FEDERAL ELECTION COMMISSION 

WASHINGTON. D.C. 20463 

BEFORE THE FEDERAL ELECTION COMMISSION 

In the Matters of ) 

) MUR 6391 &MUR 6471 

Commission on Hope, Growth & ) 

Opportunity ) 

STATEMENT OF REASONS OF 

VICE CHAIRMAN STEVEN T. WALTHER 

I. Introduction 

Two administrative complaints were filed against the Commission on Hope, Growth & 

Opportunity ("CHGO"), a District of Columbia non-profit association formed on March 31, 2010 

and organized under section 501(c)(4) of the Internal Revenue Code. The first complaint 

("DCCC Complaint") was filed on October 7, 2010, by the Democratic Congressional Campaign 

Committee ("DCCC") and is referenced as Matter Under Review ("MUR") 6391.' The second 

complaint ("CREW Complaint") was filed on May 23, 2011, and amended ("CREW Amended 

Complaint") on April 26, 2012 by Citizens for Responsibility and Ethics in Washington 

("CREW") and its former Executive Director, Melanie Sloan, and is referenced as MUR 6471.^ 

The complaints alleged that CHGO violated the Federal Election Campaign Act ("FECA" or the 

"Act") by (I) failing to properly report its spending on election-related communications, 

(2) failing to include proper disclaimers on them, and (3) failing to organize, register and report 

as a political committee. 

DCCC alleged that CHGO violated the Act by spending over $600,000 in the 2010 

elections to air several advertisements that were either independent expenditures or 

electioneering communications, and that CHGO failed to report the advertisements and failed to 

include proper disclaimers. 

CREW alleged that CHGO violated the Act by spending over $2.3 million in the 2010 

elections to broadcast fifteen advertisements in twelve Congressional races, and that the 

' DCCC's FEC complaint is available at http.V/eqs.fec.gov/eqsdocsMUR/l 5044380002.pdf. 

^ The CREW Complaint and the CREW Amended Complaint are available at. 

http://eqs.fec.gOv/eqsdocsMUR/lS044380186.pdf and http://eqs.fec.gov/eqsdocsMUR/15044380263.pdf. 

' See 52 U.S.C. § 30102 ("Organization of political committees"), 52 U.S.C. § 30103 ("Registration of political 

committees") and 52 U.S.C. § 30104 ("Reporting requirements"). 
MUR 6391 & MUR 6471 (Commission on Hope, Growth & Opportunity) 

Statement of Reasons of Vice Chairman Steven T. Walther 

advertisements were either independent expenditures or electioneering communications that 

CHGO failed to report and failed to include proper disclaimers. CREW further alleged that 

CHGO's extensive election-related spending, along with the lack of any significant non-electoral 

activity, indicated that CHGO may have violated the FECA by failing to organize, register, and 

report as a political committee in 2010. 

In response to the complaints, CHGO denied the allegations, asserting that the 

advertisements did not constitute express advocacy, that it did not engage in electoral politics at 

the federal level, and that its public communications were specifically issue-oriented. According 

to CHGO, its sole purpose was to educate the public on matters of economic policy formulation, 

and therefore it was not a political committee. CHGO further stated that none of its 

communications was targeted at any specific electoral constituency, that any error in disclosing 

electioneering communications was made in good faith, and that the policy behind disclosure 

was satisfied by the disclaimer CHGO attached to each advertisement, as well as by the 

information made available by broadcasters as required by the Federal Communications 

Commission ("FCC"). 

On September 16, 2014, the Commission unanimously found reason to believe ("RTB") 

in these matters that CHGO violated the Act by failing to report several advertisements that it 

had disseminated in 2010 as electioneering communications or independent expenditures. 

However, the Commission deadlocked twice - on September 16, 2014 and October 1, 2015 - on 

the central issue of whether there was reason to believe CHGO had achieved political committee 

status.^ As a political committee, CHGO would have been required to register with the 

Commission and file disclosure reports that would have publicized all of its contributions and 

disbursements in a timely manner. 

On October 1, 2015, the Commission voted again on the political committee status issue. 

Three Commissioners, Commissioner Ravel, Commissioner Weintraub and I, voted to find RTB 

that CHGO may have violated the Act by failing to report and register as a political committee 

and failing to file reports as a political committee. Following the second and fateful deadlock, 

the Commission voted, as a matter of common practice, to close the file.® 

On November 6, 2015, Commissioners Matthew S. Petersen, Caroline C. Hunter and Lee 

E. Goodman, jointly issued their "Statement of Reasons" ("Controlling Group SOR") stating 

why they voted in each instance in these matters against the recommendations of the Office of 

General Counsel ("OGC") to find reason to believe on the political committee status issue, which 

" CHGO's responses to the complaints are available at http://eqs.fec.gov/eqs/searcheqs?SUBMIT=continue. 

' See Amended Certification in MUR 6391 and 6471, dated Sept. 16,2014, available at 

http://eqs.fec.gOv/eqsdocsMUR/l5044380338.pdf, and Certification in MUR 6391 and 6471, dated Oct. 1,2015, 

available at http://eqs.fec.gov/eqsdocsMUR/15044380400.pdf. 1 voted in each of those instances, along with 

Commissioners Ann M. Ravel and Ellen L. Weintraub, to find reason to believe that CHGO may have violated the 

Act's political committee status provisions. 

'See Certification in MUR 6391 and 6471, dated Oct. 1,2015. The vote to close the file was approved by five 

Commissioners; I dissented. 

Page 2 of 18 
MUR 6391 & MUR 6471 (Commission on Hope, Growth & Opportunity) 

Statement of Reasons of Vice Chairman Steven T. Walther 

effectively prevented the Commission from further pursuing CHGO for failing to organize, 

register and report as a political committee.' 

On November 23, 2015, CREW, one.of the two administrative complainants, exercised 

its statutory right to file suit in U.S. District Court pursuant to section 30109(a)(8) of the Act, 

alleging that the Commission's dismissal by the Commission of that matter was "contrary to 

law."^ CREW currently seeks a court order declaring that the Commission's dismissal of 

MUR 6471 was contrary to law, and requiring the Commission to conform with such 

declaration,® which, if granted, would allow the Commission to complete the enforcement 

process. Notwithstanding my disagreement with the content of the Controlling Group SOR, I 

voted, consistent with Commission tradition and practice, to authorize OGC to defend the 

Commission in this suit.'° 

See Controlling Group SOR in MURs 6391 and 6471 by Vice Chairman Matthew S. Petersen and Commissioners 

Caroline C. Hunter and Lee E. Goodman, dated Nov. 6,2015, available at 

http://eqs.fec.gov/eqsdocsMUR/15044381253.pdf. In this matter, where one of the complainants that initiated the 

MUR, CREW, has filed suit in U.S. District Court pursuant to 52 U.S.C. § 30109(a)(8), the Controlling Group is 

required to provide a "statement of their reasons" for voting against OGC's recommendation. See Democratic 

Cong. Campaign Comm. v. E£C,831 F.2d 1131, 1132 (D.C. Cir. 1987); E£Cv. Nat'l Republican Senatorial 

Comm., 966 F. 2d 1471, 1476 (D.C. Cir. 1992) ("[W]hen the Commission deadlocks 3-3 and so dismisses a 

complaint, that complaint, like any other, is judicially reviewable under Section 437g(a)(8).... [T]o make judicial 

review a meaningful exercise, the three Commissioners who voted to dismiss must provide a statement of their 

reasons for so voting. Since those Commissioners constitute a controlling group for purposes of the decision, their 

rationale necessarily states the agency's reasons for acting as it did."); Common Cause v. FEC, 655 F. Supp. 619 

(D.D.C. 1986), rev'd on other grounds, 842 F.2d 436 (D.C. Cir. 1988). On March 3, 2016 Commissioner Goodman 

issued a "Supplemental Statement of Commissioner Lee E. Goodman". In that document. Commissioner Goodman 

expresses dissatisfaction with what he believes were unclear and inconsistent tests or analyses by OGC on the 

political committee status issue. However, as seen from OGC's reports, it is clear that OGC was attempting to cover 

all bases - not just its own view - given the disparity between the Controlling Group and Commissioners Ravel, 

Weintraub and me on what is required to make a finding of RTB on political committee status. In view of the 

unwillingness of the Controlling Group to adhere to the analysis we supported, OGC stated in GCR #3 that "under 

any analysis," the "major purpose" test was clearly satisfied. 

* See CREW v. FEC, Case No. 15-2038 (D.D.C. filed Nov. 23,2015). CREW's district court complaint is available 

at http://www.fec.gov/law/litigation/crewl52038_complaint.pdf. Section 30109(a)(8)(C) states that: "In any 

proceeding under this paragraph the court may declare that the dismissal of the complaint or the failure to act is 

contrary to law, and may direct the Commission to conform with such declaration within 30 days, failing which the 

complainant may bring, in the name of such complainant, a civil action to remedy the violation involved in the 

original complaint" (emphasis added). The complainant in MUR 6391, DCCC, chose not to exercise its statutory 

right to file suit in district court against the Commission under 52 U.S.C. § 30109(a)(8)(C). 

'Id. 

" The following explanatory footnote was included as footnote 1 of the FEC's Answer to the Complaint, dated 

February 12,2016, available at http://www.fec.gov/law/litigation/crew_152038.shtml: 

This litigation is commenced against the Federal Election Commission (Commission) on 

the grounds that the Commission did not approve a recommendation of the Commission's 

Office of General Counsel (OGC) to find "reason to believe" (RTB) that a violation of 

the FECA or of its regulations occurred in this case and that the file was consequently 

closed. 52 U.S.C. § 30109(a)(8) (formerly 2 U.S.C. § 437g(a)(8)). The reason for the 

inaction of the Commission is because there were not four or more Commissioners' votes 

to proceed on the RTB recommendation. Courts have held that, in order to properly 

Page 3 of 18 
MUR 6391 & MUR 6471 (Commission on Hope, Growth & Opportunity) 

Statement of Reasons of Vice Chairman Steven T. Walther 

I am issuing this Statement of Reasons to express why I believe the court should (a) 

declare that the Controlling Group's rationale for not finding RTB is arbitrary and capricious and 

therefore "contrary to law," and (b) "direct the Commission to conform with such declaration."'' 

11. The Controlling Group's Rationale For Not Finding Reason to Believe Is Contrary 

to Law 

The Controlling Group's rationale for not finding reason to believe is contrary to law, and 

the court should rule accordingly, as discussed below. 

The basis of the Controlling Group's refusal to vote to find reason to believe that CHGO may 

have achieved political committee status can be summed up in the following statements in the 

Controlling Group's SOR: 

• "The information available at the time [of OGC's pre-investigation recommendations to 

the Commission on December 27, 2013] did not support a finding of reason to believe 

that CHGO had failed to organize, register, and report as a political committee."'^ 

• "The information learned during this period [OGC's Commission-authorized 

investigation in 2014 and 2015] did not definitively resolve whether there was reason to 

believe CHGO was a political committee and raised novel legal issues that the 

Commission had no briefing or time to decide." 

review the inaction of the Commission, the court must be supplied with a "statement of 

reasons" of those Commissioners who voted against, or abstained from voting for, the 

OGC recommendation, who the court has called the "controlling grOup." See Democratic 

Cong. Campaign Comm. v. FEC, 831 F.2d 1131, 1132 (D.C. Cir. 1987); EEC v. Nat 7 

Republican Senatorial Comm., 966 F. 2d 1471,1476 (D.C. Cir. 1992) ("[Wjhen the 

Commission deadlocks 3-3 and so dismisses a complaint, that complaint, like any other, 

is judicially reviewable under Section [30109(a)(8)] [T]o makejudicial review a 

meaningful exercise, the three Commissioners who voted to dismiss must provjde a 

statement of their reasons for so voting. Since those Commissioners constitute a 

controlling group for purposes of the decision, their rationale necessarily states the 

agency's reasons for acting as it did."); Common Cause v. FEC, 655 F. Supp. 619 

(D.D.C. 1986), rev'd on other grounds, 842 F.2d 436 (D.C. Cir. 1988). The Commission 

has historically voted by a majority vote (pursuant to 52 U.S.C. §§ 30106(c) and 

30107(a)(6) (formerly 2 U.S.C. §§ 437c(c) and 437d(a)(6))) to authorize the OGC's 

appearance on behalf of the Commission in suits commenced pursuant to 52 U.S.C. 

30109(a)(8) (formerly 2 U.S.C. § 437g(a)(8)). Accordingly, the views of the 

Commissioners who voted to pursue enforcement are not defended by the OGC, although 

their statements of reasons are part of the administrative record and available for the 

Court's consideration. Furthermore, the OGC's representational role in this matter does 

not change OGC's recommendation to find RTB or any of the reasons supporting it, 

which are part of the administrative record. 

" See fn. 8, supra {quotingfrom Act). 

Controlling Group SOR at 3 (portion in brackets added for clarification). 

" Controlling Group SOR at 4 (portion in brackets added for clarification). 

Page 4 of 18 
MUR 6391 & MUR 6471 (Commission on Hope, Growth & Opportunity) 

Statement of Reasons of Vice Chairman Steven T. Walther 

The information that was learned during that investigation indicated "that CHGO no 

longer existed and that the statute of limitations effectively foreclosed further 

enforcement efforts ... 

Id. As discussed below, three public documents are attached to this statement to assist the discussion of the 

salient issues: 

Attachment A, which is publicly available at https://assets.documentcloud.org/documents/326131/1024-commisionon-hope-growth-and-opportunity.pdf, is an August 16,2010 letter from the IRS approving CHGO's application for 

tax-exempt status, which also includes (a) CHGO's "Application for Recognition of Exemption Under Section 

501(a)" ("IRS Application"), which was signed by CHGO counsel William B. Canfield ("Canfield") on March 31, 

2010, and (b) CHGO's Articles of Association, which were signed by CHGO's President and Executive Director 

Steve Powell and CHGO counsel Canfield on March 31, 2010. In response to the question on the IRS Application . 

"Has the organization spent or does it plan to spend any money attempting to influence the selection, nomination,, 

election, or appointment of any person to any Federal, stale, or local public office or to an office in a political 

organization?" (emphasis added), CHGO counsel Canfield answered "No." 

Attachment B, which is publicly available at http://www.guidestar.org/FinDocuments//2010/271/920/2010-

271920168-07d71 ldl-90.pdf, (and attached as Exhibit C to CREW's Amended Complaint) is CHGO's tax return 

for 2010 (IRS Form 990). That document, as discussed later, shows that CHGO spent over $4.7 million during the 

2010 calendar year. The tax return was executed by CHGO counsel Canfield on November 14, 2011. In response to 

question "Did the organization engage in direct or indirect political campaign activities on behalf of or in opposition 

to candidates for public office?" (during the 2010 calendar year), CHGO counsel Canfield answered "No." The tax 

return further shows that Canfield received compensation of $50,000 in 2010. 

