Federal Communications Commission DA 18-15
Before the
Federal Communications Commission
Washington, D.C. 20554
In the Matter of
NRT Communications Group, LLC
Application for License Renewal of Station
KVAW(TV), Eagle Pass, Texas 
)
)
)
)
)
)
NAL/Acct. No. 201841420001
Fac. ID No. 32621
FRN:  0020514378
File No. BRCDT-20140401AQE
ORDER
Adopted:  January 8, 2018 Released:  January 8, 2018
By the Chief, Media Bureau:
1. In this Order, we adopt the attached Consent Decree entered into between the Media Bureau 
(Bureau) of the Federal Communications Commission (Commission) and NRT Communications Group, 
LLC (NRT or Licensee).  The Consent Decree resolves issues raised in the Bureau’s review of the above-
captioned application for license renewal for station KVAW(TV), Eagle Pass, Texas (Station), 
specifically the Licensee’s compliance with:  (1) Section 73.3526(e)(11)(i) of the Rules,
1
 which requires 
broadcast stations to prepare and place on a quarterly basis in their local public inspection file TV 
issues/programs lists; (2) Section 73.3526(e)(11)(ii) of the Rules,
2
 which requires broadcast stations to 
prepare and place on a quarterly basis in their local public inspection file documentation demonstrating 
compliance with the Commission’s limits on commercial matter during children’s programming; (3) 
Section 73.3526(e)(11)(iii) of the Rules,
3
 which requires broadcast stations to prepare and place on a 
quarterly basis in their local public inspection file and file with the Commission Children’s Television 
Programming Reports; (4) Section 73.3526(e)(13) of the Rules requiring that each applicant for renewal 
of its license place into its public file a certification that the Station ran its required pre-filing and post-
filing public announcements, as required by Section 73.3580(h) of the Rules;
4
 (5) Section 73.3615 of the 
Rules requiring the filing of a biennial ownership report and ownership report upon change in ownership;
5
 
and (6) Section 73.3514(a) of the Rules requiring that each application filed with the Commission include 
all necessary information.
6
  
2. After reviewing its terms, we find that the public interest would be served by adopting the 
Consent Decree.  Although we conclude that the Consent Decree contains appropriate terms and 
conditions, after reviewing the record before us, we believe that the grant of a short-term renewal is 
appropriate in order to better ensure the Licensee’s ongoing compliance with the Act and the Rules.
7
  
1
 47 C.F.R. §§ 73.3526(e)(11)(i).
2
 47 C.F.R. §§ 73.3526(e)(11)(ii).
3
 47 C.F.R. §§ 73.3526(e)(11)(iii).
4
 47 C.F.R. § 73.3526(e)(13).
5
 47 C.F.R. § 73.3580(h).
6
 47 C.F.R. § 73.3514(a).
7
 Section 309(k)(1) of the Act states that the Commission shall grant a license renewal application “if it finds, with 
respect to that station, during the preceding term of its license—(a) the station has served the public interest, 
convenience, and necessity; (b) there have been no serious violations by the licensee of the Act or Commission rules 
and regulations; and (c) there have been no other violations by the licensee of the Act or Commission rules or 
(continued….)
Federal Communications Commission DA 18-15
2
Accordingly, Media Bureau staff is instructed to grant the renewal application, File No. BRCDT-
20140401AQE, and renew the Station’s license for a period of two years pursuant to Section 309(k)(2) of 
the Communications Act of 1934, as amended (Act).  Grant shall be conditioned upon KVAW fully and 
timely satisfying its obligation to pay the Civil Penalty as called for and in the manner set forth by 
paragraph 17 of the Consent Decree.  As a result, we need not determine whether KVAW committed 
“serious violations” of our rules or violations that constituted a “pattern of abuse” for purposes of Section 
309(k)(1).
8
  A copy of the Consent Decree is attached hereto and incorporated by reference.
3. Accordingly, IT IS ORDERED that, pursuant to Sections 4(i) of the Communications Act of 
1934, as amended,
9
 and authority delegated by Sections 0.61 and 0.283 of the Commission’s rules,
10
 the 
Consent Decree attached to this Order IS ADOPTED.
