Great Moments in Campaign Finance Disclosure

CORRECTION

Fri, 17 May 2013 21:25:11 -0400

From the Friends of Liberty for Jessica:

*******************************************************************************
CORRECTION- The candidate made a commitment of up to $15,000 to the 
campaign, but the money was never put into the campaign checking account.
The candidate used a personal credit card to purchase items for the campaign
and forgave those charges to thier personal credit card.

*******************************************************************************

Fourth Time Might Be The Charm

Fri, 17 May 2013 16:28:01 -0400

The Washoe County Republican Party’s federal account would like to be closed. It would really like to be closed, having filed four termination reports this year.

But the interesting thing is why it ever existed in the first place. County parties do have federal accounts, but this one was created last summer and specifically said that it was not affiliated with the state party. That’s because the state party was controlled by Ron Paul supporters, and the National Republican Senatorial Committee and Romney campaign did not want to funnel money for Nevada races through the state party. So they sent money to Washoe County instead.

Its 2012 duties fulfilled, the county party has no need for its federal account. Or rather, outsiders have no need for it.

Field Size Limits Are Enforced

Wed, 08 May 2013 11:30:32 -0400

From the Delaware Democratic State Committee:

Schedule H3 transfers from the account named 
Delaware Democratic Party - CoorCamp N is in fact 
a non-federal account of the committee.  Evidently 
the number of characters allowed in our filing software 
is less than the number of characters in the name of 
the account so the committee will abbreviate it in 
future filings to clearly identify it as a non-federal account.

Proprietary Software

Fri, 26 Apr 2013 14:23:37 -0400

The Andy Schmookler for Congress committee bought a license for software to file its reports. That license expired. Then it needed to amend its reports:

I understand the normal procedure for clarifying 
information previously reported to the FEC is to amend 
the report in question. However, the Andy Schmookler 
for Congress committee used proprietary campaign 
finance software to generate and file our reports in 2012. 
In the intervening months our license to use the software 
expired and our data was removed from the company's 
servers. Reactivating our license would have posed a 
financial cost we did not believe necessary nor intended 
by the RFAI. Since no fundamental changes to the report 
in question were necessary, such as might change the 
amount of money received or disbursed, we chose instead 
to provide the information requested via Form 99.

Way to own it, guys.

Seems Like a Problem

Wed, 24 Apr 2013 20:09:11 -0400

TECHNICAL LIMITATIONS DO NOT CURRENTLY ALLOW 
US TO FILE AMENDED 24 HOUR REPORTS which delete 
or change  items contained in the reports as originally filed.

Checks Made Out To Cash, You Say?

Wed, 24 Apr 2013 13:41:07 -0400

See if you can read between the lines of this submission by the Visclosky for Congress committee:

After an internal audit, the Visclosky for Congress campaign
committee is unable to verify the payee or purpose for the 
following cash disbursements: $2,000 on 7/2/2008, $3,000 
on 8/5/2008, $2,000 on 9/3/2008, $1,000 on 10/8/2008, 
$2,000 on 10/15/2008, $2,000 on 10/27/2008, $2,000 on 
11/3/2008 and $2,000 on 11/18/2008. The campaign 
committee has inadequate information to determine whether 
the payments were authorized. The payments were in the 
form of checks made out to cash and were signed and 
endorsed by Chuck Brimmer, a former campaign aide.

Top Secret

Thu, 11 Apr 2013 15:31:17 -0400

This electioneering communications filing from the Special Operations OpSec Education Fund is so top secret that it cannot divulge the amount spent, nor the candidates mentioned or recipients of the money.

What Part of "We're Not Disclosing" Do You Not Understand?

Wed, 10 Apr 2013 14:28:58 -0400

Crossroads GPS gently responds to the FEC’s latest request for disclosure of its donors:

We are in receipt of your Request For Additional 
Information (RFAI), dated April 9, 2013, regarding 
the 2012 Year End Report of Crossroads Grassroots 
Policy Strategies (Crossroads GPS).  This Request is 
the fourth such RFAI we have received on this exact 
same subject, and we refer you generally to our 
previous responses of July 19, 2011, and November 
29, 2012.