Attachment C, which is publicly available at http://www.guidestar.org/FinDocuments/2011/271/920/2011-

271920168-08862c6f-9O.pdf, is CHGO's tax return for 2011 (IRS Form 990). That document, as discussed later, 

shows that CHGO paid out $31,000 for compensation, legal and other fees, designates its status as "terminated," and 

states that "no assets are remaining for this entity." The tax return was executed on May 4, 2012 by J. Stephen 

Powell as CHGO's President/Executive Director. This return containing a notice of termination was dated just 

18 days after Michael H. Mihalke (who apparently was responsible for billing and invoicing CHGO's 

advertisements) sent an email to CHGO treasurer James D. Warring and CHGO counsel Canfield expressing 

concerns about possible FEC involvement, suggesting that CHGO be terminated "most quickly" because "[tjhere is 

an outstanding matter at the Federal Elections [sic] Commission and my sense is that we ought to shut it down to 

make things less complicated moving forward." 5ee footnote 33. 

Attachment D is a portion of the subpoena response of Michael H. Mihalke, in which CHGO states, as discussed 

later, that its goal was "[t]o make an impact using express advocacy in targeted Senate races on key issues including 

financial reform, energy, taxes, pharmaceuticals, health care and other key concerns," and identifies certain states as 

"potential targets." 

These documents, along with other information discussed in this statement, conclusively show that CHGO was 

active for nine (9) months, from March 31 through December 31,2010, during which it spent over $4 million on 

express advocacy expenditures and electioneering communications. These uncontroverted facts demonstrate a clear 

electoral purpose and stand in stark contrast to Mr. Canfield's statement in CHGO's 2010 IRS Application that 

CHGO had not spent, and did not plan to spend, "any money" to influence elections. 

As to the issue of CHGO's assets, a filing with the IRS is only that, and investigations often show that such filings 

are not always accurate; further, if CHGO had filed with the Commission as a political committee, those filings 

could have revealed with much more certainty the extent of CHGO's receipts and final disbursements, and to what 

extent any assets may still exist. 

Pages of 18 
MUR 6391 & MUR 6471 (Commission on Hope, Growth & Opportunity) 

Statement of Reasons of Vice Chairman Steven T. Walther 

Not only was there sufficient Information supporting reason to believe findings when 

OGC presented its initial recommendations to the Commission on December 27,2()13, the 

investigation conducted by OGC during 2014 and 2015 confirmed that information and 

uncovered overwhelming additional facts (discussed by OGC in subsequent reports) which, 

considered together, demonstrated that there was reason to believe CHGO is a political 

committee under the Act. 

A. First General Counsel's Report (December 27,2013) 

On December 27, 2013, OGC submitted its First General Counsel Report ("GCR #1") to 

the Commission for its consideration; however, consideration was delayed and it was not 

discussed in executive session until July 22, 2014, and ultimately not voted on in executive 

session until September 16,2014.'^ GCR #1 recommended that the Commission find reason to 

believe CHGO may have violated the Act (a) by failing to properly report its independent 

expenditures and electioneering communications, and (b) by failing to include proper disclaimers 

on its advertisements.'® In addition, GCR #I recommended that the Commission find reason to 

believe CHGO may have violated the Act (a) by failing to organize and register as a "political 

committee," and as a consequence, additionally, (b) by failing to file with the FEC the disclosure 

reports required of a political committee.'^ I approved OGC's recommendations shortly after 

GCR #1 was submitted to the Commission; however, the matter was not placed on an executive 

session and discussed until several months later, on July 22, 2014, and was not voted on by the 

Commission until September 16, 2014. 

OGC based its political committee status recommendations on a wealth of undisputed 

evidence that did not persuade the Controlling Group. Because the Commission had not yet 

authorized OGC to conduct an investigation, which procedurally can only happen after a finding 

of RTB, the Commission was limited to the information in the two original complaints and one 

amended complaint and on the specificity of the denials in CHGO's responses, along with 

certain publicly available information. Still, even with those limitations, the facts as disclosed in 

GCR #1 in support of OGC's recommendations were compelling: 

• CHGO's Form 990 for 2010 filed with the Internal Revenue Service ("IRS") {see 

Attachment B), which was provided in CREW's amended complaint, showed that CHGO 

spent over $4.5 million on "media placement" and "media production" during the 2010 

calendar year, out of total spending of over $4.7 million. 

" OCR #I is available at http;//eqs.fec.gov/eqsdocsMUR/l5044380072.pdf. 

See 52 U.S.C. § 30104(c) ("Statements by other than political committees"), 52 U.S.C. § 30104(0 ("Disclosure of 

electioneering communications") and 52 U.S.C. § 30120(a)(3) and (d)(2) ("Identification of funding and authorizing 

sources" and "Communications by others"). 

Specifically, GCR #1 recommended that the Commission find reason to believe that CHGO failed to organize, 

register, and report as a political committee as required, respectively, by 52 U.S.C. § 30102 ("Organization of 

political committees"), 52 U.S.C. § 30103 ("Registration of political committees") and 52 U.S.C. § 30104 

("Reporting requirements"). 

Page 6 of 18 
MUR 6391 & MUR 6471 (Commission on Hope, Growth & Opportunity) 

Statement of Reasons of Vice Chairman Steven T. Waither 

• Although exact figures were unavailable at the time, based only on the advertisements 

identified in the complaints and responses, it appeared that there was reason to believe 

that CHGO may have spent over $1.7 million on television advertisements that contained 

express advocacy alone (not including the additional amount that it appears that CHGO 

spent on electioneering communications). 

• The information suggested (a) that CHGO spent over $530,000 on non-express advocacy 

advertisements that clearly supported or opposed a clearly identified candidate, and 

(b) that the advertisements were run in the respective candidates' districts within 

approximately six weeks of the 2010 general election. 

Because the available facts established - and remain uncontroverted to this date - that 

over $2.2 million was spent on advertisements identified in both complaints and one amended 

complaint ($1.7 million of express advocacy and $530,000 in non-express advocacy 

communications); and since, in light ofCHGO's overall spending of $4.77 million in 2010 and 

the fact that its IRS disclosures revealed over $4.5 million on "media placement" and "media 

production," OGC concluded that there was reason to believe that CHGO's "major purpose" may 

have been conducting federal campaign activity.'® Indeed, given that there was no other 

information about how CHGO spent the $4.5 million, it was reasonable to infer at the time that 

far more than $2.2 million was spent on the advertisements at issue. 

As to whether CHGO's spending on the identified advertisements comprised a majority 

of its spending, in my view - which view is consistent with the Commission's policy as 

enunciated in its 2007 Supplemental Explanation and Justification on Political Committee Status 

("2007 E&J")'® - the facts clearly supported an initial finding that there was reason to believe 

that CHGO may have achieved political committee status. From the outset it has been the 

Commission's interpretation of the law that a majority of express advocacy communications is 

not required in order to find RTB that an organization's major purpose is the nomination or 

election of federal candidates; in fact, the Commission stated in the 2007 E&J - which is still in 

effect - that it would evaluate "[ejach organization's full range of campaign activities."^" As 

OGC stated in GCR #1: 

" The Act and Commission regulations define a "political committee" as "any committee, club, association or other 

group of persons which receives contributions aggregating in excess of $1,000 during a calendar year or which 

makes expenditures aggregating in excess of $1,000 during a calendar year." 52 U.S.C. § 30I01(4)(A); 11 C.F.R. 

§ 100.5. In Buckley v. Valeo, 424 U.S. I (1976), the Supreme Court ruled that defining political committee status 

"only in terms of the annual amount of 'contributions' and 'expenditures'" may be overbroad, as it would reach 

groups "engaged purely in issue discussion." Id. at 79. The Court therefore concluded that the term "political 

committee" "need only encompass organizations that are under the control of a candidate or the major purpose of 

which is the nomination or election of a candidate." Id (emphasis added). Accordingly, under the relevant 

provisions of the Act as construed by the Supreme Court, an organization that is not controlled by a candidate must 

register as a political committee only if (1) it satisfies the $1,000 threshold and (2) it has as its "major purpose" the 

nomination or election of one or more federal candidates. 

" See 2007 Supplemental Explanation and Justification on Political Committee Status, 72 Fed. Reg. 5595 (Feb. 7, 

2007) ("2007 E&J"), available at http;//sers.fec.gov/fosers/showpdf.htm?docid=347892007. 

See 2007 E&J at 5596-97. 

Page 7 of 18 
MUR 6391 & MUR 6471 (Commission on Hope, Growth & Opportunity) 

Statement of Reasons of Vice Chairman Steven T. Walther 

[A]lthough it is unclear at this stage whether the amount CHGO spent on federal 

campaign activity exceeds 50% of its budget, that fact is not dispositive. See 

supra at 25 and note 16; see also Human Life of Washington, Inc. v. Brumsickle, 

624 F.3d 990, 1009 (9th Cir. 2010), cert, denied. 131 S. Ct. 1477 (2011) 

("Nothing in Buckley suggests ... that disclosure requirements are constitutional 

only when applied" to "organizations whose single major purpose was political 

advocacy") (emphasis added). And that consideration is particularly compelling 

here, at the initial stage of the enforcement process, where the Commission would 

seek merely to obtain a full record and would not be finding a violation of the Act 

on the facts before it. See Statement of Policy Regarding Commission Action in 

Matters at the Initial Stage of the Enforcement Process, 72 Fed. Reg. 12,545 

(Mar. 16, 2007) ("[Rjeason to believe findings indicate only that the Commission 

has found sufficient legal justification to open an investigation to determine 

whether a violation of the Act has occurred."). Accordingly, in light of the nature 

of the substantial spending for which the Commission currently has information, 

there is reason to believe that CHGO's major purpose in 2010 was federal 

campaign activity (i.e.. the nomination or election of a federal candidate).^' 

On September 16, 2014, the Commission met in executive session and voted on the 

reason to believe recommendations in GCR #1." The Commissioners unanimously voted to find 

reason to believe that CHGO may have failed to file the required reports disclosing the 

communications identified in the complaints as required by the Act;" however, the political 

committee status recommendations in GCR #1 failed to gamer the necessary four votes. Three 

Commissioners (Commissioners Ann M. Ravel and Ellen L. Weintraub and I) voted to approve 

the political committee status recommendations, while the Controlling Group voted against 

them. The Controlling Group states in its SCR that, among other things, it "was not prepared to 

extrapolate the breakdown of CHGO's total spending ($4.7 milliqn) based on the $2.2 million 

subset of spending alleged in the complaint." ^ 

Despite the Commission's failure to find RTB regarding the central allegation, the 

unanimous approval of an RTB finding regarding CHGO's failure to file the required reports 

disclosing its communications at least provided OGC with the authority to commence an 

" GCR#1 at 38-39. 

The Commission meets regularly in closed session to discuss and vote on pending enforcement actions, litigation 

and other matters that, by law, are kept confidential. See http://www.fec.gOv/agenda/agendas.shtml#executive. 

These are usually referred to as "Executive Sessions." 

" See Certification in MUR 6391 & MUR 6471 (CHGO), dated September 16,2014, available at 

http://eqs.fec.gOv/eqsdocsMUR/lS044380338.pdf. The certification stated that CHGO "violated 52 U.S.C. § 30104 

(formerly 2 U.S.C. § 434) by failing to report the communications at issue in the report." 

Controlling Group SOR at fn. 13. As mentioned elsewhere, more extrapolation by OGC followed, although 1 do 

not think further additional facts or extrapolation were necessary.in order to find RTB on the political committee 

status issue on September 16,2014. 

Page 8 of 18 
8 

MUR 6391 & MUR 6471 (Commission on Hope, Growth & Opportunity) 

Statement of Reasons of Vice Chairman Steven T. Walther 

investigation to obtain additional facts regarding that issue.^^ Assuming OGC could confirm the 

amounts at issue and obtain more information about CHGO's spending - whether that 

information was inculpatory or exculpatory - the Commission would have been well situated to 

make appropriate findings in advance of the impending statute of limitations, which was 

projected by OGC to start expiring in late September 2015. 

Although, as discussed below, OGC compiled additional facts that far surpassed the low 

"reason to believe" threshold and presented uncontroverted facts to the Commission in sufficient 

time to potentially conciliate with CHGO, it was still not enough to convince the Controlling 

Group. 

B. Second General Counsel's Report (July 28, 2015) 

On July 28, 2015, after conducting a limited investigation in accordance with the 

reporting RTB finding previously approved by the Commission, OGC submitted its Second 

General Counsel's Report ("GCR #2") for the Commission's consideration." Although, as 

previously mentioned, the low RTB threshold regarding political committee status, in my 

opinion, had been satisfied several months earlier when OGC made its initial political committee 

status recommendations in GCR #1 circulated December 27, 2013, the subsequent investigation 

confirmed what could already be inferred by the information in GCR #1, i.e., that nearly all of 

CHGO's spending - $4.59 million out of a total of $4.77 million (96 %) as reported on its 2010 

Form 990 filed with the IRS - was related to the advertisements identified in the complaints. 

Although OGC's investigation was confined to the reporting RTB finding (and not the 

political committee status issue), the documents OGC gathered in connection with that RTB 

finding included statements that were highly relevant to CHGO's "major purpose" by shedding 

some light on the group's true goals and objectives:" 

• CHGO stated in a planning document (see Attachment D) that its goal was "[t]o make an 

impact using express advocacy in targeted Senate races on key issues including financial 

reform, energy, taxes, pharmaceuticals, health care and other key concerns.The 

planning document even identified twelve states as "potential targets."" 

" See Amended Certification in MUR 6391 and 6471 (CHGO), dated Sept. 16,2014, available at 

http://eqs.fec.gOv/eqsdocsMUR/15044380338.pdf. 

^ GCR #2 is available at http.7/eqs.fcc.gov/eqsdocsMUR/15044380353.pdf. 

" The Commission stated in its 2007 E&J that, in determining an entity's major purpose, it considers a group's 

"overall conduct," including public statements about its mission, organizational documents, government filings (e.g., 

IRS notices), the proportion of spending related to "federal campaign activity," and the extent to which fundraising 

solicitations indicate that funds raised will be used to support or oppose specific candidates. 2077 E&J at 5597, 

5605. As can be seen, the percentage of express advocacy spending is only one factor of many in considering the 

existence of "major purpose" and nowhere is it hinted that express advocacy must be a majority of a group's total 

spending. 

^ GCR #2 at 12 (emphasis added). 

"Id. 