4. IT IS FURTHER ORDERED that the investigation by the Commission into the matters 
discussed above and in connection with this station IS TERMINATED.
5. IT IS FURTHER ORDERED that a copy of this Order and Consent Decree shall be sent by 
both First Class mail and Certified Mail, Return Receipt Requested, to the Licensee, NRT 
Communications Group, LLC, 2524 N. Veterans Blvd., Eagle Pass, TX 78852 and to its counsel, Alfonso 
Cabanas Esq., Cabanas Attorneys, The Tower Life Building, 310 S. St. Mary’s Street, Suite 955, San 
Antonio, TX 78205.
FEDERAL COMMUNICATIONS COMMISSION
Michelle M. Carey 
Chief, Media Bureau
(Continued from previous page)  
regulations which, taken together, would constitute a pattern of abuse.”  47 U.S.C. § 309(k)(1).  Section 309(k)(2) of 
the Act states, however, that if the licensee fails to meet this three-part standard, the Commission may deny the 
application—after notice and comment, and opportunity for hearing under Section 309(e) of the Act—“or grant the 
application on terms and conditions as are appropriate, including renewal for a term less than the maximum 
otherwise permitted.”  47 U.S.C. § 309(k)(2).  
8
 See Shareholders of Univision Communications Inc. et al., Memorandum Opinion and Order,  22 FCC Rcd 5842, 
5859, n.113 (2007)(“Given our finding that the grant of the renewal application is warranted under Section 
309(k)(2) of the Act because the consent decree contains appropriate terms and conditions, we need not determine 
whether Univision committed ‘serious violations’ of our rules or violations that constituted ‘a pattern of abuse’ for 
purposes of Section 309(k)(1)).” 
9
 47 U.S.C. §§ 154(i).  
10
 47 CFR §§ 0.61, 0.283.
Federal Communications Commission DA 18-15
Before the
Federal Communications Commission
Washington, D.C. 20554
In the Matter of
NRT Communications Group, LLC
Application for License Renewal of Station
KVAW(TV), Eagle Pass, Texas 
)
)
)
)
)
)
NAL/Acct. No. 201841420001
Fac. ID No. 32621
FRN:  0020514378
File No. BRCDT-20140401AQE
CONSENT DECREE
1. The Media Bureau (Bureau) of the Federal Communications Commission (Commission) and 
NRT Communications Group, LLC (NRT or Licensee), licensee of station KVAW(TV), Eagle Pass, 
Texas, hereby enter into this Consent Decree for the purpose of:  (i) resolving the Bureau’s investigation 
of NRT’s compliance with Sections 73.3526, 73.3615, 73.3514(a), and 73.3580(h) of the Commission’s 
rules
1
 and (ii) facilitating the short-term grant of the above captioned pending license renewal application.  
I. DEFINITIONS
2. For the purposes of this Consent Decree and Compliance Plan, the following definitions shall 
apply:
a) “Act” means the Communications Act of 1934, as amended, 47 U.S.C. § 151 et seq.
b) “Adopting Order” means the Order of the Commission adopting the terms of this Consent 
Decree without change, addition, deletion, or modification. 
c) “Bureau” means the Media Bureau of the Federal Communication Commission.
d) “Commission” or “FCC” mean the Federal Communications Commission and all of its 
bureaus and offices.  
e) “Communications Laws” means, collectively, the Act, the Rules, and the published and 
promulgated orders and decisions of the Commission to which NRT is subject by virtue 
of being a Commission licensee, and/or controlling party of a Commission licensee, 
including but not limited to 47 C.F.R. §§ 73.3526, 73.3615, 73.3514(a), and 73.3580(h).
f) “Division” means the Video Division of the Media Bureau.
g) “Effective Date” means the date on which the Bureau releases the Adopting Order.
h) “Investigation” means the Media Bureau’s investigation of NRT’s potential violations of 
47 C.F.R. § 73.3526, 73.3615, 73.3514(a), and 73.3580.
i) “License Renewal Application” means the license renewal application of station 
KVAW(TV), Eagle Pass, Texas, File No. BRCDT-201410401AOE. 
j) “Parties” means NRT and the Bureau, each of which is a “Party.”
k) “Public file” or “E-pif” refers to the documents a commercial broadcast station is 
required to maintain as part of its local public inspection file, as required by Section 
73.3526 of the Rules.
