group . . . for public inspection.”
10
7. All of the stations subject to the complaints we resolve in this Order are within the top 50
Designated Market Areas and are owned by or affiliated with one of the four major television broadcast 
networks.  The stations, therefore, were required to place their political records in a Commission-hosted 
online public file beginning August 2, 2012.
11
    
III. DISCUSSION
A. Standing
8. Before addressing the merits of the complaints, we resolve the threshold procedural issue 
of whether Complainants have legal standing to bring the complaints.
12
  The licensees of stations 
                                                     
8
47 U.S.C. § 315(e)(2).
9
Id. § 315(e)(3).
10
47 CFR § 73.1212(e).  See also id. § 73.1943.
11
Standardized and Enhanced Disclosure Requirements for Television Broadcast Licensee Public Interest 
Obligations, Second Report and Order, 27 FCC Rcd 4535 (2012) (Enhanced Disclosure Order).  In addition to 
broadcast television licensees, the Commission requires broadcast radio licensees, Direct Broadcast Satellite 
providers, and Satellite Digital Audio Radio Services to upload their political files to the Commission’s online 
database.  Expansion of Online Public File Obligations to Cable and Satellite TV Operators and Broadcast and 
Satellite Radio Licensees, Report and Order, 31 FCC Rcd 526 (2016) (Expanded Online File Order); Effective Date 
Announced for Expanded Online Public Inspection File Database, Public Notice, DA 16-536, rel. May 12, 2016.
12
In general, standing refers to a complainant’s direct interest in the matter that is the subject of the complaint.  
Implementation of Section 255 of the Telecommunications Act of 1996; Access to Telecommunications Services, 
Telecommunications Equipment, and Customer Premises Equipment by Persons with Disabilities, WT Docket No. 
96-198, Notice of Proposed Rulemaking, 13 FCC Rcd 20391, 20457, n.261 (1998).  See also Petition for 
Rulemaking to Establish Standards for Determining the Standing of a Party to Petition to Deny a Broadcast 
Application, Memorandum Opinion and Order, 82 F.C.C.2d 89, 95–96 (1980) (“[T]o establish standing a litigant 
must allege a threatened or actual injury to himself, whether economic, aesthetic or otherwise, that is likely to be 
prevented or redressed by a favorable decision.  So long as these requirements are satisfied, persons to whom 
Congress has granted a right of action may have standing to seek relief on the basis of the legal rights of others, and 
indeed, may invoke the general public interest in support of their claim.”) (citations omitted).
Federal Communications Commission DA 17-14
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WTVT(TV) and KMSP-TV assert that the complaints against them are defective because Complainants 
have not demonstrated that they would be harmed by any failure of the stations to comply with the 
political file rules.  In particular, they contend that the online public file requirements were intended to 
allow consumers to more easily locate the political and public files of stations within their viewing area 
and to access in one location information about all broadcast stations within a viewer’s market.
13
  Because 
Complainants are not consumers within either station’s viewing area, they assert, “the advertisement at 
issue was not intended to be viewed by Complainants and the Complaint should not serve as the basis for 
any FCC action.”
14
9. We conclude that Complainants have standing to bring the complaints.  In contrast to
contexts in which Congress or the Commission has established specific standing requirements,
15
nothing 
in the Act, the Commission’s public file rules, or Commission precedent requires a complainant to 
demonstrate that he or she resides within a station’s viewing area to file a complaint for violation of the 
political file rules.  As noted above, Section 315(e)(1) of the Act requires licensees to maintain, and make 
available “for public inspection,” records of certain requests to purchase broadcast time.
16
  Because such 
records must be kept for inspection by the general public, and nothing in Section 315(e)(1) expressly 
limits the scope of entities entitled to bring complaints, we believe that Congress intended to permit any 
interested member of the public, including persons located outside of a station’s market, to bring 
complaints for alleged violations of Section 315’s record-keeping requirements.  
10. In addition, we find that accepting complaints only by consumers within a station’s 
viewing area would hinder the Commission’s ability to ensure that stations are complying with the 
political and public file requirements and are properly discharging their duty to operate in the public 
interest.
17
  This conclusion is consistent with the Commission’s previous determination that a station’s 
public file not only serves members of a broadcast station’s community of license, but also is “a tool for 
the larger media policy community,” including “public advocacy groups, journalists, and researchers” 
who “act in part as surrogates for the viewing public in evaluating and reporting on broadcast stations’ 
performance.”
18
  A station’s failure to comply with the political and public file rules could impede the 
                                                     
13
WTVT(TV) Answer at 3 n.8; KMSP-TV Answer at 3, n.8.
14
Id.
15
For example, the Commission has established standards by which consumers may qualify as parties-in-interest 
with standing to file a petition to deny a license application under Section 309(d)(1) of the Act.  See, e.g., 
Applications for Consent to Transfer of Control from License Subsidiaries of Allbritton Communications Co. to 
Sinclair Television Group, Inc., MB Docket No. 13-203, Memorandum Opinion and Order, 29 FCC Rcd 9156, 9162 
(MB 2014).
16
47 U.S.C. § 315(e)(1).  See also 47 CFR § 73.1212(e) (requiring, among other things, that licensees “[make] 
available for public inspection” a list of the chief executive officers or other specified officials) (emphasis added).
17
Id.
18
Enhanced Disclosure Order, 27 FCC Rcd at 4545. See also Expanded Online File Order, 31 FCC Rcd at 528, 
para. 5 (“To provide the public with access to information about station operations, the Commission’s rules have 
long required television and radio broadcast stations to maintain a physical public inspection file, including a 
political file, at their respective stations or headquarters and to place in the file records that provide information 
about station operations.  The purpose of the public inspection file requirement is to ‘make information to which the 
public already has a right more readily available, so that the public will be encouraged to play a more active part in 
dialogue with broadcast licensees.’”) (emphasis added). In an analogous case involving the Commission’s broadcast 
contest rule, the Commission’s Enforcement Bureau rejected a radio station’s argument that only those individuals 
residing within a station’s listening area have standing to file a complaint.  See CBS Radio Inc. of Philadelphia, 
Licensee of Station WIP(AM), Philadelphia, Pennsylvania, Memorandum Opinion and Order, 24 FCC Rcd 10993 
(EB 2009).  The Enforcement Bureau found that “the contest rule is designed to protect the general public” from 
Federal Communications Commission DA 17-14
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efforts of public interest or research groups to analyze information and report on how local stations serve 
their communities, to the detriment of the public.  Complainants Campaign Legal Center
19
and Sunlight 
Foundation
20
are among the entities the political and public file requirements are intended to serve.
21
  For 
these reasons, we find that Complainants have standing to bring the complaints.
B. Clarification of Political File Requirements
11. We clarify below certain disclosure obligations that the Act and/or the Commission’s
rules impose on broadcast licensees with respect to requests for the purchase of broadcast time by legally 
qualified candidates for elective office and issue advertisers.
22
  The complaints generally allege that the 
licensees failed to meet their obligations under Section 315(e)(2) of the Act and/or Section 73.1212(e) of 
our rules.  Resolution of the complaints turns on the appropriate interpretation of those provisions, and the 
record reveals that parties have varying interpretations about the nature and extent of the obligations that 
they impose.  Accordingly, we take this opportunity to clarify those obligations.
23
  In so doing, we place 
licensees on notice that, going forward, they will be subject to enforcement action for willful and/or 
repeated failure to comply with their political file disclosure obligations, as clarified here. 
1. Contents of Political Records Required by Section 315(e)(2)(E)  
12. We clarify that, for each request to purchase broadcast time that triggers disclosure 
obligations under Section 315(e)(1), licensees are required, pursuant to Section 315(e)(2)(E), to include in 
their political record the names of all candidates (and the offices to which they are seeking election), all 
elections, and all national legislative issues of public importance to which the communication refers.  
Complainants maintain that Section 315(e)(2)(E) requires licensees to include all of these categories of 
information in their political records for each relevant request for air time and that several of the licensees 
failed to satisfy this obligation.
24
  By contrast, licensees argue that the language of Section 315(e)(2)(E) 
indicates that Congress intended to afford licensees the discretion to selectively identify in their political 
record any one -- but not necessarily all -- of the categories of information listed in that provision.
25
  As 
discussed below, we find that the text and design of Sections 315(e)(1) and (e)(2) support a broader 
                                                                                                                                                                          
false or misleading contests and “does not preclude any member of the public from filing a complaint if they have 
information establishing that a contest rule violation has occurred.”  Id. at 10994-95.
19
The Campaign Legal Center is a “nonpartisan, nonprofit organization that promotes awareness and enforcement 
of political broadcasting laws” whose mission is “to represent the public interest in the enforcement of media and 
campaign laws.”  KMGH-TV Complaint at 1.  Through public education, advocacy for federal rulemaking 
proceedings, and congressional action, the Campaign Legal Center “seeks to shape political broadcasting policies 
and promote effective enforcement of the public interest obligations of the media.”  Id.
20
The Sunlight Foundation is a “nonpartisan nonprofit that advocates for open government globally and uses 
technology to make government more accountable to all.”  Id. at 2.  The foundation seeks to accomplish these goals 
“by building tools that empower democratic participation and by working with policymakers and civil society 
organizations to employ a technology-centric and transparency-oriented approach to their work.”  Id.
21
Supra n. 18.
22
We note that the requirements clarified in this section are alleged to have been violated by one or more licensees.
23
As noted above, we do not take enforcement action in instances in which one or more of these licensees has failed 
to satisfy a requirement that we clarify in this Order.
24
Complainants’ Consolidated Reply at 2-3 (claiming that certain licensees disclosed the legally qualified 
candidates referenced in advertisements that they broadcast, but not other political matters of national importance 
referenced in those ads).
25
WCNC-TV Answer at 2; WTVD(TV) Answer at 3-4; KMSP-TV Answer at 3; WDIV-TV Answer at 2; WWJ-TV 
Answer at 2, n.1; WFLA-TV Answer at 3-4.
Federal Communications Commission DA 17-14
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interpretation that favors disclosure.  
13. As a threshold matter, we note that Section 315(e)(1)(B) requires licensees to maintain a 
record of requests for broadcast time that “communicate[] a message relating to any political matter of 
national importance,”
26
including (i) a legally qualified candidate;
27
(ii) any election to Federal office;
28
or 
(iii) a national legislative issue of public importance.
29
  As to each such request, Section 315(e)(2) 
requires broadcast licensees to place in their record certain information specified in Section 315(e)(2), 
including information identified in Section 315(e)(2)(E).
30
  Section 315(e)(2)(E) states that the contents of 
a licensee’s record must include “the name of the candidate to which the communication refers and the 
office to which the candidate is seeking election, the election to which the communication refers, or the 
issue to which the communication refers (as applicable).”
31
  The three categories listed in that provision 
(i.e., candidate/election/issue) mirror the three kinds of messages listed in Section 315(e)(1)(B) that 
trigger Section 315(e)(2)(E)’s record-keeping requirement.
32
  