Page 9 of 18 
MUR 6391 & MUR 6471 (Commission on Hope, Growth & Opportunity) 

Statement of Reasons of Vice Chairman Steven T. Walther 

• A September 15, 2010 letter to a potential donor from Wayne Herman, who was 

identified as a CHGO "consultant" by key witness Michael Mihaike (who was 

responsible for billing and invoicing CHGO's advertisements), described CHGO as "an 

organization which focuses on running independent expenditure campaigns in key 

districts to support the election of Republican candidates," and further assured the donor 

that contributions to CHGO would not be disclosed, thereby hiding the names of donors 

from the electorate.^" 

In its follow-up investigation, OGC obtained no documents that supported CHGO's claim 

in its response to the complaints that its purpose was solely to educate the public on matters of 

economic policy formulation. 

I 

It is worth noting that OGC encountered a number of obstacles in the post-RTB period j 

that severely hampered its investigation of CHGO, caused in no small part by CHGO's failure to 

abide by the law (as well as its failure to adhere to timely notices provided to it by OGC that 

cautioned CHGO's counsel to follow the law) to preserve records related to the complaints as 

required by law. These legal requirements were included in complaint notification letters from 

the Commission as early as 2010.'' OGC provided the following disturbing information in its 

July 28, 2015 report to the Commission: 

The investigative record suggests that CHGO lacked a records retention policy, 

did not appear to otherwise attempt to retain records, and did not direct any of its 

vendors to retain records, despite notice from the Commission of the obligation to 

preserve relevant documents. None of the witnesses identified any records 

retention policy in place at CHGO or Meridian [its primary vendor for media 

placement and production] during the time CHGO conducted the activities at 

issue. Canfield [i.e., CHGO counsel William B. Canfield III] Subpoena Resp. 

at 2; Powell [i.e., CHGO President/Executive Director James S. Powell] 

Subpoena Resp. at 6; Response of Michael H. Mihaike to Order to Submit 

Answers to Questions and Subpoena to Produce Documents at 5 (June 26, 2015) 

("Mihaike Subpoena Resp."). Additionally, all of the relevant witnesses stated 

that they either did not receive notice or did not recall receiving notice to retain 

records relating to CHGO in light of the Commission's open matter. Response of 

James D. Warring [i.e., CHGO treasurer and founder of Warring & Company, 

LLC, the firm responsible for CHGO's accounting and tax filings] to Order to 

Submit Answers to Questions and Subpoena to Produce Docuihents at 8 (June 29, 

2015) ("Warring Subpoena Resp."); Powell Subpoena Resp. at 6; Mihaike 

" The Commission's complaint notification letters to counsel stated: 

Please note that you have a legal obligation to preserve all documents, records and materials relating to the 

subject matter of the complaint until such time as you are notified that the Commission has closed its file in 

this matter. See 18 U.S.C. § 1519. 

Page 10 of 18 
MUR 6391 & MUR 6471 (Commission on Hope, Growth & Opportunity) 

Statement of Reasons of Vice Chairman Steven T. Walther 

Subpoena Resp. at 5. To the contrary, in response to the subpoenas Warring and 

Cedillo [i.e., Susi Cedillo, employee of Warring & Company, LLC] produced an 

April 16, 2012 e-mail from Mihalke to Warring and Canfield suggesting that 

CHGO be terminated "most quickly," because "[tjhere is an outstanding matter at 

the Federal Elections [sic] Commission and my sense is that we ought to shut it 

down to make things less complicated moving forward." Warring Subpoena 

Resp. at FEC-481; Response of Susi Cedillo to Order to Submit Answers to 

Questions and Subpoena to Produce Documents (July 6, 2015) ("Cedillo 

Subpoena Resp.") at FEC-219." 

In spite of these fact-finding challenges, OGC was successful in presenting the 

Commission with much stronger factual support that there was reason to believe that CHGO is a 

political committee. Accordingly, GCR #2 renewed OGC's previous recommendations, stating 

that 

"since each of CHGO's advertisements was either an express-advocacy 

4 independent expenditure or electioneering communication, both of which 

% are indicative of major purpose, we conclude that 96% of CHGO's 

spending in 2010 involved federal campaign activity."^^ 

GCR #2 also recommended that the Commission immediately authorize pre-probable 

conciliation with CHGO, given that the statute of limitations was to begin expiring in two 

months. 

However, notwithstanding the foregoing, the Controlling Group contended OGC still had 

not obtained enough evidence to satisfy their arbitrary threshold for political committee status by 

definitively categorizing which disbursements were for express advocacy independent 

expenditures versus non-express advocacy electioneering communications. As the Controlling 

Group stated in its SOR: 

It was ... our expectation that OGC's investigation would provide a more 

thorough accounting of CHGO's spending, including its spending on each 

communication, and whether there were other communications not known to the 

Commission that CHGO had financed.^^ 

However, the investigation had not developed any more information detailing 

CHGO's spending on specific communications.^ 

" GCR #2 at fn. 20 (portion in brackets added for clarification). This is perhaps the reason why the IRS termination 

was filed as well, which unfortunately was used by the Controlling Group as a reason to not vote for RTB findings 

on the political committee status issue. 

" GCR #2 at 10. 

" Controlling Group SOR at 3. 

" Controlling Group SOR at 3-4. 

Page II of 18 
MUR 6391 & MUR 6471 (Commission on Hope, Growth & Opportunity) 

Statement of Reasons of Vice Chairman Steven T. Walther 

In each instance where the Controlling Group criticized the sufficiency of the evidence, 

OGC conducted fiirther investigation in an attempt to satisfy their concerns. Although not 

necessary, in an effort to obtain yet more precise details about CHGO's spending on the 

advertisements at issue, OGC undertook additional investigative steps following an August 11, 

2015 executive session discussion.^® As discussed below, however, although OGC diligently 

pursued other potential leads and returned to the Commission the next month, on September 24, 

2015, with a detailed breakdown of CHGO's spending, the additional copious evidence did not 

persuade the Controlling Group that the low reason to believe standard had been satisfied. 

C. Third General Counsel's Report (September 24, 2015) 

On September 24, 2015, OGC submitted its Third General Counsel's Report ("GCR #3") 

for Commission consideration.^' OGC described the investigative efforts it had undertaken since 

the August 11 executive session, such as seeking political files from 144 television stations in 

broadcast areas utilized by CHGO, and obtaining documents from and interviewing 

representatives of previously unknown CHGO subvendors. Based on these new leads and other 

investigatory steps, OGC was able to provide the Commissioners with an even more 

comprehensive and detailed breakdown of CHGO's spending. 

In GCR #3, OGC focused primarily on the portion of CHGO's spending that comprised 

express advocacy communications, stating that: 

Though the Commission has not limited its consideration to spending on express 

advocacy communications when determining whether a group's spending 

indicates a major purpose of federal campaign activity, CHGO qualifies as a 

political committee even if the Commission were to consider the entity's spending 

on independent expenditures alone. As explained [on page 14 of GCR #3], 

CHGO spent $2,933,631.34 on the production and placement of express advocacy 

advertisements. Using only this amount, it appears that CHGO's express 

advocacy spending amounted to 61% of its confirmed total of $4,801,000 that it 

spent over the entire course of its organizational lifetime.^® 

OGC also calculated that CHGO's combined spending on express advocacy and 

electioneering communications amounted to 85% of its total spending in 2010," but since the 

Controlling Group - in departure of formal Commission policy as enunciated in its 2007 E&J -

had historically refused to include electioneering communication disbursements in assessing a 

I supported a short delay during this period in order to permit OGC to pursue additional leads in its investigation. 

" GCR #3 is available at http://eqs.fec.gov/eqsdocsMUR/15044381224.pdf. 

GCR #3 at 18-19 (emphasis added, footnotes omitted, portion in brackets added). OGC explained in a footnote 

that, to establish that CHGO's major purpose was to influence federal elections "under any analysis" of the test, it 

used the $4,801,000 that CHGO spent during 2010 and 2011, the duration of the group's spending history, instead of 

the $4.77 million it spent only in 2010. GCR #3 at fh. 2. OGC notes that "[t]he minimal spending undertaken in 

2011 does not materially change the proportion of CHGO's spending on independent expenditures." Id. 

"5eeGCR #3 at 18. 

Page 12 of 18 
MUR 6391 & MUR 6471 (Commission on Hope, Growth & Opportunity) 

Statement of Reasons of Vice Chairman Steven T. Walther 

group's major purpose,this higher figure was of little practical significance in terms of 

attracting the necessary four votes for finding reason to believe. 

On September 29, 2015, just five days after OGC submitted OCR #3 to the Commission, 

OGC provided the Commission with a memorandum accompanied by a detailed spreadsheet 

containing all available cost information and an explanation of the methodology it used to 

allocate production and placement costs. This information was made available to the 

Commissioners at the next executive session considering the matter, which was on October 1, 

2015. Despite this level of additional detail elicited in that short period, and even though the 

uncontroverted facts easily satisfied the reason to believe threshold - which I believe was 

satisfied at the initial stage of the enforcement process through GCR #1 - the Controlling Group 

ultimately rejected OGC's analysis that express advocacy communications constituted 61% of 

CHGO's spending. The Controlling Group simply stated that it was not "persuaded by OGC's 

calculations that 61% of CHGO's spending was devoted to communications that expressly 

advocated the election or defeat of a federal candidate.""' 

The matters came before the Commission on October 1, 2015 for a vote. Commissioners 

Ravel, Weintraub, and I voted to find RTB on the political committee status issue, and the 

Controlling Group voted against, leaving the Commission deadlocked on that issue. Instead of 

relying on alternative spending calculations or a competing analysis of the content of the 

advertisements,"^ the Controlling Group focused on the fact that the statute of limitations was 

fast approaching, the fact that CHGO had filed termination documents with the IRS in 2011, and 

the fact that CHGO "had no money" or "people acting on its behalf.""^ Accordingly, the 

Controlling Group viewed closing the file as the Commission's "most prudent course" and once 

again voted against finding RTB that CHGO violated the Act's political committee provisions, 

leaving the Commission with little choice but to close the file."" 

D. The Failure to Find Reason to Believe Was Contrary to Law 

A court may not disturb the dismissal of a Commission enforcement matter unless that 

dismissal was "contrary to law.""^ Courts have construed this phrase to reflect the standard that 

See, e.g.. Statement of Reasons of Chairman Lee E. Goodman and Commissioners Caroline C. Hutiter and 

Matthew S. Petersen, MUR 6538 (Americans for Job Security), available at 

http://eqs.fec.gov/eqsdocsMUR/1404436l962.pdf; Statement of Reasons of Chairman Lee E. Goodman and 

Commissioners Caroline C. Hunter and Matthew S. Petersen, MUR 6589 (American Action Network), available at 

http;//eqs.fec.gov/eqsdocsMUR/14044362004.pdf. 

Controlling Group SOR at fn. 16. 

Throughout the pendency of this case, the Controlling Group has never challenged OGC's characterization of the 

advertisements, i.e., which ones constitute electioneering communications and which ones were express advocacy 

independent expenditures. 

Controlling Group SOR at 4. 

^ Id. I voted against closing the file. 

See fn. 8, supra (quoting from Act). 

Page 13 of 18 
MUR 6391 & MUR 6471 (Commission on Hope, Growth & Opportunity) 

Statement of Reasons of Vice Chairman Steven T. Walther 

normally governs judicial review of administrative decisions; i.e., a Commission dismissal may 

be overturned only if it was "arbitrary or capricious, or an abuse of discretion," or rests on an 

"impermissible interpretation of the Act.""® Although the "arbitrary and capricious" standard of 

review is a deferential one that presumes an agency's action to be valid, a court is not required 

"to accept 'meekly administrative pronouncements clearly at variance with established facts.'""^ 

As I have expressed in my previous statements of reasons in enforcement matters,"* the 

standard of proof as to whether or not to find reason to believe is very low; if it were otherwise, 

the Commission could open an investigation only on rare occasions. The Commission only has 

civil (i.e., non-criminal) jurisdiction, but the standard for finding reason to believe is lower than 

other standards of proof in civil matters, including "preponderance of the evidence," and "clear 

and convincing evidence." The Commission is merely required to find that there is reason to 

believe a violation may have occurred before moving forward to the next stage of the matter, i.e., 

usually initiating an investigation and/or engaging in conciliation. 

It should be noted that the language was unanimously approved by the Commission in its 

3 publicly available "Guidebook for Complainants and Respondents on the FEC Enforcement 

g Process," which provides formal guidance to complainants and respondents in enforcement 

K matters."' The Commission in 2009 and 2012 voted - unanimously - to provide the following 

g explanation of a reason to believe finding: 

5 

The Act requires that the Commission find "reason to believe that a person has 

committed, or is about to commit, a violation" of the Act as a precondition to opening 

an investigation into the alleged violation. 2 U.S.C. § 437g(a)(2) [now 52 U.S.C. 

§ 30109(a)(2)]. A "reason to believe" finding is not a finding that the respondent violated 

the Act, but instead simply means that the Commission believes a violation may have 

occurred."^° 

As OGC concluded in GCR #3, under any analysis, the Commission should have found 

reason to believe that CHGO may have violated the Act by failing to organize, register, and 

" IM Bolz V. FEC, 889 F.Supp.2d 51, 59-60 (D.D.C. 2012), quoting Hagelin v. FEC, 411 F.3d 237, 242 (D.C. Cir. 

2005). See also Orloski v. FEC, 795 F.2d 156, 161 (D.C. Cir. 1986). 

Antosh V. FEC, 599 F. Supp. 850 (D.D.C. 1984), citing Environmental Defense Fund v. Costle, 657 F.2d 275, 283 

(D.C. Cir.1981). 

See, e.g., MUR 6396 (Crossroads GPS) Supplemental SCR by Commissioner Steven T. Walther, dated Dec. 30, 

2014, available at http://eqs.fec.gov/eqsdocsMUR/14044364941.pdf: MUR 6570 (Berman for Congress, et al.) 

Supplemental SOR by Commissioner Steven T. Walther, dated Jan. 4, 2013, available at 

http;//eqs.fec.gov/eqsdocsMUR/13044324639.pdf. 

See MUR 6396 (Crossroads GPS) Supplemental SOR at 9-10. 

See "Guidebook for Complainants and Respondents on the FEC Enforcement Process" ("Guidebook") at 12 

(emphasis added), available at http://www.fec.gov/em/respondent_guide.pdf. The Guidebook was unanimously 

approved by the Commission on Dec. 17,2009; an updated edition was unanimously approved on May 10,2012. 

See Minutes of FEC Dec. 17,2009 Open Meeting, available at http://www.fec.gov/agenda/2010/mtgdocl002.pdf; 

Minutes of FEC May 10, 2012 Open Meeting, available dt http://www.fec.gov/agenda/2012/mtgdoc_1237.pdf. 