We are quite pleased to see in your most recent 
RFAI that the disclosure requirement set forth at 
11 C.F.R. ? 109.10(e)(1)(vi) is now more accurately 
paraphrased.  You now indicate that "Each contributor 
who made a donation in excess of $200 to further 
the independent expenditures must be itemized on 
Schedule 5-A, including their identification information." 
 Just as we noted in our previous responses, though, 
no contributions or donations accepted by Crossroads 
Grassroots Policy Strategies were solicited or received 
for the purpose of furthering the reported independent 
expenditures.  Accordingly, no contributions or donations 
were required to be reported under the regulations 
cited in the RFAI.

With respect to 11 C.F.R. ? 114.10(f), we refer you to 
our previous responses: 11 C.F.R. ? 114.10(f) applies 
to "qualified nonprofit corporations."  Crossroads GPS 
is not, and has never claimed to be, a "qualified nonprofit 
corporation."  If the cited provision has any relevance 
whatsoever to the reporting of contributions in connection 
with independent expenditures, it is, by its own terms, 
inapplicable to Crossroads GPS.

As we have noted before in response to your RFAIs, 
Crossroads GPS is familiar with and understands the 
applicable reporting regulations.  If the organization 
receives any contributions that are required to be reported 
pursuant to 11 C.F.R. ? 109.10(e)(1)(vi), those 
contributions will be reported as required.  Your continued 
RFAIs on this subject are unnecessary.  However, if you 
are required by Commission guidelines or procedures to 
continue to send them, we will continue to respond with 
the exact same explanation.

<coloneljessup>Are we clear?</coloneljessup>

It's Not Me, It's You

Tue, 09 Apr 2013 16:43:22 -0400

California congressional candidate Chuck Wilkerson would like to break up with the FEC:

My understanding is that the FEC has no further business 
with this campaign. The campaign office has been closed 
since early 2011 and I have concluded business as my last 
commuication of 12/25/12.

Please refer to MUR 6569.

Thanks for your attention to this as I've not heard from 
the FEC regarding being relieved of the need to file quarterlys.

Mistakes Were Made

Thu, 28 Mar 2013 11:35:43 -0400

From the Gun Owners of America:

The undersigned, who prepared and filed the required 
24-hour notices described above, is well aware of the 
FEC requirements for filing 24-hour notices and other 
reports with the FEC.  However, regarding the three IEs 
described above, the persons who arranged for the three 
IEs to be made violated GOA's established practices and 
neglected to inform the undersigned that the IEs were 
being made, preventing the required 24-hour notices 
from being timely filed with the FEC.

First Thing We Do, Let's Blame the Lawyer

Mon, 25 Mar 2013 18:08:39 -0400

From the Central Valley Independent super PAC:

We had a late 24 hour filing due to the fact that 
the attorney that we hired to fill out these reports 
did not advise us of the due dates and the requirements.  
He was advised to fill out the first form and he did and 
he was instructed to fill out the forms going forward.  
Instead he told us about the due date after it had passed

Human Error

Mon, 25 Mar 2013 15:42:00 -0400

The Operating Engineers Local 12 Voluntary Legislative Fund has “the best procedures” in place to prevent reporting mistakes. Or not:

The omission of the disbursement of $100,000.00
on 10/10/2012 that was inadvertently omitted 
was due to human error.
  
We have the best procedures in place to prevent 
and to find human errors.  Once the error was found 
the report was amended.

Following Instructions

Mon, 25 Mar 2013 15:14:33 -0400

The new Stand With Rand PAC is trying to be helpful, I’m sure, with its statement of organization. But, as the instructions clearly state:

Filing Reporting Trouble With Filing

Thu, 21 Mar 2013 16:14:00 -0400

Update: This is a test.

Hey, FEC, the Electrical Contractors PAC is having trouble with a Form 1 filing today. So they filed a report saying so:

I am trying to file a amended Form 1 but I am getting an error 
message from the website.
error Message:
the agency is taking a long time to respond to your e-filing.
Please check your email for a confirmation message. If you do not
receive this email from the governing agency within 15 minutes, 
we recommend trying to e-file your report again.