14. Based on the language and structure of the statute, we interpret Section 315(e)(2)(E) to 
require that, in cases in which a political broadcast message includes references to more than a single 
candidate, election, and/or issue, a licensee must disclose all such references that apply.
33
  Because, as 
noted above, the record-keeping requirements in Section 315(e)(2)(E) are triggered by a request to 
purchase broadcast time that communicates any one of three kinds of messages listed in Section 
315(e)(1)(B), the record that licensees are required to maintain under Section 315(e)(2)(E) must reflect 
the type of request made.  Thus, for example, if the request to purchase broadcast time communicates a 
message relating to a “legally qualified candidate,”
34
then under Section 315(e)(2)(E), the record must 
contain “the name of the candidate to which the communication refers and the office to which the 
candidate is seeking election.”
35
  Similarly, if the request to purchase broadcast time communicates a 
message relating to an “election to Federal office,”
36
then under Section 315(e)(2)(E), the record must 
contain information regarding “the election to which the communication refers.”
37
  And if the request to 
purchase broadcast time communicates a message relating to “a national legislative issue of public 
importance,”
38
then under Section 315(e)(2)(E), the record must contain information regarding “the issue 
                                                     
26
47 U.S.C. § 315(e)(1)(B) (emphasis added).
27
Id. § 315(e)(1)(B)(i).
28
Id. § 315(e)(1)(B)(ii).
29
Id. § 315(e)(1)(B)(iii).
30
See id. § 315(e)(2)(A)-(E), (G).
31
Section 315(e)(2) prescribes the content of the political record for each request to purchase broadcast time that 
triggers disclosure obligations under Section 315(e)(1).  Id. § 315(e)(1), (e)(2). The type of “issues” to which 
Section 315(e)(2)(E) refers are those involving “national legislative issues of public importance,” as referenced in 
Section 315(e)(1)(B)(iii).
32
Compare 47 U.S.C. § 315(e)(2)(E) with 47 U.S.C. § 315(e)(1)(B).
33
Complainants’ Consolidated Reply at 2-3 (arguing that the phrase “as applicable” means that “stations must 
disclose the candidate, election, or issue in its political file as each portion of the section applies to the ad in 
question”) (emphasis in original).
34
47 U.S.C. § 315(e)(1)(B)(i).
35
Id. § 315(e)(2)(E).
36
Id. § 315(e)(1)(B)(ii).
37
Id. § 315(e)(2)(E).
38
Id. § 315(e)(1)(B)(iii).
Federal Communications Commission DA 17-14
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to which the communication refers.”
39
  We believe that use of the conjunction “or” in Section 
315(e)(2)(E), coupled with the parenthetical “as applicable,” reflects Congress’s intent that the nature of 
the record should reflect the type of message that triggered the record-keeping requirement.  Consistent 
with this interpretation, if the relevant request is for broadcast time that communicates a message relating 
to more than one type of political matter of national importance specified in Section 315(e)(1)(B), then 
the licensee’s record similarly must contain information concerning all of the types of messages 
communicated that are covered by the statute, “as applicable.”
40
   
15. We are not persuaded that the language of Section 315(e)(2)(E) compels a more limited
interpretation of licensees’ obligations.  Some licensees argue, for example, that because the items listed 
in Section 315(e)(2)(E) are connected by the word “or,” rather than “and,” those items represent 
alternatives, and that a licensee satisfies its Section 315(e)(2)(E) obligation by including in its political 
record any one of those listed items.
41
  We disagree with this interpretation.  Although use of the word 
“or” in a statute typically carries a disjunctive meaning, the parallel language in Sections 315(e)(1)(B) and 
(e)(2)(E), together with Congress’s inclusion of the phrase “as applicable” in Section 315(e)(2)(E), lead 
us to adopt a different interpretation here.  In particular, based on the text and design of Section 315(e)(1), 
we find that use of the word “or” in Section 315(e)(2)(E) was intended to signify that a licensee need only 
maintain a record of the information relevant to the particular triggering message.  Thus, for example, if 
the triggering message relates only to a national legislative issue of public importance,
42
then the licensee 
would be required to maintain in its record only information relating to that issue; it would not need to 
maintain information concerning a candidate or an election because neither is mentioned in the ad.  We, 
therefore, agree with Complainants that Congress’s use of the word “or” was intended to account for the 
fact that not all messages subject to Section 315’s record-keeping requirements will mention a candidate, 
an election, and an issue.
43
  Moreover, we conclude that the reading of Section 315(e)(2)(E) urged by 
licensees would be at odds with Congress’s directive that licensees disclose all “applicable” references to 
candidates (and their offices), elections, and/or issues to which the triggering message refers.  
16. We also find that interpreting the statute to afford licensees the discretion to choose what 
information they will disclose under Section 315(e)(2)(E) would undermine the requirement that licensees 
maintain, and make publicly available, a “complete” record of certain requests to purchase broadcast 
time.
44
  Under licensees’ interpretation, for example, a licensee that receives a request to purchase 
broadcast time that communicates messages relating to both a legally qualified candidate and a national 
legislative issue of public importance (such as proposals to balance the federal budget) could discharge its 
Section 315(e)(2)(E) obligation by keeping a record indicating that the relevant message related to 
balancing the federal budget, yet omitting the name of the candidate mentioned and the office sought by 
that candidate.  We reject that interpretation.  We believe that the more reasonable reading of Section 
315(e)(2)(E) is that it requires licensees to identify in its record each and every category of information 
that is implicated by the message communicated (as signified by the phrase “as applicable”).  As 
explained above, we are not persuaded that the word “or” was intended to authorize licensees to choose 
what information to include in their records.  We agree with Complainants that such an interpretation of 
                                                     
39
Id. § 315(e)(2)(E).
40
Id. § 315(e)(2)(E).
41
See e.g.,WCNC-TV Answer at 2.  See alsoWDIV-TV Answer at 2 (asserting that “use of the disjunctive 
indicates alternatives and requires [that the listed items] be treated separately unless such a construction renders the 
provision repugnant to the Act”).  
42
47 U.S.C. § 315(e)(1)(B)(iii).
43
Complainants’ Consolidated Reply at 2, n.4.
44
47 U.S.C. § 315(e)(1).
Federal Communications Commission DA 17-14
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Section 315(e)(2)(E)’s obligations could “mislead and misinform the public” by reducing the amount of 
information available about political broadcast messages.
45
  No licensee has argued otherwise or put forth 
policy reasons that would support their interpretation of Section 315(e)(2)(E).
17. We also are not persuaded that, because each of the items listed in Section 315(e)(2)(E) is 
written in the singular tense, the Commission must construe that provision as requiring licensees to 
identify in their political record only one item from any of the three categories, even if a broadcast 
message references multiple candidates, elections, and/or issues.
46
  Under basic canons of statutory 
construction, the use of singular tense generally includes the plural tense, and vice versa.
47
  We find 
nothing to suggest that Congress intended a different result here.  Thus, the fact that Section 315(e)(2)(E) 
is written in the singular tense is not dispositive of the question whether all of the categories listed in that 
provision must be identified in a licensee’s record.
18. Finally, we are not convinced by the arguments of some licensees that requiring 
disclosure of all candidates, elections and issues referenced in each political broadcast message would be 
too onerous.
48
  We find that requiring stations to make all such information, as applicable, available to the 
public is reasonable and not unduly burdensome for licensees.  We note that licensees already are 
obligated to review the content of programming covered by Section 315(e) to confirm that information 
furnished by advertisers is complete.
49
  Additionally, most advertisements, even those that cover multiple 
categories, are typically only 30 or 60 seconds in duration.  Thus, reviewing the content of such ads for 
the purpose of identifying all candidates, elections, and issues, as applicable, would not be unduly 
burdensome for licensees.   In any event, given that Section 315(e)(2)(E) requires licensees to identify all 
candidates, elections and/or issues, as applicable, we do not have discretion to permit licensees to provide 
less than the statutorily-required information. 
19. Based on the above reasoning, we interpret Section 315(e)(2)(E) to require that licensees 
include in their political records: (i) the names of all candidates referenced in the broadcast message; (ii) 
the respective offices to which all such candidates are seeking election; (iii) all elections referenced in the 
broadcast message; and (iv) all national legislative issues of public importance referenced in such 
message.  We find that this interpretation best achieves Congress’s directive that licensees maintain 
“complete” political records containing all applicable information, and will most effectively ensure public 
access to comprehensive information memorializing the contents of each political broadcast message.
2. List of Officers or Other Officials Required by Section 315(e)(2)(G) 
20. We clarify that Section 315(e)(2)(G) of the Act and Section 73.1212(e) of the 
                                                     