Page 14 of 18 
MUR 6391 & MUR 6471 (Commission on Hope, Growth & Opportunity) 

Statement of Reasons of Vice Chairman Steven T. Walther 

report as a political committee.'' Regarding the examination of CHGO's "major purpose," it 

was arbitrary and capricious - and therefore contrary to law - for the Controlling Group to 

consider and rely upon, for purposes of determining whether to find reason to believe, only an 

organization's spending on express advocacy in relation to its other spending. The Commission 

itself has never limited a major purpose to express advocacy communications; indeed, such a 

narrow focus would effectively eviscerate the statutory test for political committee status, which 

is triggered when a group receives "contributions" or makes "expenditures" aggregating in 

excess of $1,000 during a calendar year - since the Commission has consistently interpreted the 

term "expenditures" to include communications that contain "express advocacy."" The 

Commission's view that the required major purpose test is not limited solely to communications 

that contain express advocacy (or its functional equivalent) has been upheld by every court that 

has reviewed the Commission's case-by-case approach in its 2007 E&J." 

OGC went far beyond the call of duty in this case (and what is legally required) by 

ultimately determining, as part of its investigation of the apparent reporting violation (for which 

the Controlling Group voted along with the three other Commissioners to authorize an 

investigation), the precise level of express advocacy spending in proportion to CHGO's total 

spending. OGC calculated in GCR #3 that CHGO's express advocacy spending amounted to a 

staggering 61% of its $4.8 million in total spending. 

4 The Controlling Group's conclusory dismissal - without explanation - of OGC's express 

advocacy spending calculation easily meets the "arbitrary and capricious" standard of review. 

Further, it is not a reasonable justification to vote against finding reason to believe by pointing to 

factors such as the statute of limitations and the respondent's financial condition, particularly 

considering that the Controlling Group voted against OGC's reason to believe recommendations 

more than a year earlier. Although time was running short when the Controlling Group voted 

against OGC's political committee status recommendations the second time, it was premature to 

assume - as the Controlling Group appears to have done - that the Commission's enforcement 

options were completely foreclosed. For example, if the court were to reject the Controlling 

" As noted above, OGC stated in GCR #3 that CHGO spent 52,933,631.34 on the production and placement of 

express advocacy advertisements, which amounted to 61% of its confirmed total of 54,801,000 that it spent over the 

entire course of its organizational lifetime. OGC further stated that: 

We have determined that, under any analysis, CHGO's expenditures reflect that express advocacy 

was a major purpose of the group - even when resolving any doubts regarding the purpose of the 

unused funds in favor of CHGO. For instance, if we were to remove from both the express 

advocacy expenditures and the total expenditures calculations of the amounts of the unused 

CHGO funds that, according to Mihalke, Reed distributed to Berman and himself to cover 

fundraising costs, it appears that CHGO's express advocacy spending amounted to 76% of its total 

of 53,864,906 that it spent over the course of its organizational lifetime. 

GCR #3 at 19 (emphasis added). 

" See 52 U.S.C. §§ 30101(4)(A) and (17)(A). 

" See Free Speech v. FEC, 720 F.3d 788,798 (10th Cir. 2013), cert, denied, 134 S.Ct. 2288 (May 19, 2014); Real 

Truth About Abortion. Inc. v. FEC, 681 F.3d 544, 556 (4th Cir. 2012), cert, denied, 133 S.Ct. 841 (2013); Shays v. 

FEC, 511 F. Supp. 2d 19,29-31 (D.D.C. 2007). 

Page 15 of 18 
MUR 6391 & MUR 6471 (Commission on Hope, Growth & Opportunity) 

Statement of Reasons of Vice Chairman Steven T. Walther 

Group's rationale and deem the Commission's dismissal as contrary to law, the Commission 

could then find reason to believe and attempt to conciliate with CHGO through its officers, who 

have been previously identified and contacted by OGC. 

The Controlling Group suggests that further pursuit of CHGO would be an exercise in 

futility, but since the Commission deadlocked on whether to take appropriate enforcement action 

(which would include a formal investigation) on CHGO's political committee status, there is no 

way of knowing the outcome. While a respondent's financial condition or legal status has never 

served as a bar to Commission enforcement,the Commission may consider such factors and 

exercise appropriate flexibility during conciliation negotiations. In fact, in 2014, the Controlling 

Group voted to accept a negotiated settlement with a dissolved non-profit corporation that failed 

to report its electioneering communications, even though that corporation's resources were 

severely limited.The non-profit corporation ultimately agreed to pay a small penalty, admit to 

the violations, and to file all of its required electioneering communication reports.^^ 

Even if CHGO paid no civil penalty, it may have been possible, for example, to obtain a 

settlement that would have required it to register with the Commission and file all applicable 

reports.^' That information would be disclosed too late to have any impact on the 2010 elections 

^ On December 27,2013, OGC submined GCR #I to the Commission, which included a link to CHGO's 2011 

Form 990 in fn. 7. Footnote 7 of GCR #1 states as follows: 

It does not appear that CHGO conducted activities after 2010, as its 2011 tax return reported only 

$31,000 in expenditures for website maintenance, accounting and legal fees, and compensation to its 

President and Executive Director. Form 990- Return of Organization Exempt from Income Tax (May 

4, 2012), available at http://www.guidestar.org/FinDocuments/201 1/271/920/20 11-27 1 920168-

08862c6f-90.pdf. 

Although that form listed CHGO's status as "terminated" and stated that CHGO had no remaining assets, there is no 

way of knowing whether the financial contentions set forth in that form were accurate. Also, the information the 

Controlling Group belatedly relied upon was the termination statement in CHGO's 2011 Form 990, but that 

information was made part of the record by OGC on December 27, 2013, as noted. In the intervening time, the 

Controlling Group voted to find RTB against CHGO (on September 16,2014) even though CHGO was ostensibly 

terminated and had no money, according to its 2011 IRS form (see Attachment C). If termination was a valid factor 

- and it was not - it would have been just as valid at the time the Controlling Group voted to find RTB. 

" MUR 6413 (Taxpayer Network), file available at http://eqs.fec.gov/eqs/searcheqs?SUBMIT=summary&key=2. 

^ In MUR 6413 (Taxpayer Network), the final settlement agreement included the following language: 

In ordinary circumstances, the Commission would seek a substantially higher civil penalty based on the 

violations outlined in this agreement. However, the Commission is taking into account the &ct that 

Taxpayer Network is a dissolved corporation that represents that it has limited funds and no ability to raise 

additional funds. Respondent will pay a civil penalty to the Commission in the amount of $5,000, pursuant 

to 2 U.S.C. § 437g(a)(5)(A). 

See Conciliation Agreement in MUR 6413 (Taxpayer Network), dated May 16, 2014, available at 

http://eqs.fec.gov/eqsdocsMUR/14044353947.pdf. 

" Although the federal statute of limitations provision at 28 U.S.C. § 2462 may affect the Commission's ability to 

obtain civil penalties, it does not foreclose the Commission from seeking equitable relief: 

Page 16 of 18 
MUR 6391 & MUR 6471 (Commission on Hope, Growth & Opportunity) 

•Statement of Reasons of Vice Chairman Steven T. Walther 

that CHGO sought to influence; however, such disclosure would at least provide a complete 

public record of CHGO's spending and its sources of financial support. Ultimately, if CHGO 

failed to file the required reports, the Commission could seek relief in federal court, regardless of 

the statute of limitations.^* Approving a finding on political committee status would demonstrate 

that the reason to believe standard concerning this important issue has not been eviscerated and 

could serve as important public guidance on this issue. 

III. CONCLUSION 

What separates this case from a typical political committee case is that CHGO has never 

publicly disclosed any of its spending to the Commission at any time and has never publicly 

disclosed any information about the sources of its funding, thereby frustrating the public's right 

to know about the group's spending and funding in connection with federal elections. 

In this case, assuming CHGO's 2010 and 2011 tax returns are accurate (see 

Attachments B and C), CHGO was an entity that was active only during the last (9) months of an 

election year. All of its funds - except for $31,000 listed on its 2011 tax return - were raised and 

spent between March 31, 2010 (the date of its formation) and December 31, 2010 (the last day of 

the 2010 IRS reporting period). Because its only activity appears to have been airing express 

advocacy and electioneering communications in the months leading up the 2010 general election, 

all of its contributions and disbursements of over $4.8 million dollars appear to have been 

directly connected to those advertisements. 

Despite its lofty purposes as provided to the IRS (e.g., that CHGO was "created to 

advance the principle that sustained and expanding growth is central to America's economic 

future and the well-being of all Americans"),^' the uncontroverted facts show that it was created 

solely to influence the outcome of federal elections and had no other purpose. 

OGC went to great lengths to provide information and analysis to cover all of the various 

arguments that had been raised on how to analyze political committee status, even though only 

one was necessary. And OGC concluded by stating in GCR #3 that "under any analysis," it 

would recommend finding RTB that CHGO may have violated the Act. Because OGC was in 

the midst of winding up its investigation regarding CHGO's expenditures, the matter was held 

over twice for short periods with my support; however, in my view, in each instance that the 

matter came before the Commission, and under any analysis, it was appropriate for the 

Except as otherwise provided by Act of Congress, an action, suit or proceeding for the 

enforcement of any civil fine, penalty, or forfeiture, pecuniary or otherwise, shall not be 

entertained unless commenced within five years from the date when the claim first accrued if, 

within the same period, the offender or the property is found within the United States in order that 

proper service may be made thereon. 

See, e.g., U.S. v. Banks, 115 F.3d 916 (11"" Cir. 1997) (statute of limitations cannot bar the government's equitable 

clams under 28 U.S.C. § 2462 when the government is acting in its official enforcement capacity). 

" See Attachment A. 

Page 17 of 18 
MUR 6391 & MUR 6471 (Commission on Hope, Growth & Opportunity) 

Statement of Reasons of Vice Chairman Steven T. Walther 

Commission to find RTB. The evidence was ultimately conclusive that no other finding was 

reasonable. 

Once CHGO learned that it was the subject of multiple PEG complaints, it quickly 

(within 18 days) filed its termination report with the IRS. If CHGO's termination report 

effectively allowed it to dissolve itself and drain its remaining cash assets, this method may 

become a preferred strategy for any fly-by-night group that - although in existence for a very 

short period - may exert a large influence on the political process without registering as a 

political committee with the Commission. 

If the court does not find the Commission's failure to find RTB in this matter to be 

contrary to law, it will be very difficult, I fear, for the EEC to ever be able to effectively enforce 

issues on finding political committee status - and the reporting value - the right of the voter to be 

informed - will not be vindicated. 

The uncontroverted facts of this matter compel a finding of reason to believe that FECA 

violations may have occurred in connection with CHGO's alleged political committee status, and 

any vote against the recommendations was not rationally based, and thus contrary to law. 

Accordingly, I believe the court should reject the rationale of the Controlling Group SCR as 

arbitrary and capricious, and therefore contrary to law; if the court agrees, it should remand this 

matter to the Commission for appropriate proceedings. 

For the foregoing reasons, I voted twice to approve the General Counsel's 

recommendations to find reason to believe that CHGO may have violated the Act by failing to 

organize, register, and report as a political committee as required by the Act. 

Date Steven T. Walther 

Vice Chairman 

Page 18 of 18 
ATTACHMENT A 

k 

I August 16, 2010 Letter from IRS Approving 

I CHGO's Application for Tax-Exempt Status 

I 
INTERNAL REVENUE SERVICE 

P. 0. BOX 2508 

CINCINNATI, OH 45201 

DEPARTMENT OF THE TREASURY 

Date: AUG 16 2010 

COMMISSION ON HOPE GROWTH AND 

OPPORTUNITY 

1900 M ST NW STE 600 

WASHINGTON, DC 20036 

Employer Identification Number: 

27-1920168 

DLN: 

17053203318020 

Contact Person: 

ROGER W VANCE ID# 31173 

Contact Telephone Number: 

(877) 829-5500 

Accounting Period Ending: 

December 31 

Form 990 Required: 

Yes 

Effective Date of Exemption: 

March 31, 2010 

Contribution Deductibility: 

No 

Dear Applicant: 

We are pleased to inform you that upon review of your application for taxexempt status we have determined that you are exempt from Federal income tax 

under section 501(c)(4) of the Internal Revenue Code. Because this letter 

could help resolve any questions regarding your exempt status, you should )ceep 

it in your permanent records. 

Please see enclosed Publication 4221-NC, Compliance Guide for Tax-Exempt 

Organizations (Other than 501(c)(3) Public Charities and Private Foundations), 

for some helpful information about your responsibilities as an exempt 

organization. 

Contributions to you are not deductible by donors under section 170(c) (2) of 

the Code. 

Sincerely, 

Robert Choi 

Director; Exempt Organizations 

Rulings and Agreements 

Enclosure: Publication 4221-NC 

Letter 948 (DO/CG) 

Attachment A 
»• 

.0,TM 1024 

(Rev. SeplefPber 1^998) 

Oepanmeni ol the Tieasuiy 

Inienul Revenue Secvice 

17058203318020 

Application for Recognition of Exemption 

Under Section 501(a) 

OMB No. 1S45-00S7 

II emnei ititgi H ipprawd, 

MsappgcaeanuiOlbeepen 

forpiitliclmpeeUea 

Read the instructions for each Part carefully. A User Fee must be attached to this application. 

If the required information and appropriate documents are not submitted along with Form 8718 (with payment 

of the appropriate user fee), the application may be returned to the organization. 

Complete the Procedural Checklist on page 6 of the instructions. 

Part I. Identification of Applicant (Must be completed by all applicants: also complete appropriate schedule.) 

Submit only the schedule that applies to your organization. Do not submit blank schedules. 

Check (he appropriate box below to indicate the section under which the organization is applying: 

a • Section 50i(cl(a:-Title holding.corpo«Uons (Seliedule A..Rage'7) 

b El section sot (cl(4)—Civic leagues, social vveirare organizations (including certain wa'r veterans' organlzatiohs). or locai associations ol 

employees (Schedule B. page 8) 

• Section SOilcKSji-ubor. agticuiujrai. or hortittuiiuiai organizations (Schedule C; page 9) 

• Seciloh 5bl(c)(6)^8usiness leagues, chamtzers of commerce, etc. (Schedule C, page 9) 

• S.ec8oin s6l(oi7)T-Social-ciubs'(Schedule b. pa^ >1) 

• Section, SOl(El(B)r-Fra.iemal benefTciaiy societliss, .etc.. pnwitirng rife. iitk. ectident'or-other benefits to members (Schedule E. page 13) 

g. • Section 501(0(9)—Voluntary employees' baneficiaiy asspe'ietiofis (Parts f throtrgh IV and Schedule F. page 14) 

h • Section 50i(c)(l0)i^pomestic iraiehiai spcieifos. .Orders, elc.. nol provldrng Ufo. sick, accidcht, or other tienents (Schedule E. page 13) 

I • Section 501(c)(1Z)-Benevoleni life insurance associstFons. mutual ditch of hrlgalion companies, mutual or cooperative telephone 

companies, or like organizations (Schedule G. page 15) 

J • Section 501(0(13)—CenieierleS. crematoria, odd (ilie corporations (Schedofe H. page 16) 

k • section 501 (0(1 S]-MUtuai Insurance companies or astmiations, other than life or maririe (Schedule I: page.i?) 