1
 47 CFR §§ 73.3526, 73.3615, 73.3514(a), and 73.3580(h).
Federal Communications Commission DA 18-15
2
l) “NRT” means NRT Communications Group, LLC and its subsidiaries, affiliates, 
successors, assigns, and/or transferees.
m) “Rules” means the Commission’s regulations found in Title 47 of the Code of Federal 
Regulations.
n) “Station” means the broadcast television station KVAW(TV), Eagle Pass, Texas.
II. BACKGROUND
3. On April 1, 2014, the Licensee timely filed its license renewal application (FCC Form 303-S) 
for the Station.
2
  The Licensee acquired the Station on May 13, 2011, and in its License Renewal 
Application was required to certify its compliance with all Commission rules, including compliance with 
the Station’s public file requirements from the date of acquisition.   A review of the Station’s e-pif by 
Division staff revealed that numerous documents were either missing or filed late.  On January 6, 2016, 
Division staff sent the Licensee a letter of inquiry seeking information concerning the missing and late-
filed public file documents, including compliance with Section 73.3526 of the Rules since the Station was 
acquired by NRT.
3
  On March 4, 2016, NRT filed a response with the Commission answering all 
questions presented in the letter.
4
  Specifically, NRT stated that:  (1) with the exception of third quarter of 
2014, first quarter 2016, and second quarter 2016, no quarterly TV issues/programs lists or commercial 
limit certifications were prepared since the Licensee acquired the Station; (2) all the of Station’s 
Children’s Television Programming Reports, with the exception of first and third quarters of 2014 were 
filed late; (4) it failed to place in the Station’s electronic public file a certification that the Station aired its 
local public announcements concerning the filing of the Station’s license renewal; and (5) the Station 
failed to file its “post-closing” media ownership report, which should have been filed by June 12, 2011, as 
well as file in a timely manner its 2011 Biennial Ownership Report.
5
4. Section 73.3526 of the Rules requires each full power broadcast licensee to maintain a 
public file containing information related to a station’s operations.  In particular, Subsection 
73.3526(e)(11)(i) requires every full power television licensee to place in its public file, on a quarterly 
basis, a TV issues/programs list which details programs that have provided the station’s most significant 
treatment of community issues during the preceding three-month period and must include a brief narrative 
of the issue addressed, as well as the time, date, duration, and title of each program that addressed the 
issue.  Subsection 73.3526(e)(11)(ii) of the Rules requires each commercial television licensee to prepare 
and place in its public inspection file, on a quarterly basis, records sufficient to substantiate the Station’s 
certification, in its license renewal application, of compliance with the commercial limits on children’s 
programming.
6
  That subsection also requires those licensees to file the records with the Commission by 
the tenth day after the close of the reporting quarter.
7
  Copies of these documents must be retained until 
final action on the station’s next license renewal application.  
2
 License Renewal Application.
3
 Letter from David Brown, Deputy Chief, Video Division, Media Bureau to NRT Communications Group, LLC, 
Daniel Kirkpatrick, Esq., and Francisco R. Montero, Esq. (Jan. 6, 2016).
4
 NRT was required to file a response to the LOI within 30 days.  NRT requested two requests for extension of time 
to respond, both requests were granted by Division staff.
5
 Response from Francisco R. Montero and Anne Goodwin Crump, Counsel to NRT Communications Group, LLC 
to Ms. Marlene Dortch, Secretary, Federal Communications Commission (Mar. 4, 2016) (LOI Response).
6
 47 CFR § 73.3526(e)(11)(ii).  
7
 Starting March 31, 2016, broadcasters are required to file their quarterly Children’s Television Programming 
Reports using the Commission’s Licensing and Management System (LMS).  See All Children's Television 
Programming Reports Must Be Filed Using the Commission's Licensing and Management System, Public Notice, 31 
FCC Rcd 1104 (MB 2016).   Prior to that date, all quarterly Children’s Television Programming Reports were filed 
using the Commission’s KidVid Online Filing System.   