45
Complainants’ Consolidated Reply at 3.
46
See, e.g., WTVD(TV) Answer at 3-4.
47
See 1 U.S.C. § 1; Public Citizen, Inc. v. Mineta, 340 F.3d 39, 54 (2d Cir. 2003).
48
See, e.g., WTVD(TV) Answer at 3-4 (asserting that it would be impractical and inappropriate to impose on 
broadcasters the obligation to identify and describe every “political issue of national importance” to which a
broadcast message refers because “political advertisements often include quick references to a myriad of issues and 
votes”). 
49
For example, in order to ensure that they provide appropriate on-air sponsorship identification, licensees must 
necessarily review candidate and issue advertisements that they intend to broadcast.  See 47 U.S.C. § 317 (requiring 
the licensee to identify, at the time of broadcast, those who furnished or paid for the broadcast, and exercise 
reasonable diligence to obtain from its employees information necessary to enable the licensee to make the required 
announcement); 47 CFR § 73.1212 (requiring the licensee that receives consideration for transmitting any matter to 
“fully and fairly disclose the true identity” of the person(s) or entity whom or for whom the consideration was 
supplied, and to exercise reasonable diligence in obtaining such information from its employees in order to make the 
announcement).
Federal Communications Commission DA 17-14
10
Commission’s rules
50
require broadcast licensees to maintain a record that identifies, among other 
things,
51
all of the chief executive officers or members of the executive committee or board of directors of 
any person seeking to purchase broadcast time under Section 315(e)(1)(B).  The record reflects that 
parties have differing views of the obligations that these provisions impose on broadcast licensees.  
Although no party disputes that Section 315(e)(2)(G) of the Act and Section 73.1212(e) of the 
Commission’s rules require licensees to maintain a list of specified officials of the sponsor in their 
political files,
52
at least one party suggests that those provisions impose no obligations on licensees 
beyond disclosing the information supplied by sponsoring entities.
53
  Under that interpretation, if the 
sponsor provides the name of only one executive officer or board member, disclosure of that name 
suffices for purposes of these provisions.  By contrast, Complainants assert that licensees are obligated to 
obtain the requisite information in cases where material provided by a sponsoring entity is insufficient.
54
21. Section 315(e)(2)(G) provides, with respect to requests for broadcast time other than 
those made by or on behalf of candidates, that a licensee shall maintain “a list of the chief executive 
officers or members of the executive committee or of the board of directors of” the entity requesting 
broadcast time.
55
  In addition, Section 73.1212(e) of our rules provides that:
[w]here material broadcast is political matter or matter involving the discussion of a 
controversial issue of public importance and a corporation, committee, association or 
other unincorporated group, or other entity is paying for or furnishing the broadcast 
matter, the station shall . . . [make available for public inspection] a list of the chief 
executive officers or members of the executive committee or of the board of directors of 
the corporation, committee, association or other unincorporated group. . . .
56
  
22. Given that Section 315(e)(2)(G) of the Act and Section 73.1212(e) of our rules expressly 
require that licensees maintain a “list” of specified officials, we conclude that, in cases where a licensee 
initially is given the name of a single official of a sponsoring entity,
57
or otherwise has a reasonable basis 
for believing that the information initially provided is incomplete or inaccurate, the licensee has an 
obligation to inquire whether there are any other officers or members of the executive committee or of the 
                                                     
50
47 U.S.C. § 315(e)(2)(G); 47 CFR § 73.1212(e).
51
Section 315(e)(2)(G) also requires licensees to disclose the name and certain contact information for the 
sponsoring entity.  47 U.S.C. § 315(e)(2)(G).  None of the instant complaints alleged that any station failed to 
provide this additional information, and we believe that the requirement to provide such information is self-
explanatory and requires no clarification.
52
A few licensees that are alleged to have violated these provisions by identifying only one official concede that 
their disclosure failed to meet the requirement to maintain a list.  See, e.g., KMGH-TV Answer at 1; KNXV-TV 
Answer at 1; WWJ-TV Answer at 2.
53
WFLA-TV Answer at 4 (asserting that because the Federal Election Commission generally requires only one 
named officer to form a political action committee, the station had no way of knowing whether there were any other 
officials that needed to be disclosed, and that under Commission precedent, broadcasters are not obligated to act as 
“private investigators” to determine the identity of officers and directors).
54
Complainants’ Consolidated Reply at 4 (“The treasurer is not the chief executive officer, nor does identifying the 
treasurer constitute a list of members of the executive committee or of the board of directors.”) (emphasis in 
original).
55
47 U.S.C. § 315(e)(2)(G).
56
47 CFR § 73.1212(e).
57
For example, Complainants allege that Station WFLA-TV failed to meet its disclosure obligation under these 
provisions by maintaining in its political file only the name of the treasurer of the entity that purchased broadcast 
time.  WFLA-TV Complaint at 7.
Federal Communications Commission DA 17-14
11
board of directors of such entity.  We note that one of the principal purposes of the Bipartisan Campaign 
Reform Act of 2002, which expanded Section 315’s record-keeping requirements, was “to promote the 
free and swift flow of information to the public regarding the activities of groups and individuals in the 
political process.”
58
  We find that requiring licensees to undertake reasonable efforts to ensure complete 
and accurate disclosure of the sponsoring entity’s officials in the political file will best achieve 
Congress’s goals in enacting BCRA by enabling the public to access information about broadcast political 
ads specifically identified in the statute.    
23. Although some licensees argue that they are required to identify in their political files 
only those individuals whose names have been provided to them,
59
we believe the requirement that 
licensees maintain a “list” of specified officials obligates stations to inquire further in cases where the 
station has a reasonable basis for believing that the information provided appears to be incomplete, e.g., 
where the name of only one official has been supplied.  Because Congress in BCRA amended Section 315 
to require that licensees maintain specific information in their records, we find it reasonable to conclude 
that it intended to impose on licensees an obligation to take certain steps to obtain that information.   We 
also find that requiring licensees to make this follow-up inquiry is not unduly burdensome, and is 
necessary to discharge their statutory duty to maintain a “list” of the required information.
60
  For example, 
in cases where a purchaser of broadcast time has provided the name of only one official, licensees may 
discharge their obligation by asking the purchaser whether there are other officials of the sponsoring 
entity that must be identified under Section 315(e)(2)(G) of the Act and Section 73.1212(e) of our rules, 
or, alternatively, by informing the purchaser as to which officials must be identified under those 
provisions and asking it to provide that information.  We note that under Section 315(e)(1), the 
responsibility to maintain the list of officials resides with licensees, not advertisers.
61
  Thus, the onus is on 
licensees to make reasonable efforts to obtain that information, regardless of whether the purchaser 
affirmatively has supplied such information.
24. We reject the suggestion that imposing the requirement above would improperly place 
stations in the role of “private investigators” contrary to Commission precedent.
62
  Media General 
Communications Holdings. LLC, the licensee of Station WFLA-TV contends, for example, that, “absent 
a claim that the listed officer/director information is incomplete or incorrect, stations have not been 
obligated to research issue group executive leadership.”
63
  Under our interpretation of Section 
                                                     
58
Statement by President George W. Bush Upon Signing H.R. 2356, 
http://www.presidency.ucsb.edu/ws/?pid=64503 (visited Dec. 13, 2016) (stating that the legislation creates new 
disclosure requirements that will provide the public with more accurate and timely information about the source of 
campaign contributions). 
59
See, e.g., WFLA-TV Answer at 4.  Based on the record, it appears that a few licensees subject to complaints 
disclosed only one official, and that the official disclosed did not represent the complete list of officials required to 
be disclosed under the Act and the Commission’s rules.  See, e.g., KMGH-TV Answer at 1; KNXV-TV Answer at 1.  
60
47 U.S.C. § 315(e)(2)(G); 47 CFR § 73.1212(e) (both requiring that licensees maintain and make publicly 
available a “list”).
61
47 U.S.C. § 315(e)(1) (providing that “a licensee shall maintain, and make available for public inspection” certain 
records) (emphasis added).  See also Complainants’ Consolidated Reply at 4 (asserting that Section 315 imposes the 
disclosure burden on licensees, not advertisers, and that if information supplied by an advertiser is insufficient, then 
it is the station’s responsibility to obtain the requisite information).
62
WFLA-TV Answer at 4, citing Trumper Communications of Portland, Ltd., 11 FCC Rcd 20415, 20417 (MB 
1996) (asserting that Trumper supports interpreting the relevant provisions as not requiring stations to act as private 
investigators in an effort to identify every officer or director of an entity purchasing programming that 
communicates a political matter of national importance). 
63
WFLA-TV Answer at 4.  
Federal Communications Commission DA 17-14
12
315(e)(2)(G) of the Act and Section 73.1212(e) of our rules, licensees need not conduct independent 
research to identify all of the officials of a sponsoring entity. Rather, as noted above, licensees must 
make a simple inquiry of the purchaser in cases where the purchaser has identified only one official of the 
sponsoring entity, or where the licensee has a reasonable basis for believing that the information initially 
provided is incomplete or inaccurate (e.g., where the licensee has sold time to the same purchaser in the 
past and the information now provided by the purchaser is inconsistent with its prior buys).
25. If, after such further inquiry, a licensee is provided with the names and titles of additional
officials, it must identify those persons and their titles in its political file.  We acknowledge that in some 
cases a sponsoring entity may in fact have only one officer or other official in the specified categories.  In 
such instances, after the licensee has made the additional inquiry discussed above, we believe that the 
licensee will have satisfied its obligation to provide the “list” required by Section 315(e)(2)(G) of the Act 
and Section 73.1212(e) of our rules by identifying the one official, even if the purchaser has failed to 
supply a complete list of officials in response to the licensee’s further inquiry.
64
  
3. Political Matters of National Importance under Section 315(e)(1)(B)
26. For the purpose of applying Section 315(e)(1)(B) of the Act,
65
we clarify that we will 
consider context in determining whether an advertisement communicates a message relating to a 
“political matter of national importance.”
66
  As discussed below, the record generated in response to the 
complaints reflects conflicting views regarding the meaning and scope of this phrase.  Although 
fulfillment of a licensee’s disclosure obligations under this provision will be determined on a case-by-case 
basis, we provide examples below to assist broadcasters in evaluating their obligations.  
27. As noted above, Section 315(e)(1) of the Act requires that licensees maintain records for 
two types of requests to purchase broadcast time.
67
  The first type concerns requests for broadcast time 
that are “made by or on behalf of a legally qualified candidate for public office.”
68
  The second type 
concerns requests for broadcast time that communicate a message relating to “any political matter of 
national importance.”
69
  The clarification herein relates to the latter category of requests.  When Congress 
amended Section 315 to include that category of broadcast messages, it provided in Section 315(e)(1)(B) 
three examples of the kinds of messages that may constitute “political matters of national importance.”
70
  
Specifically, Section 315(e)(1)(B) requires broadcasters to maintain a political file for any request for 
broadcast time that “communicates a message relating to any political matter of national importance, 
                                                     