I • Sedion ^l(0(i7)-Trusts pnividlng for the payment of supptiiiiiini'ai uiiernploymant.aitniiensation bendits (Paris I through IV and ^hedule J. page 18) 

m • Section 56l(c)n9)-A post, organiistion, aunllary unit, ctu ot pau or present meniMis (if the Armed Forces of the llnited States (Schedule K. page 19) 

la Full name of organization (as shown in organizing document) 

Commission on Hope, Growth and Opportunity 

2 Employer identification number (EIN) (il 

none, see Specific instructions on page 2) 

27; 1920168 

1 b c/o Name (if applicable) 3 Name and telephone number of person to be 

contacted if additional information is needed 

Wiiiiam B. Canfleid 

( 202 ) 589-2651 

1c Address (number and street) 

1900 M street, N.W. 

Room/Suite 600 

Suite too 

3 Name and telephone number of person to be 

contacted if additional information is needed 

Wiiiiam B. Canfleid 

( 202 ) 589-2651 

Id City, town or post office, state, and ZIP'« 4 If you have a foreign address, see Specific 

Instructions lor Part 1. page 2. 

Washington, D.C. 20036 

3 Name and telephone number of person to be 

contacted if additional information is needed 

Wiiiiam B. Canfleid 

( 202 ) 589-2651 

1e Web site address 

N/A 

4 Month the annual accounting period ends 

December 

S Date Incorporated or formed 

March 31.2010 

EI'VEO 

Did the organization previously apply for recognition of exemption under this Code section or uniler any other section or the Code? • Yes (Zl No 

if "Ves.' attach an explanation. 

Has the organization tiled Federal income tax returns or exempt organization information returns? • Yes (9 No 

if "Yes." state the form numbers, years filed, and internal Revenue office where filed. 

Check the box for the type of organization. ATTACH A CONFORMED COPY OF THE CORRESPONDING 6RGANK|NG OOCUMENTS/m, 

THE APPLICATION BEFORE MAILING. " ' 

D Corporation— Attach a copy ol the Articles of incorporation (including amendments and restatemaiils) ^twipg approval by the 

appropriate state official: also attach a copy of the bylaws. i'lQ /Jill , 

• Trust— Attach a copy of the Trust indenture or AgreemenL including all appropriate signatures and dates. * 10 

El Association— Attach a copy of the Articles of Assodatioa Constitution, or other creating documem.. with a dedaratiorj^e instructions) or 

other evidence that the organization was formed by adoption of the document more (hen one pefSQAvS^l^iile a copy 

o( the bylaws. =•^''£(7 

II this is a corporation or an unincorporated association that has nol yet adopted bylaws, check here » • 

PLEASE 

SIGN 

HERE • 

I declare under the penalties of perjury that I em authrxized to sign this applicaiim on behalf of the above organization, and that I have axa'r 

this application, including the accompanying schedules and attachments, and to the best of my knowladga it is true, conect. and complate. 

.Cac.leld 

(Signatura) (Type or print name and title or authority of slgnci) 

For Paperwork Reduction Act Notice, see page 9 of the instructions. 

171520102O3001 

Cat. No. 12343K 

Attachment A 
Form 1024 (Rev. 9-98) Page 2 

i 

8 

0 

Part II. Activities and Operational Information (Must be completed by all applicants) 

1 Provide a detailed narrative description of all the activities of the organization—past, present, and planned. Do not merely refer to or 

repeat the language In the organizational document. Ust each activity separately in the order of importance based on the relative time and 

other resources devoted to the activity. Indicate the percentage of time for each activity. Each description should include, as a minimum, 

the following: (a) a detailed description of the activity including its purpose and how each activity furthers your exempt purpose: (b) when 

the activity was or will be initiated; and (c) where and by whom the activity will be conducted. 

The Commission on Hope, Growth and Opportunity (the "Commission') is a pubiic weifare organization created to 

advance the principie that sustained and expanding economic growth is central to America's economic future and 

the well-being of aii Americans. The Commission believes and intends to inform the American pubiic that economic 

expansion is necessary to America's economic future and that public policy makers must understand and make a 

commitment to this principle. The Commission will engage economists and other business experts to Inform its 

understanding of the necessity for sustained economic growth and will bring the fruits of this expertise and research 

directiy to the attention of decision makers at aii levels of government The Commission will communicate its pubiic 

welfare message on the issue of sustained economic expansion to the public through aii forms of mass 

communication, Including, but not limited to, print advertising, cable television and radio messaging, as weii as 

e-mail and direct mall communications. The Commission will share Its research and findings with public policy 

formuiators and will encourage its supporters to communicate their views on the issues of consequence to the 

Commission directiy with policy makers at aii levels of govemment. The Commission will seek the commitment of 

these policy makers to implement statutes, rules and regulations that are consistent with free-market principles and 

that adhere to economic growth and expansion. 

List ifie organization's present and future sources of financial support, beginning with the largest source first. 

Once operational, the Commission will seek voluntary donations from those American citizens, business entities and 

labor organizations that support the Commission's commitment to the sustained growth of the American economy. 

Aii such donations will be utilized by the Commission to communicate with the pubiic and policy makers and to 

r r^ Circh the economic consequences of sustained economic growth in the formulation of public policy. 

Attachment A 
Form 1024 (Rev. 9-98) Page 3 

Part II. Activities and Operationai Information (continued) 

3 Give the (ollowing inrormalion about the organization's governing body: 

a . Names, addresses, and titles of officers, directors, trustees, etc. b AnrruSi 

Steven Powell (President/Executive Director) 1310 Morning Glory Place, Vista, CA 92084 

James Warring, CPA (Treasurer- Non Voting)) #300,16S28 Emoiy Lane, Rockvllle, MD 208^ 

William B. Canfleld (General Counsel) #500,1900 M Street NW, Washington, DC 20036 

None 

None 

None 

If the organization is the outgrowth or continuation of any form of predecessor, state the name of each predecessor, the period during 

which it was in existence, and the reasons for its termination. Submit copies of ail papers by which any transfer of assets was effected. 

N/A 

If the applicant organization is now. or plans to be. connected in any way with any other organization, describe the other organization and 

explain the relationship (e.g.. financial support on a continuing basis: shared facilities or employees; same officers, directors, or trustees). 

N/A 

If the organization has capitai stock issued and outstanding, state: (1) class or classes of the stock; (Q number and par value of the 

shares; G) cortsideration for which they were issued; and (4) if any dividends have been paid or whether your organization's creating instrument authorizes dividend payments on any class of capital stock. 

N/A 

State the qualifications necessary for membership in the organization; the classes of membership (ivith the number of members in each 

class); and the voting rights and priviieges received. If any group or class of persons is required to joia describe the requirement and 

explain the relationship between those members and members who Join voluntarily. Submit copies of any membership solicitation material. 

Attach sample copies of all types of membership cenificates issued. 

None 

Explain how your organization's assets will be distributed on dissolution. 

Upon dissolution, any assets remaining to the organization will either be refunded, pro-rata, to donors or will be 

donated to a tax-exempt charitable entity recognized by the Internal Revenue Service. 

Attachment A 
Form 1024 (Rev. 9-98) Page 4 

Part II. Activities and Operational information (continued) 

9 Has ihe organizalion made or does il plan to make any disliibution of its property or surplus funds to shareholders or 

members? D Yes 0 No 

II 'Yes.' state the lull details, including: (1) amounts or value: (2) source of funds or property distributed or to be 

distributed: and (3) basis of. and authority for. distribution or planned distribution. 

10 Does, or wDI. any part of your organization s receipts represent payments for services performed or to be performed?. D Yes 0 No 

If "Yes." state in detail the amount received and the character of the services performed or to be performed. 

% 

4 

1 

6 

2 

11 Has the organization made, or does it plan to make, any payments to members or shareholders fa services perfonned 

or to be performed? D Yes 0 No 

If "Yes." state in detail the amount paid, the character of the services, and to whom the payments have been, or will 

be. made. 

12 Does the organization have any arrangement to provide insurance for members, their dependents, or others Qncluding 

provisions for the payment of sick or death beneflts. pensions, or annuities)? Q Yes 0 No 

If 'Yes.' describe and explain the arrangement's eligibility rules and attach a sample copy of each plan document and 

each type of policy issued. 

13 Is the aganization under the supervisory jurisdiction of any public regulatay body, such as a social welfare agency. 

etc.? • Yes 0 No 

If 'Yes,' submit copies of all administrative opinions or court decisions regarding this supervision, as well as copies of 

applications or requests fw the opinions w decisions. • 

14 Does the organization now lease or does it plan to lease any property? Q Yes 0 No 

If 'Yes.' explairi in detail. Include the amount of rent, a description of the propeny. and any relationship between the 

applicant organization and the other party. Also, attach a copy of any rental a lease agreement. (If the organization is 

a party, as a lessor, to multiple leases of rental real propeny under similar lease agreements, please attach a single 

representative copy of the leases.) 

1S Has the organization spent a does it plan to spend any money attempting to Influence the selection, nomination, election. 

or appointment of any person to any Federal, state, or local public office or to an office in a political organization?. . Q Yes 0 No 

If 'Yes.' explain In detail and list the amounts spent or to be spent in each case. 

16 Does the aganization publish pamphlets, brochures, newsleners. journals, a similar printed material? 

If 'Yes.' attach a recent copy of each. 

• Yes • No 

Attachment A 
Foim 1024 (Rev. 9-98) PapB 5 

4 

Part III. Financial Data (Must be completed by all applicants) 

Complete lite rmancial statements for the current year and for each of the 3 years immediately before it. if in eaistence less than 4 years, complete the 

statements for each year in existence. If in existence less than 1 year, also provide proposed budgets for the 2 years folknring the current year. 

A. Statement of Revenue and Expenses 

Revenue 

1 Gross dues and assessments d members . . 

2 Gross contributions, gifts, etc 

(a) Current Tax Year 3 Prior Tax Years or Proposed Budget for Next 2 Years 

(e) Total 

Revenue 

1 Gross dues and assessments d members . . 

2 Gross contributions, gifts, etc 

3/31/10 

(b) ....201.1..... (c).....2.qi.2.... (d) (e) Total 

Revenue 

1 Gross dues and assessments d members . . 

2 Gross contributions, gifts, etc 

To 12/31/10 (b) ....201.1..... (c).....2.qi.2.... (d) (e) Total 

Revenue 

1 Gross dues and assessments d members . . 

2 Gross contributions, gifts, etc 

0 0 0 0 

Revenue 

1 Gross dues and assessments d members . . 

2 Gross contributions, gifts, etc 5.000,000 7,500,000 10,000,000 22,500,000 

3 Gross amounts derived from activities reiated to 

the organization's exempt purpose (attach 

scheduie) (Include related cost of sales on line 9.) 

4 Gross amounts from unrelated liusiness activities (anadi schedule) 

5 Gain from sale of assets, excluding inventory items 

(attach schedule) 

0 0 0 0 

3 Gross amounts derived from activities reiated to 

the organization's exempt purpose (attach 

scheduie) (Include related cost of sales on line 9.) 

4 Gross amounts from unrelated liusiness activities (anadi schedule) 

5 Gain from sale of assets, excluding inventory items 

(attach schedule) 

.0 0 0 0 

3 Gross amounts derived from activities reiated to 

the organization's exempt purpose (attach 

scheduie) (Include related cost of sales on line 9.) 

4 Gross amounts from unrelated liusiness activities (anadi schedule) 

5 Gain from sale of assets, excluding inventory items 

(attach schedule) 0 0 0 0 

6 Investment Income (see page 3 of the instructions) 

7 Other revenue (attach schedule) 

6 0 0 0 0 Investment Income (see page 3 of the instructions) 

7 Other revenue (attach schedule) 0 0 0 0 

8 Total revenue (add lines 1 through 7) . . . . 

Expenses 

9' Expenses attributable to activities related to the 

organization's exempt purposes 

8 Total 5.000.000 7.500.000 10.000,000 22,500.000 revenue (add lines 1 through 7) . . . . 

Expenses 

9' Expenses attributable to activities related to the 

organization's exempt purposes 5,000,000 7,500,000 10,000,000 22,500,000 

10 Expenses atvibutabie to unreiated business activities 

11 Contributions, gifts, grants, and similar amounts 

paid (attach scheduie) 

10 Expenses atvibutabie 0 0 0 0 to unreiated business activities 

11 Contributions, gifts, grants, and similar amounts 

paid (attach scheduie) 0 0 0 0 

12 Distufsements to or lor the henafu of members (attach schedule) 

13 Compensation of officers, directors, and tnistees (attach schedule) 

14 Other salaries and wages 

0 0 0 0 12 Distufsements to or lor the henafu of members (attach schedule) 

13 Compensation of officers, directors, and tnistees (attach schedule) 

14 Other salaries and wages 

0 0 0 0 

12 Distufsements to or lor the henafu of members (attach schedule) 

13 Compensation of officers, directors, and tnistees (attach schedule) 

14 Other salaries and wages 0 0 0 0 

IS Interest 0 0 0 0 

16 Occupancy. . . . ' 0 0 0 0 

17 Depreciation and depletion 0 0 0 0 

18 Other expenses (attach schedule) 0 0 0 0 

19 Total expenses (add lines 9 through 18) . . . 

20 Excess of revenue over expenses (iine 8 minus 

line 19) 

19 Total 5,000,000 7.500,000 10,000,000 22,500.000 expenses (add lines 9 through 18) . . . 

20 Excess of revenue over expenses (iine 8 minus 

line 19) 0 0 0 0 

B. Balance Sheet (at the end of the period shown) 

Assets 

Cuneni Tax vear 

as Of...1.2/1?... Assets 

i unknown 

2 Accounis receivable, net ... 

2 0 

3 Inveniaries 3 0 

4 Bonds and notes receivable (attach schedule) 4 0 

S CofDorate stocks (attach schedule) S 0 

fi Mortaaae loans (attach schedule) .... ... 

6 0 

7 nihfv inwAcimentc (atiarh crhedule) 7 0 

8 Depreciable and depietabie assets (attach schedule) 

O 1 and . . 