Federal Communications Commission DA 18-15
3
5. In 2012, the Commission adopted Section 73.3526(b) of the Rules, which requires licensees 
to upload elements of Stations’ physical public file to an on-line Commission hosted website (i.e., a 
Station’s e-pif or electronic public file).
8
  The Commission’s electronic public file requirement was 
implemented as a means to modernize the way that television broadcasters “inform the public about how 
they are serving their communities….”
9
  Broadcasters’ e-pif requirements were phased in between August 
2012 and February 2013.  Beginning August 2, 2012, stations were required to post any document that 
would otherwise be placed in a station’s public file, with limited exception, to their e-pif on a going-
forward basis.  By February 4, 2013, stations were required with limited exception to upload to their e-pif 
those documents that were already in their physical public file prior to August 2, 2012.
10
  Under Section 
73.3526(b)(2) of the Rules, copies of a Station’s Commercial Limit Certifications and TV 
issues/programs lists, among other items, must be placed in its e-pif.  
6. Since acquiring the Station in May 2011, with the exception of third quarter of 2014, all of 
2016 and first quarter of 2017, the Licensee failed to prepare any quarterly TV issues/programs lists.
11
 
Furthermore, no commercial limit certifications were prepared, however, NRT has placed a certification 
in its electronic public file certifying that for the prior license term the Station complied with the 
Commission’s commercial limit rules.
12
  Finally, with the exception of first and third quarters of 2014, all 
the Station’s Children’s Television Programming Reports were filed late.
7. Subsection 73.3526(e)(13) of the Rules provides that “[e]ach applicant for renewal of license 
shall, within 7 days of the last day of broadcast of the local public notice of filing announcements 
required pursuant to § 73.3580(h), place in the station's local public inspection file a statement certifying 
compliance with this requirement....”
13
  NRT not only admits that it failed to upload any statements that 
would demonstrate compliance with this requirement,
14
 but it also failed to air the required pre-filing and 
8
 See Standardized and Enhanced Disclosure Requirements for Television Broadcast Licensee Public Interest 
Obligations, Extension of the Filing Requirement for Children’s Television Programming Report, Second Report 
and Order, 27 FCC Rcd 4535 (2012) (“Second R&O”) (requiring broadcast television stations to post their public 
inspection files, with limited exceptions, to an online Commission-hosted database).
9
 Second R&O, 27 FCC Rcd at 4536.  
10
 See Effective Date Announced for Online Publication of Broadcast Television Public Inspection Files, Public 
Notice, 27 FCC Rcd 7478 (2012) (announcing effective date of electronic public file rule); Television Broadcast 
Stations Reminded of Their Online Public Inspection File Obligations, Public Notice, 27 FCC Rcd 15315 (2012) 
(reminding station’s to upload copies of existing public file documents to their electronic public file); Television 
Broadcast Stations Reminded of the Upcoming Public Inspection Filing Deadline, Public Notice, 28 FCC Rcd 429 
(2013) (providing a final remainder to broadcasters to upload copies of existing public file documents to their 
electronic public file); see Second R&O, 27 FCC Rcd at 4580 (establishing compliance periods for complying with 
broadcasters new electronic public file requirement).
11
 NRT states that the TV issues/programs lists for the portion of second quarter 2011 that it was the licensee, as 
well as third quarter 2011 and fourth quarter 2011 would have stated that the Station was off-the-air and therefore 
not offering any issue-responsive programming.  LOI Response at 2.  While the Station prepared TV 
issues/programs lists for first, third and fourth quarters of 2016 and first quarter of 2017, these reports were not 
prepared or placed in the station’s e-pif in a timely manner.  In addition, the TV issues/program list for third quarter 
of 2014 includes programming for the months of May, June, July and August.  The report should have included 
programming for July, August and September.  May and June should have been included in the Station’s second 
quarter TV issues/programs list, which was never prepared.     
12
 LOI Response at 2.  After filing its LOI Response the licensee filed commercial limit certifications for first 
quarter and second quarter of 2016.  It has failed to place another certification in its public file stating that it has 
complied with the commercial limit rules for third and fourth quarter of 2016 and first quarter of 2017.
13
 47 CFR § 73.3526(e)(13).
14
 LOI Response at 3.
Federal Communications Commission DA 18-15
4
post-filing announcements required by Section 73.3580(d)(4) of the Rules.