64
WFLA-TV’s licensee maintains that it “had no way of knowing whether there were any additional 
officers/directors that should have been disclosed” because “the rules of the Federal Election Commission only 
require one named officer to form a political action committee . . . .” Id., citing the FEC website at 
http://www.fec.gov/info/toolkit.shtml. While we acknowledge that the FEC allows political action committees to be 
formed with, and to identify in FEC Form 1, Statement of Organization, just a treasurer and a custodian of records 
(which may be the same person), see 11 CFR § 102.7, it is nonetheless incumbent upon FCC regulatees to provide 
all of the information required by the Act and our rules relating to political files.  As we clarify in this Order, if after 
further inquiry, a licensee reasonably determines that the sponsoring organization in fact has only one officer or 
other like official, its disclosure of that information would render it compliant with Section 315(e)(2)(G) of the Act 
and Section 73.1212(e) of our rules.  
65
47 U.S.C. § 315(e)(1)(B).
66
Id. § 315(e)(1)(B).
67
Supra para. 5.
68
47 U.S.C. § 315(e)(1)(A).
69
Id. § 315(e)(1)(B).
70
This category was added to Section 315 as a result of the Bipartisan Campaign Reform Act of 2002.  Supra n. 7.
Federal Communications Commission DA 17-14
13
including (i) a legally qualified candidate;
71
(ii) any election to Federal office;
72
or (iii) a national 
legislative issue of public importance.
73
  
28. As a threshold matter, we interpret the items specified in Section 315(e)(1)(B) – a 
“legally qualified candidate,” an “election to Federal office,” and a “national legislative issue of public 
importance” – to represent only three examples of “political matters of national importance” that may 
trigger a licensee’s obligation to maintain records of requests to purchase broadcast time.  Our 
interpretation is supported by the language of Section 315(e)(1)(B), which refers to “any political matter 
of national importance,” and states that such matters “includ[e],” and thus are not limited to, these three 
specified items.
74
  In addition, we note that under Section 315(e)(1)(B), a broadcast message must satisfy 
two requirements in order to trigger a licensee’s disclosure obligations.  First, the message must be 
“political” in nature.  Second, it must be of “national importance,” i.e., it must have significance on a 
national level.  If a message relates to a “political matter” and is “of national importance,” the Act 
requires the licensee to disclose information about the message in its political record.  As discussed 
below, we will consider context in determining whether an advertisement communicates a message 
relating to a “political matter of national importance.”   
29. “Legally Qualified Candidate” under Section 315(e)(1)(B)(i).  Although Section 
315(e)(1)(B) requires broadcasters to maintain a political record for any request for broadcast time that 
“communicates a message relating to any political matter of national importance,” including a “legally 
qualified candidate” for public office, not every advertisement that references a “legally qualified 
candidate” will trigger a record-keeping obligation.  For example, an advertisement that promotes the 
virtues of an individual running for state attorney general, yet has no relevance to issues considered or 
debated at the national level, would not reasonably constitute a message having national importance.  
Therefore, such an ad, despite having referenced “a legally qualified candidate,” would not rise to the 
level of communicating a message relating to a “political matter of national importance” and thus would 
not be subject to Section 315(e) record-keeping requirements.  On the other hand, if an ad for state 
attorney general references the candidate’s position on issues that are debated at the national level, then 
the ad would be deemed to relate to a “political matter of national importance” and would trigger record-
keeping obligations.  
30. For purposes of Section 315(e)(1)(B)(i), we interpret the phrase “legally qualified 
candidate” to include all legally qualified candidates for public office, not just candidates for federal 
office.  Given that the very next subsection, section 315(e)(1)(B)(ii), expressly refers to “[f]ederal” office, 
and Section 315(e)(1)(B)(i) does not contain the word “federal,” we find it reasonable to conclude that 
Congress did not intend to restrict the definition of “a legally qualified candidate” to federal candidates.  
Nonetheless, as discussed above, an advertisement that references a non-federal candidate would be 
covered by Section 315(e)(1)(B) only if it is political in nature and has national importance.
31. In addition, we clarify that a legally qualified candidate for public office need not be 
mentioned in connection with an election in order to trigger the obligation to maintain information about a 
particular advertisement under Section 315(e)(1)(B)(i).  Based on the record, parties appear to have 
differing views about the circumstances under which licensees are obligated to maintain political records
                                                     
71
47 U.S.C. § 315(e)(1)(B)(i).
72
Id. § 315(e)(1)(B)(ii).
73
Id. § 315(e)(1)(B)(iii) (emphasis added).
74
Id. § 315(e)(1)(B) (requiring a licensee to maintain a complete record of a request to purchase broadcast time that 
“communicates a message relating to any political matter of national importance, including – (i) a legally qualified 
candidate; (ii) any election to Federal office; or (iii) a national legislative issue of public importance”) (emphasis 
added).
Federal Communications Commission DA 17-14
14
for ads that mention a “legally qualified candidate” for public office.  For example, Fox Televisions 
Stations, Inc., the licensee of station KMSP-TV, suggests that it is obligated to disclose the name of the 
candidate and the office to which the candidate is seeking election only if the candidate is referenced in 
connection with an election.
75
  By contrast, Complainants argue that the obligation to disclose this 
information is triggered whenever a legally qualified candidate for public office is referenced in a 
political advertisement, even if that candidate is not mentioned in connection with an election.
76
  
32. We agree with Complainants’ interpretation.  As explained above, the categories listed in 
Section 315(e)(1)(B)(i), (ii), and (iii),
77
are examples of “political matters of national importance,” the 
reference to any one of which in an advertisement may, when considered in context, trigger disclosure 
obligations.
78
  Thus, an ad triggers the obligation to disclose information specified in Section 315(e)(2) if 
it references a legally qualified candidate but not an election to federal office and vice versa, so long as 
the ad “communicates a message relating to any political matter of national importance.”  Contrary to the 
suggestion of Fox Television Stations,
79
nothing in section 315(e)(1) or (e)(2) requires that a candidate be 
mentioned in connection with an election in order to trigger disclosure requirements.  Moreover, we find 
that use of the word “or” in Section 315(e)(1)(B) indicates that Congress contemplated that each of the 
items listed in that provision could independently trigger record-keeping obligations.  Thus, the reference 
to a legally qualified candidate and an election to federal office are independent criteria, either of which 
may trigger appropriate disclosure.     
33. “Any Election to Federal Office” under Section 315(e)(1)(B)(ii).  We will also consider 
context in evaluating ads that reference an “election to Federal office” under Section 315(e)(1)(B)(ii).
80
  
Again, only ads that relate to a political matter of national importance trigger a record-keeping obligation.  
For example, an advertisement by an auto dealership that announces the sale of new cars to celebrate an 
upcoming presidential election would not reasonably be deemed to be a message that is political in nature.  
As a result, such an ad, despite having referenced an “election to Federal office,” would not constitute a 
message relating to a political matter of national importance.  
34. “National Legislative Issue of Public Importance” under Section 315(e)(1)(B)(iii).  With 
respect to Section 315(e)(1)(B)(iii), we clarify that a national legislative issue of public importance would 
not be limited to issues for which legislation is pending, proposed, or contemplated,
81
but rather could 
encompass an issue for which legislation has already passed and is the subject of continuing controversy 
or discussion.  For example, an advertisement that discusses the future of Social Security likely would 
trigger record-keeping obligations even if there were no national legislative proposals being actively 
considered that relate to that topic at the time the ad is aired.  We believe this interpretation is consistent 
with Section 315(e)(1)’s directive that licensees maintain a “complete” record of a request to purchase 
broadcast time
82
and with BCRA’s purpose to foster greater public access to certain political information 
                                                     
75
KMSP-TV Answer at 3-4 (“The American Encore advertisement does not mention Senator Franken in reference 
to any election.”).
76
Complainants’ Consolidated Reply at 7-8. 
77
They are: (i) a legally qualified candidate; (ii) any election to Federal office; or (iii) a national legislative issue of 
public importance.
78
However, if the advertisement is made by or on behalf of a legally qualified candidate for public office under 
Section 315(e)(1)(A), disclosure requirements are automatically triggered without regard to context.
79
KMSP-TV Answer at 3.
80
47 U.S.C. § 315(e)(1)(B)(ii).
81
Complainants’ Consolidated Reply at 5-6.
82
47 U.S.C. § 315(e)(1).
Federal Communications Commission DA 17-14
15
by expanding disclosure obligations.  
35. Despite this interpretation, not every advertisement that references a “national legislative 
issue of public importance” will, when considered in context, constitute a message relating to a political 
matter of national importance requiring disclosure.  Consider, for example, an advertisement that 
promotes the sale of power-operated wheelchairs and mentions that the cost to consumers will be covered 
by Medicare.  While Medicare coverage is a national legislative issue of public importance, its reference 
in this particular advertisement, when considered in context, would not reasonably constitute a political 
matter of national importance because it is not communicating a message about Medicare; rather 
Medicare is being mentioned to help sell a commercial product.  
C. Individual Complaints
36. In this section, we address the merits of Complainants’ allegations with respect to each of 
the above-captioned licensees.  For the reasons explained below, we admonish nine of the 11 licensees for 
their failures to satisfy record-keeping obligations under Section 315 of the Act. We decline to take 
enforcement action in those instances in which a licensee’s actions were inconsistent with the obligations 
that we clarify in this Order.  Going forward, we expect all entities that receive requests for broadcast 
time that trigger disclosure requirements under Section 315(e)(1) to place in their political files 
immediately the specific items of information required by Section 315(e)(2), as clarified.
1. Station KMSP-TV, Minneapolis, MN 
37. We admonish Fox Television Stations, Inc. (Fox), the licensee of Station KMSP-TV, for
maintaining a record in its political file for an American Encore
83
advertisement that did not identify any
political matters of national importance that were communicated in the ad, in willful violation of Section 
315(e)(2)(E) of the Act.
84
  The advertisement mentioned Senator Al Franken, who was then a legally 
qualified candidate for election to the U.S. Senate, and his support of an Internal Revenue Service 
proposed rulemaking involving the activities of certain non-profit organizations which the sponsor argued 
would have adverse First Amendment implications.
85
  Fox states that “KMSP-TV reviewed the content of 
the advertisement and determined that Section 315(e)(1) was implicated,” and, as a result, “KMSP-TV 
was required to, and did, put records into the public file, including the order and rates charged.”
86
  Fox 
concedes that even though the ad triggered disclosure requirements under Section 315(e)(1)(B), it failed 
to identify any political matters of national importance in Station KMSP-TV’s political file, as required
by Section 315(e)(2)(E).
87
  