8 0 8 Depreciable and depietabie assets (attach schedule) 

O 1 and . . 0 0 

10 Other assets (attach schedule) 10 0 

11 Total assets .... 

11 unknown 

Liabilities 

12 Accounts navable 12 0 

13 Contributions, oifts. aranis etc.. oavable 13 0 

ia Morioaoes and notes oavable (attach schedule) • 14 0 

IS Other liabilittes (attach schedule) ... 

15 0 

IS Total liabilities 18 0 

Fund Balances or Net Assets 

17 Total fund balances or net assets . 

17 0 

18 Total liabilities and fund balances or net assets (add Ii(ie..i6 and line 17) 18 unknown 

ir there has t>een any substantial change In any aspect of the organization's financial activities since the end of the 

check the bos and attach a detailed explanation 

period shown above. _ 

• 

Attachment A 
Form 1024 (Rev. 9-98) 

ScheduliB B; 

Page 8 

Organizations Described in Section 501(c)(4) (Civic leagues, social welfare organizations 

(inciuding posts, councils, etc., of veterans' organizations not qualifying or applying for 

. exemption under section 501(c)(19)) or local associations of empioyees.) 

Has the Internal Revenue Service previously Issued a ruling or determination letter recognizing the applicant organization 

(or any predecessor organization listed in question 4. Part II ol the application) to be exempt under section S01(c|(3) and 

later revoked that recognition ol exemption on the basis that the applicant organization (or its predecessor) was carrying 

on propaganda or othenvise attempting to influence legislation or on the basis that it engaged in political activity? . . U Yes l£l No 

If 'Yes.* indicate the earliest tax year for which recognition of exemption under section S01(c|(3) was revoked and the 

IRS district office that issued the revocation. 

5 

Does the organization perform or pian to perform (for members, shareholders, or others) services, such as maihtaining 

the common areas of a condominium; buying food or other items on a cooperative basis: or providing recreational facilities _ 

or transportation sen/ices, job placement, or other similar uhdertakings?. LJ Yes B No 

If "Yes." explain the activities in detail, inciuding Income realized and expenses incurred. Also, explain in detail the nature 

ol the benefits to the general public from these activities, (if the answer to this question is explained in Part II of the 

application (pages 2. 3. and 4). enter the page and item number here.) 

If the organization is claiming exemption as a homeowners' association, is access to any property or facilities it owns _ _ 

or maintains restricted in any way? Q Yes 0 No 

If "Yes." explain. 

4 If the organization is claiming exemption as a local association of employees, state the name and address of each employer whose employees 

are eligible for membership in the association, if employees of more than one plant or office of the same employer are eligible for membership, 

give the address of each plant or office. 

Attachment A 
2 

9 

6 

(Rav. January 2010) 

DflpartiMni el-lhe Truawy 

Imamal Ravonue Satvica 

User Fee for Exempt Organization 

Determination Letter Request 

> Attach this form to doterminatlon letter application. 

(Form B718 Is NOT a-determination letter application.) 

1 Name ol orsaniiation 

Commission on Hope, Growth and Opportunity 

For 

IRS 

use 

Only 

CMS No. 1MS-17$8 

Contra! 

AniounI paid 

User tee screeier 

2 Employer Identlflcatlon Number 

27 : 1920168 

Caution. Do not attach Form 8718 to an application for a pension plan determination letter. Use Form 8717 Instead. 

3 Type of request Fee 

a • Initial request for a determination letter for: 

a An exempt organization that has had annual gross receipts averaging not more than $10,000 during the 

preceding 4 years or 

e A new organization that anticipates gross receipts averaging not more than $10,000 during its first 4 years > $400 

Note. If you checked box 3a, you must complete the Certification below. 

Certification 

I certify fhat the annual gross receipts of 

name ol organiation 

have averaged (or are expected to average) not more than $10,000 during the preceding 4 (or the first 4) years of 

operation. 

Signature • ^ Title • 

b ^Z) Initial request for a determination letter for: 

• An exempt organization that has had annual gross receipts averaging more than $10,000 during the preceding 

4 years or 

• A new organization that anticipates gross receipts averaging more than $10,000 during Its first 4 years . ^ $850 

c D Group exemption letters • $3,000 

instructions 

The law requires payment of a user fee 

with each application for a determination 

letter. The user fees are listed on line 3 

above. For more information, see Rev. 

Proc. 2009-8; 2009-1 I.R.B. 229, or latest 

annual update. 

Check the box or boxes on line 3 for the 

type of application you are submitting. If 

you check box 3a, you must complete and 

sign the certification statement that 

appears under line 3a. 

Attach to Form 8718 a check or money 

order payable to the "United States 

Treasury' for the full amount of the user 

fee. If you do not include the full amount, 

your application will be returned. Attach 

Form 8718 to your determination letter 

application. 

Generally, the user fee will be refunded 

only if the Internal Revenue Service 

declines to issue a determination. 

Where To File 

Send the determination letter application 

and Form 8718 to: 

Internal Revenue Service 

P.O. Box 12192 

Covington, KY 41012-0192 

Who Should File 

Organizations applying for federal income 

tax exemption, other than Form 1023 filers. 

Organizations submitting .Form 1023 

should refer to the Instmctions in that 

application package. 

Paperwork Rediictlon Act Notice. We ask 

for the information on this form to carry out 

the Internal Revenue laws of the United 

States. If you want your organization to be 

recognized as tax-exempt by the IRS, you 

are required to give us this information. We 

need it to detennine whether the 

organization meets the legal requirements 

for tax-exempt status. 

You are not required to provide the 

information requested on a form that is 

subject to the Paperwork Reduction Act 

unless the fomt displays a valid 0MB 

control number. Books or records relating 

to a form or its instructions must be 

retained as long as t.heir contents may 

become material in the administration of 

any Intemal Revenue law. The rules 

governing the confidentiality of Form 8718 

are covered in section 6104. 

The time needed to complete and file 

this form will vary depending on individual 

circumstances. The estimated average time 

is 5 minutes. If you have comments 

concerning the accuracy of this time 

estimate or suggestions for making this 

form simpler, we would be happy to hear 

from you. You can write to the Internal 

Revenue Sen/ice, Tax Products 

Coordinating Committee, 

SE:W:CAR:MP:T:T:SP. 1111 Constitution . 

Ave. NW, IR-6526. Washington. DC 20224. 

Do not send this form to this address. 

Instead, see Where To File above. 

Cat. No. 647282 Form 8718 (1-2010) 

Attachment A 
COMMISSION ON HOPE, Gt^OWTH AND OPPOptTUNITV 

ARTICLES OF ASSOCIATIOM 

ARTICLE I 

I Name^Orqaplzgtjon0 The name of this association is the Commission on Hope. Growth and Opportunity (the 

4 "Commission"). The Commission is designated an uruncorporated nonprofit association 

4 creafed under the laws of the District of Columbia. 

8 ARTICLE If 

1 Intent and Purpose: 

^ It Is the intent of the Commission to become a public advocate for the continuing 

education of all American citizens concerning the Importance of continued economic 

growth to America's economic future. The Commission consists of two or more 

individuals joined by mutual consent for the common, nonprofit purposes of educating 

the public on die necessity of sustained economic growth to the future well-befng of the 

United States. The Commissicm may engage in any and ail other public welfare 

activities permitted to an organization exempt from federal income tax under Section 

S01(c}(4) of the Internal Revenue Code of 1986, amended, or corresponding future 

provisions of the federal tax law. To these ends, the Commission may do and engage Irs 

any and aH lawful activities that may be inddentai or reasonably necessary to any of 

these purposes, including but not limited to. the creation and utilization of a commercial 

bank account at a fbanctal institution, and it shall have and may exercise all other 

powers and authority now or hereafter conferred upon unincorporated, nonprofit 

associations in the District of Columbia. 

ARTiCLE III 

Office and Duration: 

1. The office of the Commission shall be located at the address at which the 

Treasurer or General Counsel (or alternate title) has official residence; or at such place 

as the Commission may from time to time determine, eras the business of the 

Commission may require. 

2, The duration of the Commission shall be perpetual. 

Attachment A 
3. The death, removal, or resignation of any officer, member or supporter of the 

Commission shall not result In the dissolution of the Commission. 

ARTICLE IV 

Structure and Membership: 

• The Commission's membership consists of Individuals and groups dedicated to the 

sustalnment, promotion and advancement of growth In the American economy, through 

i public education and Information development. Membership Is open to anyone wishing 

g to render support, guidance and encouragement to Individuals wishing to learn about 

^ and advance the role of economic growth In the economy of the United States and In 

4 furthering a robust public policy debate and policy formulation regarding economic 

1 , growth. 

8 ! 

6 ! The Commission Is a purely voluntary organization, and no membership fee or annual 

2 j dues are required for membership. 

^ . .lo x^ornmisslon does not discriminate on the basis of race, color, sex, age, religious 

I affiliation, handicap, national origin, or other personal factor. 

ARTICLE V 

Association Leadership: 

I 

The Commission shall be governed by at least three (3) officers to be determined by the 

association. The name and total number of officer positions will be determined as the 

! association requires, changeable as circumstances necessitate. One person will be 

designated as Chairman/ Executive Director, one person shall be designated as the 

Treasurer and one person shall be designated as the General Counsel. The 

Treasurer's position shall be a non-management position and the Treasurer Will NOT be 

a voting member of the board of the organization. Two-thirds of the then-existing 

membership will constitute a quorum for the conduct of all Commission business. 

Officers may be elected annually by nomination and a majority vote of at least a quorum 

of the association 

ARTICLE VI 

Accounting and Records: 

I he fiscal year of the Coalition shall be January 1 through December 31 of each year. 

All minute books, correspondence, and other records of the Commission shall be 

preserved by the Treasurer or his designee. Records that have ceased to be of use for 

Attachment A 
the conduct of the affairs of the Commission may be turned over for preservation to a 

depository designated by the Commission, or discarded. 

ARTICLE VII 

Dissolution: 

In the event of the dissolution of the Commission, its property, funds, and other assets 

may be transferred to whatever organization or organizations operated exclusivelv for 

charitable, educational, and/or scientific purppses as the Commission may determine, 

provided such organization or organizations qualify as tax-exempt under the Internal 

Revenue Code of the United States. 

IN WITNESS WHEREOF, the undersigned have executed these Articles of Association 

on this 3/ day of March, 2010. 

STEVE POWELL 

President/Executive Director 

ATTEST: 

WILLIAM B. CANFIELb III 

General Counsel 

Suite ^00 

1900 M Street, N.W. 

Washington, D.C. 20036 

Attachment A 
ATTACHMENT B 

CHGO's Tax Return for Calendar Year 2010 

(IRS Form 990) 
Fbtm 990 

Oepamani of an Tnasuy 

htonal Ravma Sarataa 

Return of Organization Exempt From Income Tax 

Under section S01(c), 527, or 4847(aX1) of the Internal Revenue Code (except biacic lung 

benefit trust or private foundation) 

• The oiganizeUon may have to use a copy ot this return to satisfy state reporting requtrewents. 

A For the 2010 calendar year, or tax year tieglnning 

OMBNa IS<S004; 

2010 

~SpealoREIle~ 

B CInckR 

•sss-

•SKi. 

•isr-

•ssr-

•SSf^ 

eanOhg 

and ending 

C Name of organization 

COMMISSION ON HOPE, GROWTH & OPPORTONITY 

tWng Business As THE COMMISSION 

Number and street (or P.O. box if mail is not delivered to street address) 

1900 M STREET, NW 

Room/duite 

1600 

City or town, state or oountiy, and ZIP -f 4 

WASHINGTON, DC 20036 

F Name and address ot principal officer STEVEN POWELL 

SAME AS C ABOVE 

Tax-exempt status: 

J tWebslte:^ 

I I 50t(c)(3) LZJ S01(c) ( 4 )-4 (Insert no.) 

WWW. HOPE6ROWTHOPPORTUNITY.COM 

[Inseit I I 4947raMH er I T527 

K Form ot orqan'iBtion: I i Corpoiatnn I 

I Part i I ^mtnaty 

ITnist IXI AssociaMon I I Other• 

O Employer Identification numtier 

27-1920168 

E Telephone number 

202-530-3332 

G GfDaraoolpaS 4.601.0a0. 

H(a) Is this a group return 

for affiliates? EHYes [XINO 

H(b) Are all affiliates Included? [ZlYes ONO 

It *No,* attach a fist, (see insbuctions) 

H(c) Group peiMtnptlon exemption number • 

L Year ot tonnation: 2 010| M State ot legal domicile: DC 

1 Bfteliy descnire the organization's mission or most significant activities: THE COMMISSION BELIEVEI^ AND 

INTENDS TO INFORM THE AMERICAN PUBLIC THAT ECONOMIC EXPANSION IS 

2 Checkthlsbox ^ I I it the organizatiandlsoont'nued its operations or disposed ot more than 25H ot Its nm assets. 

3 Numberof voting members of the governing body (Part VI, Ine 1a) 

4 Number of Independent voting members of the governing body (Part VI, fine lb) 

5 Total number ot Individuals employed in calendar year 2010 (Part V, line 2a) . .. 

6 Total number ot volunteers (estimate If necessary 

7 a Total unrelated business revenue from Part VIII, column (Q, line 12 

b Net unrelated business taxable Income from Form 990-T. line 34 

8 Contributions end grants (Pert VIII, line lh) 

B Program sennce revenue (Part VIII, line 2g) 

10 Investment inoome (Part VIII, column W, lines 3,4, and 7d) 

11 Other revenue (Part VIII, column (A), lines 5,6d, 8c, 9c, 10c, and lie) 

12 Total revenue • add lines 8 through 11 (must equal Part VIII, column (A), line 12) 

13 Grants and similar amounts paid (Part iX, column (A), lines 1-3) 

14 Benefits paid to or tor members (Part IX, column (A), fine 4) 

15 Sataries, other compensation, employee benefits (Part IX, column (A), fines 5-1(9 

16a Professional fundralsing faes (Part iX, column (A), line 1 la) 

b Total tUndralsing expenses (Part IX, column (D)Jlna25)— 

17 Other expenses (Part iX, column (A), lines 1 la- id, iifSlEuEiyEp 

IB Total expenses. Add lines 13-17 (must equal Pi rtlXrcoluiTVTtAjrGne 25) TTT 

19 Revenue less ewrenses. Sutrtract line 18 from I IB>12 

20 Total assets (Part X, line 18) 

21 Total ilabifities (Part X fine 2Q 

22 Nrt assets or fii^ balances. Subtract line 21 fiwn line 20 

g" MDV21Z0-^^ s 

irt H ISignattiroBlock 

7e 

7b 

Prior Ye 

Beginning ef Caireiit Year 

0 

T 

TT 

TTT 

TTT 

QmerrtYeer 

4,801,000. 