I have attempted several times. this Form 1 is due today.


Electrical Contractor PAC
C00113811

We No Longer Have Access To Our Database

Mon, 18 Mar 2013 16:15:15 -0400

This note from the treasurer of Daniel Bongino’s 2012 Senate campaign seems a little odd.

Significant Changes

Mon, 18 Mar 2013 16:05:12 -0400

The folks at the Tea Party.net Leadership Fund wrote to the FEC to say that it had found some “significant changes in the originally reported contribution amounts” of its Pre-General report filed last October. How significant? You know, just $124,571.52 more in receipts, a 416% increase over the originally reported amount. The amended filing is here.

As Far As I Recall...

Mon, 18 Mar 2013 14:17:25 -0400

Tim Kalemkarian, a once and future Senate candidate from California, has several committees. Sometimes it seems as if he can’t keep track of them.

Thank You, Maureen

Sun, 17 Mar 2013 16:51:18 -0400

Elouise Kennedy, treasurer of the Tarrant County (Texas) Republican Victory Fund, is new to the job:

I'm more than glad to file this form now that I am aware of it.  
I apologize for the delay but we have left numerous messages 
about this matter and was not given specific informantion until 
on 3/11/2013 when Maureen directed our office to this misc 
form 99 thank you Maureen

Having looked over past non federal years for filings it appears 
that we filed semi-annually and would like to continue this for 2013
Maureen said that we have to file our February report 
Please accept our apology as I'm new as of 6/2012
Elouise Kennedy  Treasurer

That Could Be My Money, But ...

Wed, 13 Mar 2013 11:30:00 -0400

Meet Daryle L. Doden of Fort Wayne, Indiana. Last year, Doden spent $87,172.50 on newspaper ads in support of Richard Mourdock, a Republican candidate for Senate who lost to Rep. Joe Donnelly in the Hoosier State. Individuals are permitted to conduct unlimited independent expenditures, on the understanding that the money used to finance them belongs to the individual.

But when the FEC asked about the source of the funding, Doden told the agency to pound sand, using the same language that non-profit organizations employ when they do IEs: that no money was given for the express purpose of conducting IEs for or against a specific candidate. From Doden’s response:

11 CFR 109.10(e)(1)(vi) requires that independent expenditure reports identify each person who made a contribution in excess of $200 to the person filing such report, which contribution was made for the purpose of furthering the reported independent expenditure. I did not solicit or receive any contributions that were required to be reported under this regulation.

What this suggest is that someone, likely Doden, spent money on the newspaper ads supporting Mourdock, but that the money wasn’t intended for a specific race. So an Indiana resident likely spent his own money on an Indiana Senate candidate (and no other races) but did not “raise” any money specifically for that purpose.

Ok.

McCotter to FEC: Have Mercy

Wed, 06 Mar 2013 11:25:10 -0500

Every day that the McCotter 2012 committee exists is just another reminder that Thad McCotter once tried to run for President. In order to remove that knowledge from us, the committee has asked the FEC to put it out of its misery via administrative termination:

McCotter 2012, Inc., respectfully requests that
the Commission administratively terminate its filing 
obligations pursuant to 11 CFR 102.4 based on 
the following factors-
1.	The Committee's aggregate reported activity 
in 2012 was less than $5,000. The Committee reported 
$659.70 in receipts and $971.98 in disbursements; 
$1,631.68 in the aggregate.
2.	The Committee received no contributions in 2012.
3.	The Committee's last two reports disclosed no 
disbursements.
4.	The Committee's primary purpose for filing its 
reports has been to disclose outstanding debts and obligations.
5.	The Committee's last report does not have 
substantial outstanding accounts receivable. Its 
accounts receivable balance is $761.00.
6.	The Committee's debts and obligations of $105,636.24 
exceed the total of the Committee's cash on hand balance of $615.10.

The Committee appreciates the Commission's consideration 
of this request and understands that its reporting obligation 
continues until such time as the Commission notifies the 
Committee of its administrative termination.