                                                     
83
American Encore describes itself as “an IRS-recognized nonprofit social welfare organization organized under 
Section 501(c)(4) of the Internal Revenue Code.”  See https://transaxt.com/Donate/EN4LPQ/AmericanEncore/.
84
47 U.S.C. § 315(e)(2)(E).  
85
KMSP-TV Complaint at 4.  In late 2013, the Internal Revenue Service proposed new regulations to “provide 
guidance to tax-exempt social welfare organizations on political activities related to candidates that will not be 
considered to promote social welfare.”  78 Fed. Reg. 71535 (Nov. 29, 2013).  According to Complainants, “IRS 
rulemakings and First Amendment speech issues are subject to nationwide debate and media coverage, and impact 
citizens across the country.”  KMSP-TV Complaint at 6.  We conclude that in the context in which it referenced the 
proposed IRS rule, the American Encore advertisement communicated a message relating to a political matter of 
national importance.  We also conclude that the ad communicated an additional message relating to a political 
matter of national importance by its reference to Senator Al Franken, a legally qualified candidate.  Because the ad 
triggered disclosure requirements under Section 315(e)(1)(B), the station was required to place in its political file, 
among other things, the items of information required by Section 315(e)(2)(E).
86
KMSP-TV Answer at 2.  
87
Id. at 2-3.  
Federal Communications Commission DA 17-14
16
38. Fox acknowledges that the ad referenced Senator Al Franken, but maintains that it was 
under no obligation to identify him in Station KMSP-TV’s political file because the ad did not mention 
the candidate in connection with an election.
88
  Fox further argues that even if the ad had advocated for or 
against Senator Franken’s election, under Section 315(e)(2)(E), it had the option to disclose either the 
candidate or the IRS proposed rulemaking issue referenced in the ad.
89
  As discussed above, we disagree 
with these arguments and clarify that a candidate need not be mentioned in connection with the specific 
election in which he or she is running in order to trigger disclosure requirements,
90
and a licensee is 
required to identify all candidates, elections, and issues, as applicable, which, in context, constitute 
political matters of national importance.
91
  In the instant case, given that the conduct occurred before 
release of the instant order, we would not take action against Fox had it disclosed at least the candidate or
the issue in its political file.  However, because it disclosed neither political matter of national importance 
communicated in the ad, we conclude that an admonishment is warranted.  
2. Station WTVT(TV), Tampa, FL  
39. We admonish New World Communications of Tampa, Inc. (New World), the licensee of 
Station WTVT(TV), for maintaining a record in its political file for a Democratic Congressional 
Campaign Committee
92
advertisement that did not disclose any political matters of national importance 
that were communicated in the ad, in willful violation of Section 315(e)(2)(E) of the Act.
93
  The ad 
referenced David Jolly, a legally qualified candidate in the special election for the 2014 U.S. House of 
Representatives in Florida, and criticized his “lobbying for special interests that received over three 
million in taxpayer-funded earmarks” at a time that the U.S. “face[d] record debt.”
94
  New World states 
that Station WTVT(TV) determined that the “advertisement communicated a message relating to a legally 
qualified candidate which implicated an election for Federal office.  The station thus placed the record [of 
the ad] in the public file  . . . . “
95
  However, New World concedes that even though the ad triggered 
disclosure requirements under Section 315(e)(1)(B) because it referenced a political matter of national
importance (i.e., a legally qualified candidate), it failed to identify the candidate in Station WTVT(TV)’s 
political file, as required by Section 315(e)(2)(E).
96
  
40. New World argues that “[T]he ad in question did not address a ‘national legislative issue 
of public importance.’  The ad attacks Jolly’s record as a lobbyist and notes America is facing record 
debt.  There is no national legislative issue presented in the ad.”
97
Furthermore, New World claims that 
even if the ad had referenced a national legislative issue of public importance, the station had the option 
                                                     
88
Id. at 3-4.  
89
Id.  
90
Supra paras. 31-32.
91
Supra paras. 12-19, 26-35.
92
The Democratic Congressional Campaign Committee describes itself as “the official campaign arm of the 
Democrats in the House of Representatives.”  See http://dccc.org/about/. 
93
47 U.S.C. § 315(e)(2)(E).  
94
WTVT(TV) Complaint at 3-4.  The national debt, including its effect on the economy, is a subject of continuing 
debate, dialogue, news reports, and controversy affecting the nation as a whole.  Thus, we believe that, in context, 
the reference to the national debt in the subject ad constituted a national legislative issue of public importance that 
New World should have disclosed in Station WTVT(TV)’s political file.
95
WTVT(TV) Answer at 2.
96
Id.  
97
Id. at 3-4.
Federal Communications Commission DA 17-14
17
to disclose either the issue or the candidate.
98
  As clarified above, all references to political matters of 
national importance (including a legally qualified candidate, an election to Federal office, and a national 
legislative issue of public importance) in each ad must be disclosed in a station’s political file.
99
Even 
assuming, arguendo, that the subject ad had referenced only one political matter of national importance 
(i.e., a legally qualified candidate) rather than two (the second being the reference to the national debt), 
New World failed to identify the one political matter that it acknowledges was referenced in the ad.  Had 
New World disclosed either the candidate or the issue, we would have refrained in this instance from 
taking action in light of the fact that the conduct occurred before our clarification. However, because 
New World disclosed neither political matter of national importance communicated in the ad, we 
conclude that an admonishment is warranted.  
3. Station WFLA-TV, Tampa, FL  
41. We admonish Media General Communications Holdings, LLC (Media General), the 
licensee of Station WFLA-TV, for maintaining a record in its political file for a National Republican 
Congressional Committee (NRCC)
100
advertisement that did not disclose any political matters of national 
importance that were communicated in the ad, in willful violation of Section 315(e)(2)(E) of the Act.
101
  
The subject advertisement compared and contrasted the opposing positions of two competing candidates 
for the U.S. House of Representatives on two controversial matters of national significance -- the 
Affordable Care Act and a balanced budget.
102
  Media General acknowledges that the station’s political 
file did not disclose either the issues or the candidates.
103
  
42. Nevertheless, Media General maintains that the public could have ascertained from other 
information in the station’s political file the identities of the candidates mentioned in the ad.
104
  In 
particular, Media General asserts that based on its identification of the NRCC as the sponsor of the ad, 
information about the NRCC on that organization’s website, and the timing of the ad (just prior to a 
special election for U.S. House of Representatives), the identity of the candidates should have been 
                                                     
98
Id. at 4.    
99
Supra paras. 12-19.
100
The NRCC describes itself as “a political committee devoted to increasing the Republican majority in the U.S. 
House of Representatives.”  See https://www.nrcc.org/about/. 
101
47 U.S.C. § 315(e)(2)(E).  Complainants also allege that station WFLA-TV violated Section 315(e)(2)(G) of the 
Act and Section 73.1212(e) of the Commission’s rules by failing to maintain a list of the NRCC’s board of directors 
or chief executive officers.  WFLA-TV Complaint at 7.  Media General argues that it disclosed the NRCC’s 
Treasurer in the station’s political file, and that it had no way of knowing that there were other officials that should 
be disclosed because Federal Election Commission rules generally require only one named officer (usually a 
treasurer) to form a political action committee.  WFLA-TV Answer at 4.  Because we clarify in this Order how 
licensees should proceed in situations where they are provided with the name of only one officer or other like 
official, supra paras. 20-25, we take no enforcement action against Media General for its failure to identify all such 
officials in Station WFLA-TV’s political file.
102
WFLA-TV Complaint at 3-4.  We agree with Complainants that the Affordable Care Act (also referred to as 
“Obamacare”) may be the “quintessential legislative and controversial issue of public importance: it was President 
Obama’s key initiative and has been the subject of nationwide debate and court challenges, including at the Supreme 
Court.”  Id. at 6.  The matter of a balanced budget also is a subject of continuing debate, dialogue, news reports, 
controversy, and national importance.  In the context in which they were discussed, these issues and candidates 
constituted political matters of national importance.  
103
WFLA-TV Answer at 2-3.
104
Id.
Federal Communications Commission DA 17-14
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evident to anyone reviewing the file.
105
  We find this argument unpersuasive.  Section 315(e)(2)(E) of the 
Act expressly requires that a licensee’s political file contain, among other things, “the name of the 
candidate” to which an advertisement refers.
106
  In addition, we find that requiring the public to “connect 
the dots” in order to determine the identity of candidates mentioned in an ad, or any other information 
required to be disclosed under Section 315(e)(2)(E), would improperly shift to the public a burden that 
Congress expressly imposed on licensees in Section 315(e)(1).  
43. We also reject Media General’s contention that by including other information about the 
ad in the station’s file (such as the rates charged and the dates and times the ads aired), the information in 
the file “met the Commission’s policy goal that ‘the disclosures included in the political file [should] 
further the First Amendment’s goal of an informed electorate that is able to evaluate the validity of 
messages and hold accountable the interests that disseminate political advocacy.”
107
  We agree with 
Complainants that the statute does not require licensees to disclose “just enough information for viewers 
to infer the candidates, elections, and issues mentioned by an ad based on political party leanings or 
names of groups,” and that a licensee’s “[failure] to disclose information required by law does not inform 
the electorate.”
108
  It is not enough for a licensee to provide the information in its political file required by 
Sections 315(e)(2)(A), (B), (C) and/or (D).  It also must provide the information required by Sections 
315(e)(2)(E), (F), and/or (G), as applicable.  
44. Media General further argues in mitigation of a sanction that it provided public and 
political file training to its employees prior to the complaint and continues to do so, and is working with 
its national sales representation firm to ensure that it gathers all information required to be disclosed in its 
political file.
109
  While we recognize Media General’s efforts to train its staff in maintaining the station’s 
public and political files, such efforts provide no basis for excusing its misconduct.
110
Given that Media 
General did not identify any political matters of national importance communicated in the NRCC ad, we 
admonish Media General.
                                                     