IT 

TT 

T. 

4,801,000 

IT 

UT 

IT 

TTT 

4,770'; OOP. 

4,770,000. 

31,000. 

End of Year 51,000. 

20,000. 

31,000. 

Under penalties of perjury, I declare that I have examined this retum, including a apanying schedules and statements, and to the best of my knowledge and beliet it s 

^^cqrrect and c^plete. Decbf^tion otj^paier (other than ot^per^lg^based on all intbnnation ot which preparer has any knowtedge. 

Paid 

Preparer 

Use Only 

PitntfType preparer's name 

JAMBS D. WARRING, CPA 

Rtmsnante WARRING & COMPANY,' 

Firm's address ^ 16528 EMORY LN, SUITE 300 

ROCKVILLE, MD 20853-1228 

AS 

Uale. a jm- U 

/////Aiy/reeehrmw 

/ ' iFirm'sEIWfc. 

TTir 

Phoneno. 301-260-0809 

May the IRS discuss this retum with the preparer shown above? (see instnrctionsl 

II oe-aa-ii LXA For Paperworir RedhieUon Act Notlee, see the separate instructions. 

SEE SCHEDULE 0 FOR ORGANIZATION MISSION STATEMENT CONTINUATION 

ULJYes U 

Form 990 (2010) 

Attachment B 

No. • 

J10) (Ti 
Ft)ini99flgOlO) COMMISSION ON HOPE, GROWTH & OPPORTUNITY 27-1920168 Paqe2 

jst^ement of Program Service Accomplishments 

Check if Schedule O contains a response to any question In this Part III LXJ 

Bnefly descrilw the oiganizatlon's nHssion: 

THE COMMISSION WILL SHARE ITS RESEARCH AND FINDINGS WITH PUBLIC POLICY 

FORMULATORS AND WILL ENCOURAGE ITS SUPPORTERS TO COMMUNICATE THEIR 

VIEWS 6N THE ISSUES OF CONSEQUENCE TO THE COMMISSION DiREfcTLY WITH 

POLICY MAKERS AT ALL LEVELS OF GOVERNMENT. THE COMMISSION WILL SEEK 

m the organization undertake any significant program services during the year wtiich were not listed on 

the prior Fomi 990 or.990-EZ7 ... •ves [£)NO 

If 'Yes,' descnbe these new services on Schedule O. 

Did the organlzabon cease conducting, or make significant changes In how It conducts, any program serviees? IZDyes [X]NO 

If 'Yes,' describe these changes on Schedule O. 

Descnbe the exempt purpose achievements for each of the orgartizatlon's three largest program services by expenses. 

Section 501(c)(3} and S01(cX4) organizations and section 4947(aX1) tresis are required to report the amount of giants and 

allocations to others, the total expenses, and revenue. If arw, for each program senrioe reported. 

(Code: )(ExpensesS 0» including grants of $ 0»)(Revenue$ 0«) 

N/A 

4b (Code: )(Expenses$ 0 « including grants of $ 0«)(Revanue$ 0») 

N/A 

4c (Code: )(Expenses$ 0. Induding grants of $ )(Revenue$ 0 . ) 

N/A 

4d Other program seivioes.(Dascifi>efri Schedule 0.) 

(ExpensesS Indudlno grants of S ) (Revenues ) 

4e Total nnxawm service exoenses^ 

1^990(2010) 

Attachment B 
F^990e010) COMMISSION ON HOPE, GROWTH & OPPORTUNITY 

~ " I Checklist ot Required Schedules 

27-1920168 Paae3 

1 Is the oigsnlzatian described in section S01(c)(3) or 4947(8)(1) (oltwrthan e private foundation)? 

It'Yes.'complete Schedule A 

2 is the oiganizationiequlred to complete Schedule B, Schedule of Contributors? 

3 Did the organization engage in dsect or indirect poTitical campaign activitias on beliaif of or in opposition to candidates for 

public office? # "Ms. • conipfcte Sc/ieduile C, flsrf / 

4 Section S01(cX3) organbatians. Did the organization engage in lobbying activities, or have a section 501(h) election In effect 

during the tax year?/f'Ybs, * comp/lete Scfieduto C, Part// 

5 Is the organization a section S01(cX4), S01(cX5). or S01(c)(6) organization that recenres membership dues, assessments, or 

similar amounts as defined in Revenue Procedure 96-19? If 'Yes,'complele Schedule C, Part III 

6 Did tfie organization maintain any donor advised fonds or any similar funds or accounts where donors fiave the nglit to 

provKle advloe on the distribution or investment of amounts in such funds or accounts? If *Ves,' conrpfsfe Schedule O, Part I 

7 Did tfie organization receive or hold a conservation easement, including easements to preserve open space, 

the envlnonment,hlstoriciandareas,orhistoricstnjctures?lf'Vbs,'complete ScfredufeOi Par? ff 

8 Od the organization maintain coOectlons of worts of art, historical treasures, or other simiiar assets? If'Yes,' complele 

Schedule D, Part III 

9 Did tfie organization report an amount in Part X, line 21; serve as a custodian for amounts not listed in Part X; or provide 

credit counseling, debt management, credit repair, or debt negotiation services? If' Ves, * complete Schedule D, Part IV 

10 Did the organizatiori, directly or thnargh a related organization, fnid assets in term, permanent, or quaslendowments? 

If'Yes,'complete Schedule D, Pert V 

11 if the organization's answer to any of tfie foiiowing questions is 'Yes,' tfien complete Schedule 0, Parts Vt, Vli, Vtii, iX, or X 

asappiicabie. 

a Did the organization report an amount for land, buildings, and eqUpment in Part X, fine 10? IT 'Yes,' complete Schedule 0, 

PartVI 

b DU the organization report an amount for investments-other securities in Part X, line 12 Ifnt is 5% or more of its total 

assets reported in Part X, ime 16? If'Yes, * corrtpleie Schedule O, Part 1/7/ 

c Did the organization report an amount for investments-program related in Part X, One 13 that is 5K or more of its total 

assets reported in Part X, line 16? lf'yte,'corrtplBlBSchedlrlBD, Part IT// 

d Did the organization report an amount for otfier assets in Part X, line IS tfiat Is 9M or more of its total assets reported in 

Part X, line 16?//'Vfes,' coovlelB Schedule ft Part/X 

e Old the organization report an amount for other GabOities in Part X, line 25? If'Yes,' complete Schedule ft Part X 

f Did the organization's separata or consolidated finaruaai statements for the tax year Include a footnote that addresses 

the organization's liability for uncertain tax positions under FIN 48 (ASC 740)7/7'Vbs,'cornpleie Schedule ft PartX 

12a (Xd the organization obtain separate, independent audited financial statements for tfie tax year? If 'Yes,' complete 

Schedule D, Parts 30. XII, md XIII 

b Was the organization included in consolidated, independent audited financiai statements for tfie tax year? 

//'Vbs,'and/r die organlEBflon answered'A/d'to line 12a, then completing Schedule D, Partsld, 301, end XIII is opticn^ 

13 is the organization a school described in section 170(b)(1)(AXii)?/f'V1ss.'corrv>lele Schedule e 

14a Did the organization maintain an office, employees, or agents outside of the United States? 

b Did the organization have aggregate revenues or expanses of more than $10,000 from grantmaidng,fundraising, business, 

and program service activities outside the United States? If 'Yes,'complete Schedule F, Parts land IV 

15 Did the organization report on Part iX, column (A), fine 3, more than $5,000 of grants or assistance to any organization 

or entity located outside the United States?/f'MB,'corrgjlele Schedule P. Parts//and/Y 

16 Did the organization report on Part DC, column (A), ime 3, more than S5/XX) of aggregate grants or assistanoe to individuals 

located outside the United States?//'Yes,'complete Schedule F, Parts///and/Y 

17 Did the organization report a total of more than $15,000 of expenses for professional fondraising services on Part DC, 

column (A), lines 6 and 11d?//'Yes,'contplBie Schedule G, Part/ 

16 Did the organization report more than $15,000 total of fondraising event gross income and contnbubons on Part Vlii, fines 

1 c and 8a7//*Vbs;'complete Schedule (S, Part// 

19 Old the organizatian report more than $15/XX) of gross income fram gaming activities on Part VUi, fine 9a?//'Yes,* 

campletB Schedule G, Pert III 

20a Did the organization operate one or more hospitals?//'Vbs,* complete SchedUteH 

b if 'Yes' to fine 20a, did tfie organization attach its audited financai statements to tha return? Note. Some Forni 990 filers that 

operate one or more hospitais must attach audited financial statements (see insbuctionsi 

Yes No 

1 X 

2 X 

3 X 

4 

5 X 

6 X 

7 X 

8 X 

9 X 

10 X 

11a X 

lib X 

11c X 

lid X 

lie X 

11f X 

12a X 

12b X 

13 X 

14e X 

14b X 

15 X 

16 X 

17 X 

16 X 

19 X 

20a X 

200 

Fomi 990 (2010) 

13-21-10 

Attachment B 
Fofm990.e010) COMMISSION ON HOPE, GROWTH & OPPORTUNITY 27-1920168 Page4 

Ch^klist of Required Schedules rconttweco 

21 

22 

23 

26 

27 

Old the oiganlzalian repoft more than $5,000 of grants and ottwr assistance to govemments and organizations in the 

United States on Pert IX, column (A), line 17 'Yes,'complete Schedute I, Parts land II 

Did the ciganization rspoil more than $5,000 of grants and other assistance to individuals in the United States on Part IX, 

column (A>, line 2? If •yfes,*co«VJfete Schedolls/, /and/// 

Did the organization answer 'Yes' to Part VII, Section A, line 3,4, or 5 about compensation of the organization's cunent 

and fonner ofRceis, directors, tmstees, key employees, and highest compensated employees? If 'Yes,'campble 

SctieduleJ 

24a Did the organization have a tax-exempt bond issue with an outstanding principal amount of more than $100,000 as of the 

last day of the year, that was Issued after December 31,2002? If 'Yes,' answer lines 24b tfiroug/t 24d and complele 

SehedirtelClf'No'.gologne25 

b Did the organization Invest any proceeds of tax-exempt bonds beyond a temporary period exception? 

c Did the organization maintain an escrow aocount other ttian a refunding escrow at any time during the year to defease 

any tax-exempt bonds? .... 

d Did the organization act as an'on behalf of Issuer for bonds outstanding at any time during the year? 

2Sa Section S01(cX3) and S01(cX4) organizations. Did the organization engage in an excess tienefit transaction with a 

disqualilied person during the year? if'Tfes,'complete Sc/iedtiteCRarf/ 

b Is the organization aware that it engaged in an excess benefit transaction with a disqualified person in e prior year, and 

that the transaction has not been reported on any of the organization's prior Ftems 990 or 990-EZ? If 'Vbs,* complete 

Schedule L, Part I 

Was a loan to or by a cunent or fonner officer, director, tnistee, key employee, highly compensated employee, or disqualified 

person outstanding as of the end of the organization's tw year? if'Yes,'convrteteScfiedl/leC PartU 

Did the organization provide a grant or other assistance to an officer, director, trustee, key employee, sutrstantial 

contributor, or a grant selection committee memlier, or to a person related to such an individual? If 'Yes,' complete 

Schedule L. Part III 

Was the organaatxm a party to a business transaction with one of the foikrwing parties (see Scfiedule L, Part IV 

instnictions fbr applicable fiGng thresholds, conditions, end exceptions); 

A current or former officer, director, tntetee, or key employee? ff'Yes,'corrtpfeteScfietfufei, PartlV 

A family member of e cunent or fbmier officer, director, tnjstae, or key employee? If 'Yes,'comfrtete Schedule L, Part lY ... 

An entity of which a cunent or former officer, director, tnistee, or key employee (or a family memirer tfieraof) was an officer, 

director, trustee, or direct or Indirect owner? If "Yes,' compime Schedule L,PartlV_ 

Did the organlzabon receive more than $25,000 In noncash contributions? If 'Yes, * complete Schedule M 

Did tfie organ'izabon receive contributions of art histoncal treasures, or other.slmiiar assets, or qualified consenration 

comrtbUbonafllfybs,'complele Schedule M 

Did the organization liquidate, terminate, or dissolve and cease operations? 

If'Yes,'complete Schedule N. Part I 

Did the organoation seD, exchange, dispose of, or transfer more than 25% of Its net assets?# 'Yes,'complete 

Schedule N, Part II 

Did the organlzatron own 100% of an entity disregarded as separate from the organization under Regulations 

sections 301.7701-2 and 301.7701-3? ff'ViBS,'complete Schedule RParff 

Was the organization related to any tax-exempt or taxable entity? 

If 'Yes,' corrtplete Schedule R, Parts II, III, IV. and V, One 1 

Is any related organization a controlled entity within the meaning of eectton 512(bX13)? 

[fid the organization receive any payment from or engage in any transaction wHh a controlled entity within tfie 

section 5l2m(13>? " "Vte.* corrtpfete Schedule R, Part V, Bie 2 Cj Yea L2J Mo 

Sectfon S01(c)(3) organlzallana. Did the organization make any transfers to an exempt noncharitable related organization? 

29 

30 

31 

32 

33 

34 

37 

38 

tfie meaning of 

O Yes Si I 

If'Yes,'complele Schedule R, Part V,tne 2 

Did tfie organization conduct more than 5% of its activities through an entity that is not a related organization 

and that Is beated as a partnership for fedeiai Income tax purposes? #'Vbs,*canvifeteScfredOleR, Part W 

Did tfie organization complete Schedule O and provide explanations In Schedule O for Part VI, lines 11 and 19? 

Note. AD Form 990 faera are leatdred to complete Schedule O . .. 

21 

Yes No 

X 

22 X 

23 X 

24a X 

24b 

24c 

24d 

Ka X 

25b X 

26 X 

27 X 

28a X 

28b X 

2Be X 

29 X 

30 X 

31 X 

32 X 

33 X 

34 X 

35 X 

36 

37 X 

38 X 

Fonn 990 (2010) 

1^^M0 

Attachment B 
Fomi990(2010) COMMISSION ON HOPE, GROWTH & OPPORTUNITY 

Statements Regarding Other IRS Filings and Tax Compliance 

27-1920168 PaoeS 

Check If Schedule 0 contains a response to any question In this Part V [X] 

la Enterthe reimlMr reported In Box3 of Foim 1096. Enter-O-Knot appricable .. _1a_ 

b Enter the number of Forms W-2G Included in line la. Enter-0-If not applicable _1|^ 

c 0x1 the organization comply wHh backup wrlthhoidlngnjles for reportable payments to vendors and reportatrle gaming 

(gambling) winnings to prize winners? .. 