15
  Consistent with Bureau 
practice in such a circumstance, Division staff instructed NRT to run the required post-filing 
announcements, as laid out by Section 73.3580(d)(4)(ii),
16
 and upon completion of those announcements 
place in the Station electronic public file the certification required pursuant to Section 73.3580(h).
17
  Such 
a certification has been filed and no objections to renewal of the Station’s license were received.  
8. Section 73.3615 of the Rules requires all full power television stations, as well as entities 
with attributable interests are required to file an ownership report using FCC Form 323 on a biennial 
basis.
18
  In addition, a FCC Form 323 is required to be filed within thirty (30) days of consummation of an 
authorized assignment or transfer of control of a permit or license.  The new licensee is required to give 
the same information required in a Station’s biennial ownership report.
19
  NRT states that it failed to file 
its “post-closing” ownership report within thirty days of acquiring the Station.  NRT goes on to admit that 
it also did not file its 2011 biennial ownership report until February 16, 2012, over two-months after the 
filing deadline.
20
  
9. Section 73.3514(a) of the Rules provides that “[e]ach application shall include all information 
called for by the particular form on which the application is required to be filed....”
21
 Section IV, of the 
license renewal application requires the licensee to certify that during the license term it complied with 
various aspects of the Rules, including placing required documents into the Station’s public file, as 
required by Section 73.3526 of the Rules and filing biennial ownership reports as required by Section 
73.3615 of the Rules.   In response to Question 3 in its license renewal application, NRT certified that it 
had placed all required documents as required. NRT failed to disclose that it had failed to prepare and/or 
place in a timely manner the aforementioned documents and forms.  The Licensee has subsequently 
amended the License Renewal Application to reflect its failures.  
10. The Bureau and NRT have negotiated the terms of the Consent Decree that terminates all 
investigations into the matters raised in this proceeding.  As part of the Consent Decree, NRT has agreed 
to make a settlement payment of Twelve Thousand Five Hundred ($12,500) to the U.S. Treasury, and to 
implement and maintain a Compliance Plan designed to ensure its future compliance with the Act and 
Commission’s rules, including those discussed above.  
III. TERMS OF AGREEMENT
11. Adopting Order.  The Parties agree that the provisions of this Consent Decree shall be 
incorporated by reference in an Adopting Order without change, addition, deletion or modification.
12. Jurisdiction.  NRT agrees that the Commission has jurisdiction over it and the matters 
contained in this Consent Decree and that the Bureau has the authority to enter into and adopt this 
Consent Decree.
15
 47 CFR § 73.3580(d)(4).  The Licensee admitted to this failure via e-mail correspondence with Division staff.
16
 47 CFR § 73.3580(d)(4)(ii).  
17
 47 CFR § 73.3580(h).
18
 47 CFR § 73.3615(a).  Stations were first required to file a revised FCC Form 323 on or before November 1, 
2009, with information current as of October 1, 2009, and to file biennially thereafter.  In 2011 the Bureau extended 
the filing deadline.  See Promoting Diversification in the Broadcasting Services, MB Docket No. 07-294, Order, 26 
FCC Rcd 11464 (extending the filing deadline to file 2011 Biennial Ownership Reports until December 1, 2011).   
19
 47 CFR §73.3615(b).
20
 LOI Response at 1-2.
21
 47 CFR § 73.3514(a).
Federal Communications Commission DA 18-15
5
13. Effective Date.  The Parties agree that this Consent Decree shall become effective on the 
Effective Date as defined herein.  As of the Effective Date, the Adopting Order and this Consent Decree 
shall have the same force and effect as any other order of the Commission.  
14. Violations.  The Parties agree that any violation of the Adopting Order or of the terms of this 
Consent Decree shall constitute a separate violation of a Commission order, entitling the Commission or 
it delegated authority to exercise any rights and remedies attendant to the enforcement of a Commission 
order.