105
Id.
106
47 U.S.C. § 315(e)(2)(E).
107
WFLA-TV Answer at 3, citing Enhanced Disclosure Order, 27 FCC Rcd 4535 (2012).
108
Complainants’ Consolidated Reply at 8-9.
109
WFLA-TV Answer at 4-5.
110
See, e.g., San Jose Navigation, Inc., 22 FCC Rcd 1040, 1043 (2007) (“It is the Commission’s long-standing 
policy . . . that corrective measures implemented after Commission inquiry or enforcement action do not nullify past 
violations and thus do not warrant reduction or cancellation of forfeiture liability”); TCI Cablevision of Maryland, 
Inc., 7 FCC Rcd 6013, 6014, para. 8 (1992) (rejecting a claim that subsequent corrective actions mitigate past
violations because it “would tend to encourage remedial rather than preventative action”); Cate Communications 
Corp., 60 RR2d 1386 (1986) (rejecting a claim that a licensee should be excused from past violations because of 
subsequent remedial measures).  See also Behringer USA, Inc., 21 FCC Rcd 1820, para. 24 (2006) (“implementation 
of corrective measures in response to an LOI is expected, and thus does not nullify or mitigate past violations”); 
ACR Electronics, Inc., 19 FCC Rcd 22293, 22304, para. 25 (2004), forfeiture ordered, 21 FCC Rcd 3698 (2006) (the 
Commission expects that corrective action will be implemented to bring past violations into compliance. However, 
such corrective action does not nullify or mitigate past marketing violations, and thus does not warrant any reduction 
in the proposed forfeiture); AT&T Wireless Services, Inc., 17 FCC Rcd 7891 (2002), forfeiture ordered, 17 FCC Rcd 
21866, 21875, para. 26 (2002) (all licensees and Commission regulatees are expected to promptly take corrective 
action when violations are brought to their attention); Seawest Yacht Brokers, 9 FCC Rcd 6099, para. 7 (1994) 
(corrective action taken to come into compliance with Commission rules or policy is expected, and does not nullify 
or mitigate any prior forfeitures or violations).
Federal Communications Commission DA 17-14
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4. Station WTVJ(TV), Miami, FL  
45. We admonish NBC Telemundo License, LLC (NBC Telemundo), the licensee of Station 
WTVJ(TV), for maintaining a record in its political file for a LIBRE Initiative
111
advertisement that did 
not disclose any political matters of national importance that were communicated in the ad, in willful 
violation of Section 315(e)(2)(E) of the Act.
112
  The LIBRA advertisement opposed the Affordable Care 
Act, arguing that premiums were going up and health policies were being cancelled.  NBC Telemundo 
concedes that the ad referenced a national legislative issue of public importance
113
and that the station did 
not identify that issue in the station’s political file.
114
  
46. The ad also questioned why a particular politician had supported the law.
115
  
Complainants allege that NBC Telemundo violated Section 315(e)(2)(E) by failing to identify in the 
station’s political file that individual, whom Complainants asserted was a candidate for U.S. House of 
Representatives.
116
  However, NBC Telemundo maintains that it was not obligated to identify the 
politician mentioned in the ad because he was not a legally qualified candidate under Florida law and the 
Commission’s rules at the time the ad aired.
117
  Complainants concede that point.
118
  We find no basis for 
enforcement action with regard to the station’s failure to disclose the name of an individual who was not 
at the time a legally qualified candidate for public office under our rules.
119
  
47. NBC Telemundo argues in mitigation of a sanction that Station WTVJ(TV)’s political 
file previously contained the information required by Sections 315(e)(2)(A)-(D) and it has taken remedial 
action to ensure that the additional information required by Section 315(e)(2)(E) also is placed in the 
file.
120
  We see no basis for mitigation.  Licensees are required to provide all of the information required
under Section 315(e)(2), as applicable.  Furthermore, remedial measures do not constitute a basis for 
mitigating or eliminating a sanction.
121
  Given that the ad communicated one national legislative issue of 
public importance requiring disclosure, and NBC Telemundo failed to include that information in Station 
WTVJ(TV)’s political file, we admonish NBC Telemundo.
5. Station WTVD(TV), Durham, NC  
48. We admonish WTVD Television, LLC (WTVD), the licensee of Station WTVD(TV), for 
                                                     
111
The LIBRE Initiative describes itself as “a 501(c)(4) non-partisan, non-profit grassroots organization that 
advances the principles and values of economic freedom to empower the U.S. Hispanic community.”  See
http://thelibreinitiative.com/about-us. 
112
47 U.S.C. § 315(e)(2)(E).  
113
The Affordable Care Act (also referred to as “Obamacare”) is the subject of continuing controversy, debate, 
dialogue, news reports, court challenges, and national importance. In the context in which it discussed the 
Affordable Care Act, the ad communicated a message relating to a national legislative issue of public importance 
that constituted a political matter of national importance. 
114
WTVJ(TV) Answer at 1-2.    
115
WTVJ(TV) Complaint at 3.
116
Id. at 6.
117
WTVJ(TV) Answer at 2-3.  
118
Complainants’ Consolidated Reply at n. 2.  
119
See 47 CFR § 73.1940.
120
WTVJ(TV) Answer at 2.
121
Supra n. 110.
Federal Communications Commission DA 17-14
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maintaining a record in its political file for an American Crossroads
122
advertisement that did not disclose 
any political matters of national importance that were communicated in the ad, in willful violation of 
Section 315(e)(2)(E) of the Act.
123
  The ad compared and contrasted the opposing positions of two 
competing candidates for the U.S. Senate on three controversial matters of national significance -- the 
Affordable Care Act, the national debt, and a voter identification law.
124
  In its response on behalf of 
WTVD, ABC, Inc. (ABC) concedes that the advertisement communicated a message relating to multiple 
political matters of national importance, none of which was disclosed in its political file.
125
  Because ABC 
failed to disclose any of the information required by Section 315(e)(2)(E), we conclude that an 
admonishment is warranted.    
49. ABC asserts in defense of WTVD that the station’s political file disclosed other 
information required by Sections 315(e)(2)(B), (C), and (G) of the Act (i.e., the rate charged; the date and 
time on which the ad was broadcast; and the name of the sponsor, and the name and telephone number of 
a contact person for the sponsor).
126
  Such disclosures, however, do not excuse WTVD’s failure to provide 
specific information about legally qualified candidates and national legislative issues of public importance 
required by Section 315(e)(2)(E).  WTVD also maintains that its failure to comply with Section 
315(e)(2)(E) was attributable to “administrative oversight”
127
and that it took subsequent action to remedy 
its omission.
128
  Such explanation and remedial measures, however, provide no bases for excusing its 
misconduct.
129
6. Station WWJ-TV, Detroit, MI  
50. We admonish CBS Broadcasting, Inc. (CBS), the licensee of WWJ-TV, for maintaining a 
record in its political file for a Senate Majority PAC
130
advertisement that did not disclose any political 
matters of national importance that were communicated in the ad, in willful violation of Section 
315(e)(2)(E) of the Act.
131
  The ad mentioned a legally qualified candidate for the U.S. Senate, Terri Lynn 
Land, arguing that she was being influenced by large donors and taking positions on controversial 
healthcare policy (including cuts to, and the rising costs of, preventative care for women) that would hurt 
                                                     
122
American Crossroads describes itself as “registered with the Federal Election Commission as an independent 
expenditure committee.”  See https://www.americancrossroads.org/donate/. 
123
47 U.S.C. § 315(e)(2)(E).
124
WTVD(TV) Complaint at 2-3.  The Affordable Care Act, the national debt and voter ID laws are all issues of 
continuing controversy, debate, dialogue, news reports, and political deliberation of national importance affecting 
millions of Americans.  In the context in which they were discussed, the references to all three matters 
communicated messages relating to national legislative issues of public importance that constituted political matters
of national importance.  
125
WTVD(TV) Answer at 3.
126
Id.
127
Id.
128
Id.
129
Supra n. 110.  Complainants also allege that WTVD violated Section 315(e)(2)(G) of the Act and Section 
73.1212(e) of the Commission’s rules by providing the name of only one official of the sponsoring entity in its 
political file, rather than a “list” of officials.  WTVD(TV) Complaint at 7.  Because the subject disclosure was made 
prior to the issuance of our clarification regarding licensees’ obligations to identify officials of sponsoring entities 
under these provisions, we decline to take enforcement action against WTVD for this alleged violation.  
130
Senate Majority PAC is a political action committee that “seeks the election of Democratic U.S. Senators.”  See
http://www.senatemajority.com/about/. 
131
47 U.S.C. § 315(e)(2)(E).
Federal Communications Commission DA 17-14
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average Americans.
132
  CBS argues that it was required under Section 315(e)(2)(E) to disclose the name 
of the candidate or the issue, but concedes that its political file did not contain information about either.
133
  
51. As discussed above, we clarify in this Order that Section 315(e)(2)(E) requires the 
disclosure of all candidates and issues (and elections, as applicable) referenced in each ad which, when 
considered in context, constitute a political matter of national importance.
134
  In those cases before us 
where the conduct in question occurred before release of the instant order and a licensee has disclosed 
some, but not all, such information in its political file, we take no enforcement action.  However, here,
CBS failed to disclose any of the information required by Section 315(e)(2)(E) with respect to the subject 
advertisement (i.e., neither the candidate nor the issue).  Additionally, while CBS asserts that it has taken 
corrective measures to ensure that the station’s political file is complete,
135
as noted above, such remedial 
action provides no basis for excusing its misconduct.
136
7. Station KNXV-TV, Phoenix, AZ  
52. We admonish Scripps Media Inc. (Scripps), the licensee of station KNXV-TV, for
maintaining a record in its political file for a House Majority PAC
137
advertisement that did not disclose 
any political matters of national importance that were communicated in the ad, in willful violation of 
Section 315(e)(2)(E) of the Act.
138
  The House Majority PAC advertisement advocated for the reelection 
of U.S. Representative Ann Kirkpatrick from Arizona’s 1st Congressional District by highlighting how 
she had worked to fix the Affordable Care Act’s HealthCare.gov website, which the ad characterized as 
“disastrous.”  The ad also claimed that the candidate had sought to prevent insurance companies from 
denying coverage for pre-existing conditions or dropping coverage when a patient becomes ill.
139
  Scripps 
concedes that KNXV-TV’s political file failed to disclose the name of the candidate, the office sought, 
and the issue referenced in the ad.
140
                                                     