15. Termination of Investigation; Grant of Short-Term Renewal Application.  In express reliance 
on the covenants and representations in this Consent Decree and to avoid further expenditure of public 
resources, the Bureau agrees to terminate the Investigation.  In consideration for the termination of the 
Investigation, NRT agrees to the terms and conditions contained herein.  The Bureau further agrees to 
grant absent any other restrictions, in conjunction and simultaneously with the adoption of this Consent 
Decree, the License Renewal Application for a period of two years from the Effective Date.  In 
consideration for the termination of the Investigation, NRT agrees to the terms, conditions, and 
procedures contained herein, including the actions specified in Paragraphs 17 and 20.  Grant of the 
License Renewal Application is expressly conditioned on NRT fully and timely satisfying its obligation 
to make a total Civil Penalty Payment in the amount of $12,500 in the manner specified in paragraph 17 
of this Consent Decree.  The Bureau further agrees that in the absence of new material evidence or failure 
by NRT to satisfy the terms and conditions set forth in paragraphs 17 and 20 of the Consent Decree, it 
will not use the facts developed, in whole or in part, from the Investigation through the Effective Date, or 
the existence of this Consent Decree to institute on its own motion any proceeding, formal or informal, or 
take any action on its own motion against NRT concerning the matters that were the subject of the 
Investigation.  Nor will the Bureau take any action in response to any petition to deny, complaint or 
objection against NRT concerning the matters that were the subject of the Investigation.  The Bureau also 
agrees that, in the absence of new material evidence or failure by NRT to satisfy the terms and conditions 
set forth in paragraphs 17 and 20 of the Consent Decree, it will not use the facts developed in the 
Investigation through the Effective Date, or the existence of this Consent Decree, to institute on its own 
motion any proceeding, formal or informal, or take any action in response to any petition to deny, 
complaint or objection, against NRT with respect to its basic qualifications, including its character 
qualifications, to be a Commission licensee or to hold Commission licenses or authorizations.
16. Subsequent Investigations.   Except as expressly provided herein, this Consent Decree shall 
not prevent the Bureau or Commission from investigating new evidence of noncompliance by NRT with 
the Communications Laws.  Nothing in this Consent Decree shall prevent the Commission or its 
delegated authority from adjudicating complaints or other adjudicatory pleadings filed against NRT for 
alleged violations of the Act or the Commission’s rules or for any other type of alleged misconduct, 
regardless of when such misconduct took place, subject to the limitations set forth in Paragraph 15.  The 
Bureau or Commission’s adjudication of any such complaints or pleadings will be based solely on the 
record developed in subsequent proceedings.  
17. Civil Penalty.  NRT will pay a civil penalty to the United States Treasury in the amount of 
Twelve Thousand, Five Hundred Dollars ($12,500) within ten (10) days after the Effective Date (Civil 
Penalty).  NRT acknowledges and agrees that upon execution of this Consent Decree, the Civil Penalty 
shall become a “Claim” or “Debt” as defined in 31 U.S.C. § 3701(b)(1).
22
  NRT shall send electronic 
notification of payment to Evan Morris at evan.morris@fcc.gov on the date said payment is made.  The 
payment must be made by check or similar instrument, wire transfer, or credit card, and must include the 
FRN captioned above.
23
  An FCC Form 159 (Remittance Advice) must be submitted with payment unless 
22
 Debt Collection Improvement Act of 1996, Pub. L. No. 104-134, 110 Stat. 1321, 1358 (1996).
23
 Payment may be made online at the Commission’s Fee Filer website: https://www.fcc.gov/encyclopedia/fee-filer.  
Online payments do not require Licensees to submit FCC Form 159.  Alternatively, payment may be made using 
FCC Form 159; detailed instructions for completing the form may be obtained at 
(continued….)
Federal Communications Commission DA 18-15
6
payment is made online at the Commission’s Fee Filer website.
24
  When completing the FCC Form 159, 
enter the Account Number in block number 23A (call sign/other ID) and enter the letters “FORF” in 
block number 24A (payment type code).  Below are additional instructions that NRT should follow based 
on the form of payment it selects: 
? Payment by check or money order must be made payable to the order of the Federal 
Communications Commission.  Such payments (along with the completed Form 159) must be 
mailed to Federal Communications Commission, P.O. Box 979088, St. Louis, MO 63197-
9000, or sent via overnight mail to U.S. Bank – Government Lockbox #979088, SL-MO-C2-
GL, 1005 Convention Plaza, St. Louis, MO 63101.  