132
WWJ-TV Complaint at 2-3. Health care reform is a subject of continuing controversy, debate, dialogue, news 
reports, and national importance affecting millions of Americans.  In the context in which it was discussed, the 
subject of health care reform constituted a national legislative issue of public importance within the meaning of 
Section 315(e)(1)(B)(iii) of the Act.
133
WWJ-TV Answer at 1-2.  CBS asserts that it placed an incorrect NAB PB-18 form (relating to a previous order 
by the sponsoring entity in 2013) in the Station WWJ-TV political file.  Id. at 1.
134
Supra paras. 12-19, 26-35.
135
WWJ-TV Answer at 1-2.  
136
Supra n. 110. Complainants also allege that station WWJ-TV violated Section 315(e)(2)(G) of the Act and 
Section 73.1212(e) of the Commission’s rules by maintaining a political file for the ad that disclosed the name of 
only one official of the sponsoring entity, rather than a “list” of officials. WWJ-TV Complaint at 6.  Because the 
subject disclosure was made prior to the issuance of our clarification regarding licensees’ obligations to identify 
officials of sponsoring entities under these provisions, we decline to take enforcement action against CBS for this 
alleged violation.  
137
House Majority PAC is a political action committee that seeks to “help Democrats win a majority in the House.”  
See https://secure.actblue.com/contribute/page/hmp20141?refcode=mainpage. 
138
47 U.S.C. § 315(e)(2)(E).
139
KNXV-TV Complaint at 3.  The subject of health care coverage is a matter of continuing controversy, debate, 
dialogue, news reports, and intense political deliberations of national importance.  In this context, the reference to 
health care coverage (including the HealthCare.gov website and actions of health insurance companies) 
communicated a message relating to a national legislative issue of public importance that constituted a political 
matter of national importance.
140
KNXV-TV Answer at 1.
Federal Communications Commission DA 17-14
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53.   Although Scripps maintains that it disclosed other information required by Section 
315(e)(2),
141
such disclosure does not excuse its failure to disclose the specific information required by 
Section 315(e)(2)(E).  Moreover, the fact that Scripps subsequently took corrective action to address the 
deficiencies in KNXV’s political file
142
provides no grounds for excusing its misconduct.
143
   
8. Station WMUR-TV, Manchester, NH  
54. We admonish Hearst Properties, Inc. (Hearst), the licensee of Station WMUR-TV, for 
maintaining a record in its political file for an Americans For Prosperity
144
advertisement that did not 
disclose any political matters of national importance that were communicated in the ad, in willful 
violation of Section 315(e)(2)(E) of the Act.
145
  The Americans for Prosperity advertisement was critical 
of the Affordable Care Act and of Ann McLane Kuster, candidate for the U.S. House of Representatives, 
for her support of it.
146
   Hearst concedes that the station’s political file omitted the name of both the 
legally qualified candidate
147
and a national legislative issue of public importance
148
referenced in the ad.  
Had Hearst disclosed either the candidate or the issue, we would have refrained in this instance from 
taking action in light of the fact that the conduct occurred before the issuance of the instant order.  
However, here, Hearst failed to disclose any of the information required by Section 315(e)(2)(E) with 
respect to the subject advertisement.
55. Hearst asserts that it has since conducted a review of its political file and taken steps to 
correct its omissions.
149
  As noted above, however, the fact that a licensee may have corrected deficiencies 
in its political file and instituted measures to ensure future compliance with Section 315(e) provide no 
grounds for excusing its misconduct.
150
                                                     
141
Id.  
142
Id.  
143
Supra n. 110.  Complainants also allege that station KNXV-TV violated Section 315(e)(2)(G) of the Act and 
Section 73.1212(e) of the Commission’s rules by maintaining a political file that disclosed the name of only one 
official of the sponsoring entity, rather than a “list” of officials. KNXV-TV Complaint at 6.  Because the subject 
disclosure was made prior to our clarification regarding licensees’ obligations to identify officials of sponsoring 
entities under these provisions, we decline to take enforcement action against Scripps for this alleged violation.
144
Americans for Prosperity describes itself as “a § 501(c)(4) entity, as determined by the Internal Revenue 
Service.”  See https://americansforprosperity.org/donate-today/. 
145
47 U.S.C. § 315(e)(2)(E).  See also WMUR-TV Complaint at 6-7.
146
Id. at 3.  
147
WMUR-TV Answer at 1.  Hearst states that the Complaint erroneously identified Carol Shea-Porter as the 
candidate whose identity was not properly disclosed in the Station WMUR-TV political file.  Id. at 1 and n. 1.   
148
Complainants describe the Affordable Care Act (also referred to as “Obamacare”) as the “quintessential 
legislative and controversial issue of public importance: the Act was President Obama’s key initiative and has been 
the subject of nationwide debate and court challenges, including at the Supreme Court.”  WMUR-TV Complaint at 
6.  In this context, the reference to the Affordable Care Act communicated a message relating to a national 
legislative issue of public importance that constituted a political matter of national importance.
149
WMUR-TV Answer at 1-2.
150
Supra n. 110.  Complainants also allege that station WMUR-TV violated Section 315(e)(2)(G) of the Act and 
Section 73.1212(e) of the Commission’s rules by maintaining a political file that disclosed the name of only one 
official of the sponsoring entity, rather than a “list” of officials. WMUR-TV Complaint at 6-7.  Because the subject 
disclosure was made prior to our clarification regarding licensees’ obligations to identify officials of sponsoring 
entities under these provisions, we decline to take enforcement action against Hearst for this alleged violation.         
Federal Communications Commission DA 17-14
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9. Station WDIV-TV, Detroit, MI
56. We admonish Graham Media Group (Graham Media), the licensee of station WDIV-TV, 
for maintaining a record in its political file for an Americans for Prosperity
151
advertisement that did not 
disclose any political matters of national importance that were communicated in the ad or any officials of 
the sponsoring entity, and for failing to place required materials in the file in a timely manner, in willful 
violation of Sections 315(e)(2)(E), 315(e)(2)(G), and 315(e)(3) of the Act.
152
  The ad mentioned U.S. 
Representative Gary Peters, who was running for the U.S. Senate from Michigan, and his support for the 
Affordable Care Act, under which, according to the ad, health care premiums were skyrocketing and
225,000 Michigan residents had lost health insurance coverage.
153
  Complainants allege that the political 
file for station WDIV-TV was deficient because it did not disclose the candidate, and it incorrectly 
identified the issue as “Americans for Prosperity.”
154
  Complainants further argue that the political file did 
not disclose a list of officers of the sponsoring entity, and materials were placed into the file in an 
untimely manner.
155
57. In its response on behalf of station WDIV-TV, Post-Newsweek Stations, Inc. (Post-
Newsweek), the parent company of the licensee of WDIV-TV, argues that the order form in the political 
file noted that the ad’s subject was “Anti-Peters Senate Race.”
156
  Post-Newsweek asserts that this 
disclosure satisfied the requirements of Section 315(e)(2)(E) by disclosing the name of the candidate (and 
the office sought).
157
  Post-Newsweek concedes that the station’s file did not identify the issue, but argues 
that under Section 315(e)(2)(E), it had the discretion to identify either the candidate or the issue in its 
political file.
158
  Post-Newsweek also concedes that it did not identify a list of officers.
159
58. We find that the reference to “Anti-Peters Senate Race” did not adequately identify the 
“name of the candidate” referenced in the ad.
160
  To ensure the public is fully informed as Congress 
intended, the full name of the candidate must be provided.  An oblique reference of the kind included in 
Station WDIV-TV’s political file to the name of the candidate does not satisfy the requirement that a 
political file contain a “complete” record of the ad. It also is unrefuted that Post-Newsweek did not 
identify the issue that was communicated in the ad and it did not provide a list of officers or like officials 
of the sponsoring organization.  In sum, Post-Newsweek failed to properly identify either the issue or the 
candidate in the station’s political file.  Furthermore, Post-Newsweek failed to identify any officers of 
Americans for Prosperity as required under Section 315(e)(2)(G). Had Post-Newsweek identified one 
                                                     
151
Americans for Prosperity describes itself as “a § 501(c)(4) entity, as determined by the Internal Revenue 
Service.”  See https://americansforprosperity.org/donate-today/. 
152
47 U.S.C. §§ 315(e)(2)(E), 315(e)(2)(G), and 315(e)(3).  See also WDIV-TV Complaint at 6-7.  
153
Id. at 3-4.  According to Complainants, the Affordable Care Act is “the quintessential legislative and 
controversial issue of public importance. It was President Obama’s key initiative and has been the subject of 
nationwide debate and court challenges, including at the Supreme Court.”  Id. at 6.  We agree.  In the context in 
which it was discussed, the references to the Affordable Care Act constituted a national legislative issue of public 
importance that was a political matter of national importance. 
154
Id. at 6-7.
155
Id. at 7-8.
156
WDIV-TV Answer at 3.
157
Id. 
158
Id. at 2-3.  
159
Id. 
160
47 U.S.C. § 315(e)(2)(E).
Federal Communications Commission DA 17-14
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officer, we would have refrained in this instance from taking action in light of the fact that the conduct 
occurred before the issuance of the instant order.  However, here, the licensee did not identify any officers 
or other like officials of the sponsoring organization.   
59. With regard to the allegation that the station failed to place materials into its political file 
in a timely manner, Section 315(e)(3) provides, in pertinent part, that “[t]he information required under 
this subsection shall be placed in a political file as soon as possible . . . .”
161
  In this context, the 
Commission has defined the phrase “as soon as possible” to mean “immediately absent unusual 
circumstances.”
162
  Post-Newsweek concedes, as alleged by Complainants,
163
that while it placed a record 
of the orders in WDIV-TV’s political file on January 17, 2014, two days before the spots started airing, it 
has no record that the final dispositions of the orders were placed in the file before April 1, 2014.
164
  Post-
Newsweek does not claim the existence of unusual circumstances that prevented it from placing the final 
dispositions of these orders in its political file in a timely manner.  Under the circumstances, we find that 
Post-Newsweek’s delay in placing required materials into WDIV-TV’s political file failed to meet the 
requirements of Section 315(e)(3) of the Act.
165
  
60. Based on the foregoing, we admonish Graham Media for not disclosing in Station 
WDIV-TV’s political file any political matters of national importance, not disclosing the names and titles 
of any officials of the sponsoring entity, and placing materials in the station’s political file in an untimely 
manner.  
10. Station WCNC-TV, Charlotte, NC  
61. We do not take enforcement action against WCNC-TV, Inc., the licensee of station 
WCNC-TV, for maintaining a record in its political file that did not identify all political matters of 
national importance communicated in a Patriot Majority USA
166
advertisement.   The Patriot Majority 
USA advertisement mentioned Thom Tillis, a 2014 Republican candidate for the U.S. Senate from North 
Carolina, and claimed that he supported the interests of insurance companies and “a plan that would end 
Medicare as we know it . . . . “
167
62. Gannett Co., Inc., the parent company of the licensee of WCNC-TV, properly identified 
the candidate in the Station WCNC-TV political file, but omitted information about the issues in the 
erroneous belief that Section 315(e)(2)(E) of the Act requires disclosure of one or the other (rather than 
                                                     
161
47 U.S.C. § 315(e)(3) (emphasis added).
162
47 CFR § 73.1943(c).
163
WDIV-TV Complaint at 7-8.
164
WDIV-TV Answer at 3. 
165
Placing information in a political file about the disposition of an order is particularly important because the 
disposition contains information about “the schedule of time purchased, when spots actually aired, the rates charged, 
and the classes of time purchased.”  See 47 CFR. § 73.1943(a).  Such information about the ultimate disposition of 
an order frequently differs from information that also is required to be placed in a station’s political file about the 
initial request to purchase broadcast time.  
166
Patriot Majority USA describes itself as an IRS Section 501(c)(4) organization whose primary purpose is to 
encourage “economic development in the United States.”  See http://www.patriotmajority.org/about. 
167
WCNC-TV Complaint at 3. Health care reform and Medicare are issues of continuing controversy, debate, 
dialogue, news reports, and national importance. The funding for and benefits provided by each program are 
subjects of ongoing political deliberation affecting millions of Americans.  In the context in which they were 
discussed in the ad, the references to health care reform and Medicare communicated messages relating to national 
legislative issues of public importance that constituted political matters of national importance.
Federal Communications Commission DA 17-14
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both, as we are clarifying today).
168
  Because the subject disclosure was made prior to the issuance of our 
clarification that licensees must disclose all candidates, elections, and issues referenced in each political 
ad that they broadcast, we decline to take enforcement action against WCNC-TV, Inc. for this alleged 
violation. 
11. Station KMGH-TV, Denver, CO  
63. We do not take enforcement action against Scripps Media, Inc. (Scripps), the licensee of 
station KMGH-TV, for maintaining a record in its political file that did not identify all political matters of 
national importance for a Senate Majority PAC
169
advertisement and did not identify all officers or like 
officials of the sponsoring organization.  The ad referenced two legally qualified candidates, Cory 
Gardner and Mark Udall, both of whom were candidates for the U.S. Senate from Colorado.  It endorsed 
Udall and criticized Gardner by suggesting that the latter candidate would “end Medicare’s guarantee, 
giving billions in profits to insurance companies, but forcing seniors to pay $6000 more a year.”
170
  
Scripps properly identified the two candidates in the Station KMGH-TV political file, but omitted 
information about Medicare
171
because, according to Scripps, the ad’s reference to Medicare was not in 
the context of any pending legislation.
172
   
64. Scripps should have identified in its political file that Medicare was mentioned in the ad
because, in this context, Medicare is a national legislative issue of public importance that constitutes a 
political matter of national importance.
173
  Nevertheless, we do not take action against Scripps in this 
instance because it properly identified the two candidates, and its failure to also disclose the subject issue 
was made prior to the issuance of our clarification that licensees must disclose all candidates, elections, 
and issues referenced in each political ad that they broadcast. 
65. Station KMGH-TV’s political file also disclosed the name of the Treasurer of the 
sponsoring entity, but no other official.
174
  As we clarify in this Order, when a licensee is provided with 
the name of just one official associated with the sponsoring entity, it has an obligation to inquire further 
whether there are any additional persons who should be disclosed.  Given that we had not previously 
clarified the obligation to make this inquiry, we will not take enforcement action against Scripps for its 
failure to do so.
IV. ORDERING CLAUSES
66. For the reasons set forth above, and pursuant to Sections 4(i), 4(j), and 315 of the 
Communications Act of 1934, as amended, 47 U.S.C. §§ 154(i) 154(j), and 315; and Sections 0.283 and 
73.1212 of the Commission’s rules, 47 CFR §§ 0.283 and 73.1212, IT IS ORDERED that Fox 
Television Stations, Inc., licensee of Station KMSP-TV, Minneapolis, MN, is ADMONISHED for its 
                                                     
168
WCNC-TV Answer at 2.
169
Senate Majority PAC is a political action committee that “seeks the election of Democratic U.S. Senators.”  See
http://www.senatemajority.com/about/.
170
KMGH-TV Complaint at 3.
171
Id. at 6-7.
172
KGMH-TV Answer at 1-2.
173
KMGH-TV Complaint at 3. Medicare is the subject of considerable ongoing debate, dialogue, controversy, and 
news reports affecting millions of Americans.  The funding for and benefits provided by this federal program are 
subjects of ongoing political deliberation and concern.  In the context in which it was discussed, the reference to 
Medicare communicated a message relating to a national legislative issue of public importance that constituted a 
political matter of national importance.
174
Id. at 12.
Federal Communications Commission DA 17-14
26
willful and/or repeated violation of Section 315(e)(2)(E) of the Act.
67. IT IS FURTHER ORDERED that New World Communications of Tampa, Inc., 
licensee of station WTVT(TV), Tampa, FL, is ADMONISHED for its willful and/or repeated violation 
of Section 315(e)(2)(E) of the Act.
68. IT IS FURTHER ORDERED that Media General Communications Holdings, LLC, 
licensee of Station WFLA-TV, Tampa, FL, is ADMONISHED for its willful and/or repeated violation of 
Section 315(e)(2)(E) of the Act.
69. IT IS FURTHER ORDERED NBC Telemundo License, LLC, licensee of Station 
WTVJ(TV), Miami, FL, is ADMONISHED for its willful and/or repeated violation of Section 
315(e)(2)(E) of the Act.
70. IT IS FURTHER ORDERED that WTVD Television, LLC, licensee of Station 
WTVD(TV), Durham, NC, is ADMONISHED for its willful and/or repeated violation of Section
315(e)(2)(E) of the Act.
71. IT IS FURTHER ORDERED that CBS Broadcasting, Inc., licensee of Station WWJ-
TV, Detroit, MI, is ADMONISHED for its willful and/or repeated violation of Section 315(e)(2)(E) of 
the Act.
72. IT IS FURTHER ORDERED that Scripps Media, Inc., licensee of Station KNXV-TV, 
Phoenix, AZ, is ADMONISHED for its willful and/or repeated violation of Section 315(e)(2)(E) of the 
Act.
73. IT IS FURTHER ORDERED that Hearst Properties, Inc., licensee of Station WMUR-
TV, Manchester, NH, is ADMONISHED for its willful and/or repeated violation of Section 315(e)(2)(E) 
of the Act.
74. IT IS FURTHER ORDERED that Graham Media Group, Michigan, Inc., licensee of 
Station WDIV-TV, Detroit, MI, is ADMONISHED for its willful and/or repeated violation of Section 
315(e)(2)(E), (e)(2)(G), and (e)(3) of the Act.  
75. IT IS FURTHER ORDERED that the complaints filed by Campaign Legal Center and 
Sunlight Foundation against each of captioned commercial television broadcast stations on May 1, 2014, 
are GRANTED to the extent indicated herein and OTHERWISE ARE DENIED.
76. IT IS FURTHER ORDERED that the complaint proceedings involving WCNC-TV, 
Inc., licensee of Station WCNC-TV, Charlotte, NC; and Scripps Media, Inc., licensee of Station KMGH-
TV, Denver, CO, ARE TERMINATED.
77. IT IS FURTHER ORDERED that copies of this Order shall be sent by first class mail 
to:
Kurt Wimmer, Esq., Covington & Burling, LLC, 1201 Pennsylvania Ave., N.W., Washington, 
DC  20004, Counsel for Gannett Company, Inc., parent company of WCNC-TV, Inc., licensee of 
Station WCNC-TV, Charlotte, NC;
Kenneth C. Howard, Jr., Esq., Baker & Hostetler LLP, Washington Square, Suite 1100, 1050 
Connecticut Ave., N.W., Washington, DC  20036, Counsel for Scripps Media, Inc., licensee of 
Station KMGH-TV, Denver, CO; 
Joseph M. Di Scipio, Vice President, Legal and FCC Compliance, Fox Television Stations, Inc., 
400 N. Capitol St., N.W., Suite 890, Washington, DC  20001, Counsel for Fox Television 
Stations, Inc., licensee of Station KMSP-TV, Minneapolis, MN;
Joseph M. Di Scipio, Vice President, Legal and FCC Compliance, Fox Television Stations, Inc., 
400 N. Capitol St., N.W., Suite 890, Washington, DC  20001, Counsel for New World 
Federal Communications Commission DA 17-14
27
Communications of Tampa, Inc., licensee of Station WTVT(TV), Tampa, FL;
Christina H. Burrow, Esq., Cooley LLP, 1299 Pennsylvania, Ave., N.W., Suite 700, Washington, 
DC  20004, Counsel for Media General Communications Holdings, LLC, licensee of Station 
WFLA-TV, Tampa, FL;
Margaret L. Tobey, Vice President, Regulatory Affairs and Assistant Secretary, NBCUniversal, 
300 New Jersey Ave., N.W., Suite 700, Washington, DC  20001, Counsel for NBC Telemundo 
License, LLC, licensee of Station WTVJ(TV), Miami, FL
John W. Zucker, Deputy Chief Counsel, ABC, Inc., 77 W. 66
th
St., New York, NY  10023, 
Counsel for WTVD Television, LLC, licensee of Station WTVD(TV), Durham, NC;
Martin P. Messinger, Chief Legal Officer, CBS Television Stations, Inc., a wholly owned 
Division of CBS Corporation, 524 W. 57
th
St., New York, NY  10019, parent company of CBS 
Broadcasting, Inc., licensee of Station WWJ-TV, Detroit, MI
Kenneth C. Howard, Jr., Esq., Baker & Hostetler LLP, Washington Square, Suite 1100, 1050 
Connecticut Ave., N.W., Washington, DC  20036, Counsel for Scripps Media, Inc., licensee of 
Station KNXV-TV, Phoenix, AZ;
Mark J. Prak, Esq., Brooks, Pierce, McLendon, Humphrey & Leonard, LLP, 1600 Wells Fargo 
Capitol Center, 150 Fayetteville St., Raleigh, NC 27601, Counsel to Hearst Properties, Inc., 
licensee of Station WMUR-TV, Manchester, NH; and
Jennifer A. Johnson, Esq., Covington & Burling, LLC, 1201 Pennsylvania Ave., N.W., 
Washington, DC  20004, Counsel for Post-Newsweek Stations, Inc., parent company of Graham 
Media Group, Michigan, Inc. licensee of Station WDIV-TV, Detroit, MI.
FEDERAL COMMUNICATIONS COMMISSION
William T. Lake
Chief, Media Bureau