? Payment by wire transfer must be made to ABA Number 021030004, receiving bank 
TREAS/NYC, and Account Number 27000001.  To complete the wire transfer and ensure 
appropriate crediting of the wired funds, a completed Form 159 must be faxed to U.S. Bank 
at (314) 418-4232 on the same business day the wire transfer is initiated.  
? Payment by credit card must be made by providing the required credit card information on 
FCC Form 159 and signing and dating the Form 159 to authorize the credit card payment.   
The completed Form 159 must then be mailed to Federal Communications Commission, P.O. 
Box 979088, St. Louis, MO 63197-9000, or sent via overnight mail to U.S. Bank – 
Government Lockbox #979088, SL-MO-C2-GL, 1005 Convention Plaza, St. Louis, MO 
63101.  
18. Waivers.  As of the Effective Date, NRT waives any and all rights it may have to seek 
administrative or judicial reconsideration, review, appeal or stay, or to otherwise challenge or contest the 
validity of this Consent Decree and the Adopting Order.  NRT shall retain the right to challenge the 
Commission’s interpretation of the Consent Decree or any terms contained herein.  If either Party (or the 
United States on behalf of the Commission) brings a judicial action to enforce the terms of the Adopting 
Order, neither NRT nor the Bureau shall contest the validity of the Consent Decree or the Adopting 
Order, and NRT shall waive any statutory right to a trial de novo.  NRT hereby agrees to waive any 
claims it may have under the Equal Access to Justice Act, 5 U.S.C. § 504 and 47 C.F.R. § 1.1501 et seq., 
relating to the matters addressed in this Consent Decree.  Notwithstanding any provision of this Consent 
Decree or the Adopting Order, the Bureau may consider the terms of the Consent Decree void and of no 
further force and effect if the condition specified in paragraph 17 is not fully and timely satisfied by NRT.
19. Admission of Liability.  NRT admits for the purpose of this Consent Decree and for 
Commission civil enforcement purposes, and in express reliance on the provisions of paragraph 15 herein, 
to the facts discussed in paragraphs 3-10 regarding NRT’s failure to meet the requirements of Sections 
73.3526, 73.3514(a), 73.3615, and 73.3580(h) of the Rules.  By entering into this Consent Decree, NRT 
makes no other admission of liability or violation of any law, regulation or policy, and the Commission 
makes no finding of any such liability or violation.  
20. Compliance Plan. In recognition that NRT’s policies and practices regarding compliance with 
the Rules, especially Section 73.3526, can be enhanced to ensure compliance in the future, NRT agrees to 
implement a compliance plan at the Station and at any station acquired by NRT, as well as any station 
licensed to NRT that becomes newly subject to the applicable requirements while the Compliance Plan 
remains in effect.  A copy of the Compliance Plan is provided below.  NRT agrees, to the extent that it 
has not already done so, to implement the Compliance Plan within thirty (30) calendar days following the 
Effective Date and to keep such Compliance Plan in effect until Commission action on the Station’s next 
license renewal application is final.
(Continued from previous page)  
http://www.fcc.gov/Forms/Form159/159.pdf. 
24
 Should the Licensee have questions regarding payment procedures, it should contact the Financial Operations 
Group Help Desk by phone at 1-877-480-3201, or by e mail at ARINQUIRIES@fcc.gov.
Federal Communications Commission DA 18-15
7
21. Severability.  The Parties agree that if any of the provisions of the Consent Decree shall be 
held unenforceable by any court of competent jurisdiction, such unenforceability shall not render 
unenforceable the entire Consent Decree, but rather the entire Consent Decree shall be construed as if not 
containing the particular unenforceable provision or provisions, and the rights and obligations of the 
Parties shall be construed and enforced accordingly.
22. Invalidity.  In the event that this Consent Decree in its entirety is rendered invalid by any 
court of competent jurisdiction, it shall become null and void and may not be used in any manner in any 
legal proceeding.  
23. Subsequent Rule or Order.  The Parties agree that if any provision of the Consent Decree 
conflicts with any subsequent rule or order adopted by the Commission (except a rule or order specifically 
intended to revise the terms of this Consent Decree to which NRT expressly consents) that provision will 
be superseded by such rule or Commission order. A conflict will be considered to have arisen in the event 
that the Licensees or DTV Holding are unable to comply with both the terms and conditions of the 
Consent Decree and the Communications Laws, as amended.
24. Successors and Assigns.  NRT agrees that the provisions of this Consent Decree shall be 
binding on its subsidiaries, affiliates, successors, assigns, and/or transferees.  
25. Final Settlement.  The Parties agree and acknowledge that this Consent Decree shall 
constitute a final settlement between the Parties with respect to the Investigation.
26. Modifications.  This Consent Decree cannot be modified without the advance written consent 
of all Parties.
27. Paragraph Headings.  The headings of the paragraphs in this Consent Decree are inserted for 
convenience only and are not intended to affect the meaning or interpretation of this Consent Decree.
28. Authorized Representative.  Each Party represents and warrants to the other that it has full 
power and authority to enter into this Consent Decree.  Each person signing this Consent Decree on 
behalf of a Party hereby represents that he or she is fully authorized by the Party to execute this Consent 
Decree and to bind the Party to its terms and conditions. 
29. Counterparts.  This Consent Decree may be signed in any number of counterparts, each of 
which, when executed and delivered (including by pdf or facsimile), shall be an original, and all of which 
counterparts together shall constitute one and the same fully executed instrument.
Federal Communications Commission DA 18-15
8
Federal Communications Commission
By:
________________________________
Michelle M. Carey
Chief, Media Bureau 
________________________________
Date
NRT Communications Group, LLC
By:
________________________________
Susanna Guillen de Gonzalez
Manager
________________________________
Date
Federal Communications Commission DA 18-15
9
COMPLIANCE PLAN OF NRT COMMUNICATIONS GROUP, LLC
In order to ensure future compliance with the Rules and the Act, NRT will institute the following 
procedures for any television or radio station that is licensed, controlled or subsequently acquired by it.  
This Compliance Plan is meant to cover, but is not limited to, KVAW(TV), Eagle Pass, Texas.  Unless 
otherwise provided, all terms defined in paragraph 2 of the Consent Decree apply to this Compliance 
Plan.  The terms of this Compliance Plan shall remain in effect until action on the Station’s next license 
renewal application is final.
1. NRT will designate a Compliance Officer responsible for responding to employee questions, 
consulting with FCC Counsel regarding compliance matters, and ensuring all stations operate in 
compliance with the Rules and the Act, including but not limited to Sections 73.3526, 73.3615, 
73.3514(a), and 73.3580(h) of the Rules.  The name and contact information for the Compliance Officer 
shall be listed in a document and placed in the Station’s electronic public file under the folder entitled 
“FCC Investigations or Complaints.”
2. In order to ensure compliance with the FCC's related rules and policies the Compliance 
Officer will oversee, as applicable, the preparation and filing of all public file documents, the 
maintenance of its physical and electronic public files, the preparation and filing of all other required FCC 
Forms and applications, and the payment of any applicable filing and regulatory fees.
3. The Compliance Officer will conduct training for all station employees and management at 
least once every twelve (12) months on compliance with FCC Rules applicable to his or her duties at the 
station.  The first training shall occur within thirty (30) days of the Effective Date.  A certification that the 
aforementioned training has occurred shall be placed in the online electronic local public inspection file 
for the Station within three (3) business days. 
4. The Compliance Officer will train any new employee within five (5) business days of 
commencement of his or her duties at the station.  Notice to the Bureau that this training has occurred is 
not required, but the employee must sign a declaration affirming that such training has occurred and such 
declaration must be retained by NRT for the term of the Compliance Plan and be provided to the Bureau 
upon request
5. The Compliance Officer will be responsible for remaining up-to-date on developments in 
communications law applicable to the station and its operations.  This may include consultation with an 
outside third-party, such as legal counsel, in order to obtain guidance on FCC compliance issues and to 
review all applications, documents, and reports prior to filing with the FCC.  In regards to the last matter, 
NRT recognizes and acknowledges that any and all information provided to the FCC must completely and 
candidly set forth all relevant facts and circumstances, regardless of whether such submission may 
disclose a violation of the Rules or the Act.