2a Enterthe number of employees reported on Form W3, Transmittal of Wage and Tax Statements, 

filed fbrttie calendar year ending with or within the year covered by this return... 2a 

b If at least one is reported on line 2a, dxi the organization file aO required federal employment tax returns? . 

Note. If the sum of lines la and 2a B greater than 250, you may be required to e^. (see Instructions) 

3a Old the organization have unrelated business gross Income of SI ,000 or more during the year? 

b If'Yes,* has It filed a Form OOO-T for this year? tf'Ato,*prDwefe en erettanafkm in Schedule O 

4a At any time during the calendar year, did the organization have an Interest In, or a signature or otfier authority over, a 

financial account In a foreign country (such as a bank aooount, securities account, or other financial account)? 

b If'Yes.'enter the name of the foreign country:^ 

Sa 

b 

c 

6a 

See instructions for filing requirements for Fonn TD F 90'22.1, Report of Foreign Benk and Rnandal Accounts. 

Was the organization a party to a prohibited tax shelter transacfion at any time during the tax year? 

•Id any taxable party notify ttie organization that it was or Is a party to a prohibited tax shelter transaction?. 

If'Yes,* to fine Sa or Sb, did the organization file Fdnn8886-T7 

Does the organization have annual gross receipts that are noimal^ greater than $100,000, and did the organization solicit 

any contributions ttiat ware not tax deductible? . . 

if 'Yes,' did the organization include with every soiicitalion an express statement that such contributions or gifts 

were not tax deductibie? 

Organizations that may receive deducdble contrlbutfoiis under secbon 170(0). 

Did the crganiiation recelvB a payment In excess of $75 made partly as a coninbuiion and partly for goods and senrices provided to die payor? 

if 'Yes,* did the organization notify the donor of the value of the goods or services provided? 

DxJ the organization saD, exchange, or otherwise dispose of tangibie personal property for which it was required 

to file F«m 8282? 

If'Yes,* indicate the number of Fbmns 6262 filed during ttie year I 7d I 

(M the organization receive any funds, directly or Indirectly, to pay premhims on a personal benefit contract? 

Did the organization, during the year, pay premiums, diiBCtly or Indirectly, on a personal benefit contract? 

If the organization received a contribution of qualrfied Intellectual property, did the organization file Fdnn 6699 as required? . 

If the organization received a contribution of cars, boats, airplanes, or other vehicles, did the organization file a Fomi 1098O? 

Sponsoring organlations mslntolnlng donor odvlsod funds and soetlon S09(o)(3) supporting orginlzitlons. Old (lie supporting 

organizallon. or a donor advised fund malnlalned by a sponsoring organbailon, have excess business holdings at any Ume dunng the year? 

Sponaoring organbEstlons maintaining donor advised funds. 

a 

b 

1 

a 

b 

10a 

10b 

11a 

lib 

a Did the orgardzation make any taxable distifbiitlons under section 4966? 

b Old the organization make a distribution to a donor, donor advisor, or related person? 

10 Section S01(c)(7) organiiattons. Enter 

Initiation fees and capital oontritautions Included on Part VIII, line 12 

Qross receipts, InchJded on Fdmi 990, Pert VIII, line 12, for public use of dub fadfities . 

11 Section S01(cX12)organizationa. Biter. 

Gross Income from members or sharehdders 

Gross income from other sources (Do not net amounts due or paid to other sources against 

amounts due or received from ttiem.) 

12a Section 4947(aX1) nen-exampt charitabie trusta. Is the organizainn filirig Form 990 In Eeu of Fomi 1041? 

b If *Yes,* enter the amount of tax-exempt interest received or accnred during the year .... 112b I 

13 Section 901(c)(29) qualified nonprofit health insuranee issuers. 

a Is the crganrzationlioensed to issue qualified healtti plans in more than one state? 

Note. See ttie Insbucilans for addltranal Infonnatlon the otganlzalion must report on Schedule O. 

b Enter the amount of reserves the organization Is required to maintain by the states hi which the 

organization is fioenssd to Issue qualified healtti plans 13b 

c Enter the amount of reserves on hand 

14a Did the organization receive any payments for Indoor tanning servleas during the tax year? 

b If *Yes.* has It filed a Fonn 720 to report these oavments? 17 *Wo,*proviitfa an erqoianatwngiSc/iertrieO 

13c 

1c 

7a 

12B 

13a 

14a 

Mb 

Yes No 

X 

X 

x_ 

S t 

X 

Form 990 (2010) 

Attachment B 
Fotm 990 (20101 jOIOl COMMISSION gSf HOPE, GROWTH & OPPORTUNITY 27-1920168 PageS 

Governance, Management, and Disclosure For each 'Yes' response to mes 2 through 7b below, and tor a 'No* response 

to Sne 8a, 8b. or 7 Ob beTow, describe die aiajmsta/ices, processes, or ebanges in Schedule O. See tnstruedoas. 

Check If Schedule O contains a response to any Question In this Part VI 

Section A. Governing Body and Management 

la Enter the number of voting members of the goveming body at the end of the tax year 

b Enter ttw number of votmg members included in line la, above, who are independent 

2 Did any officer, director, trustee, or key employee have a family relationship or a business relationship with any other 

officer, director, trustee, or key employee? 

3 Old the organization delegate control over management duties customarily parfbnned by or under tfie direct supervision 

of officers, directors or tnjstees, or key employees to a management company or other person? 

4 Did the organization make any eignificant changes to its goveming documents since ttie pnor Form 990 was filed? . ... 

5 Did the orgarvzation become aware during the year of a significant diversion of the organization's assets? 

6 Does ttie orgardzatKvi fiave members or stockholders? 

7a Does tfie organization have members, stockholders, or other persons who may elect one or more members of the 

goveming body? 

b Are any decisions of the goveming body subject to approval try members, stockhoMeis, or other persons? 

Did the organization contemporaneously document the meetings held or written actions undertaken durmg the year 

bythefonowing: 

The goveming iMdy? ... 

Eachcommltteewithauttiorftytoactonbehalf of the goveming body? 

Is there any officer, director, trustee, or key employee iBted In f>art VII, Section A, wlw cannot be reached at the 

oroanizabon's mallino address? If'Yes.' prmlda the names and addresses Hi Schedule O 

8 

9 

8a 

No 

X 

X 

x_ 

X 

X 

X 

X 

X 

Section B. Policies (this section a requests kifiarmatftrr ctes not lequbed by the Internal Revenue Code.) 

10a Does die organlzabon have local cfiapters, brancties, or afffilates? 

b If "Yes," does the otganizaban have written policies and procedures goveming the activities of such chapters, affiliates, 

and branches to ensure their operations are consistent with ttiose of the organization? 

11a Has ttie organization provided a copy of this Form 990 to ail memtms of Its governing txxly before fifing ttie form? 

b Descnbe In Schedule O the process, if any, used by the organlzatkm to review ttus Fomn 990. 

12B Does the organization have 8 written oonfllct of interest policy? If'NO.* goto Ore fS 

b Are officers, directors or tnistees. and key employees required to rfsdose annually interests that could give rise 

to conflicts? 

c Does ttie organization legularty and consistently monitor and enforce oompfiance with the poBcy? If'Yes,' descnbe 

in Schedule O how this is done 

13 Does the organization have a written whistleblowBr policy? 

14 Does the organization have a written document retentian and desbuctkm policy? 

15 Did the process fOr detemilnlng compensation of the following persons Include a review and approvai by Independent 

persons, comparability data, and contemporaneous substantiation of the deliberation and decision? 

a The organization's CEO, Executive Director, or top management offioal 

b Otiier officers or key employees of the organizabon 

If'Yes* to fine 15a or 15b, describe the process in Schedule O. (See instructions) 

ISa Did the organization invest in, contribute assets to, or participate in a joint venture or similar arrangement with a 

taxable entity during the year? 

b If 'Yes,' has the organization adopted a written policy or procedure requiring the organization to evaluate its participation 

m joint venture arrangements under applicable federal tax law, and taken steps to safeguard the organizalion's 

exemot status with respect to such ananoanients? 

Itta 

10b 

lie 

12a 

12b 

12c 

ISa 

15b 

18a 

lOb 

Yes No 

T 

IT 

T 

X 

Section C. Disdosure 

17 Ust the states with which a copy of this FOnii 990 Is required to be filed ^ "iissr 

18 

19 

20 

Section 6104 requires an organization to make Its Fonns 1023 (or 1024 if applicable), 990, and 990-T (501(c)(3)s only) available for 

public Inspection. Indicats liow you make these availabia Clieck all ttiat apply. 

CZlownwebslte d] Anottier^ website IX) Upon request 

Dascfibe In Schedule O whether (and if so, how4, the organization makes Its goveming documents, conflict of Interest policy, and flnanoal 

statements avafiable to ttie pubfic. 

State the name, pfiysical address, and telephone number of the person who possesses ttie books and records of the organeatlcn: ^ 

STEVEN POWELL - 202-530-3332 

ISOO M STREET. WASHINGTON. DC 20036 

Form 990 (2010) 

12-21-10 

Attachment B 
FormggacoiO) COimiSSION ON HOPE. GROWTH & OPPORTUNITY 27-1920168 PageT 

Compensation of Officers, Directors, Trustees, Key Employees, Highest Compensated 

Employees, and Independent Contractors 

Check If Schedule O eontare a leaponsa to any question In thb Part VII 

SecBonA. Otflcefs,Directors.Trustees.KeyEwplayaea.andHInheetCoinpeiwatedEinalowea 

la Complete this table for all persons required to be listed. Report compensation lor the calendar year ending with or within the organiatlon's tax year. 

• ^ all of the craan^on'^miit ofRcers, directors, trustees (whether tndlvtduals or organizations), regardless of amount of compensaUcin. 

Enter-O-in columns (iq,(E), and (F) if no compensation was paid. » , v-

• Ust all of the organization's current key employees, if any. See Instnjctions for definition of "key employee.' 

e Ust the organizatron's five eorreiit highest compensated employees (other than an officer, director, trustee, or key employee) who received reportable 

compensabon (Box 5 of Form W-2 and/Or Box 7 of Form 1099-MISC) of more than $100,000 from the organbation and any related organtaations. 

• Ust alt of the organization's former officers, key employees, and highest compensated employees who received more than $100,000 of 

reportable compensation from the organization and any related organizations. 

• Ust all of the organization's former directors or trustees that received. In the capacity as a fomier director or bustee of the organization, 

more ttian $10,000 of reportable compensation from the organization and any related organizations.' 

^ foira'sind'nndual trustees or directors; institutional tnistees; officers; key employees; highest compersatedemployees; 

(A) 

Name and IWe 

(B) 

Average 

hours per 

week 

(descnbe 

hours for 

related 

organizations 

in Schedule 

Q> 

(C) 

Positron 

(cfreck all that apply) 

(D) 

Reportable 

compensation 

from 

the 

organization 

(W-2/109SMISC) 

(E) 

Reportable 

compensation 

from related 

organizations 

(W-27109BMISC) 

(H 

Estimatad 

amount of 

other 

compensabon 

from the 

organization 

and related 

organizations 

(A) 

Name and IWe 

(B) 

Average 

hours per 

week 

(descnbe 

hours for 

related 

organizations 

in Schedule 

Q> 

i 

i 

1 

1 1 

1 

1 

ip 

If 1 

(D) 

Reportable 

compensation 

from 

the 

organization 

(W-2/109SMISC) 

(E) 

Reportable 

compensation 

from related 

organizations 

(W-27109BMISC) 

(H 

Estimatad 

amount of 

other 

compensabon 

from the 

organization 

and related 

organizations 

STBVBM FONSLL 

PRSSIDHHT / BXBCDTIVB DIRBCTOH 5.00 X 20,000. 0. 0. 

WILLIAM CMIPIBLD 

GBNBRAL COUBSBL 2.00 X 50,000. 0. 0. 

Attachment B 
COMMISSION ON HOPE, GROWTH & OPPORTONITY 27-1920168 

k 

0 

4 

Page 8 

(A) 

Name and title 

(B) 

Average 

hours per 

week 

(describe 

hours for 

related 

organizations 

in Schedule 

0) 

(C) 

Position 

(check all that apply) 

P) 

Reportable 

compensation 

from 

the 

organization 

(W-2/109SMISC) 

(E) 

Reportable 

from related 

(W-2/109SMISC) 

(F) 

Estimated 

amount of 

otfier 

compensabon 

from ttie 

organization 

and related 

organtaabons 

(A) 

Name and title 

(B) 

Average 

hours per 

week 

(describe 

hours for 

related 

organizations 

in Schedule 

0) 

! 

1 

1 

S 

B 

£ 1 i i 1 £ 

P) 

Reportable 

compensation 

from 

the 

organization 

(W-2/109SMISC) 

(E) 

Reportable 

from related 

(W-2/109SMISC) 

(F) 

Estimated 

amount of 

otfier 

compensabon 

from ttie 

organization 

and related 

organtaabons 

lb Sub-total • 1 70,000. 0. 0. 

c Total iromcontinuaUon sheets to Part VII, Section A ^ 

d Total iBdd lines lb and lc) >• 

0. 0. 0. c Total iromcontinuaUon sheets to Part VII, Section A ^ 

d Total iBdd lines lb and lc) >• 70,000. 0. 0. 

Total number ol Individuals Gnduding but not rimlted to those bsted above) who leosived more than $100,000 In reportable 

comoensation from the oraaniatlon » 

Old the otganteaUon list any farmer oflioer. dlractor or tnistee, key employee, or highest compensated employee on 

[me W If'Yes,'eompble Schedule J tor such htdlMua 

FOr any Individual listed on line 1a, is the sum of reportable compensation and other compensation from the organization 

and rslated organizations greater than $150,0007 II'Yes,' camplela Schedule J lor such Aidivfrftrai 

Did any person Isted on fine la reoelvo or accrue compensation from any unrelated organizabon or Individual for services 

tenderedtotheorganlzatlonVff'yes,'cornp<eiBScftedulbJitarsirc/ipefson 

Suction 8b Indepenitent ContFactof a 

No 

X 

1 Complete this table for your five highest compensated independent contractors that received more than $100,000 of compensation from 

(A) 

Name and business address 

(B) 

Description of services 

(C) 

(Vimpensation 

MERIDIAN STRATEGIES, LLC, 400 7TH STREET, 

NH, SUITE 300, WASHINGTON, DC 20004 4EDIA PLACEMENT 4,319,825. 

MERIDIAN STRATEGIES, LLC, 400 7TH STREET, 

NW, SUITE 300, WASHINGTON, DC 20004 lEDIA PRODUCTION 275,000. 

MERIDIAN STRATEGIES, LLC, 400 7TH STREET, 

NW, SUITE 300, WASHINGTON, DC 20004 

a}VERTISING & 

rECHNOLOGY 105,175. 

2 Total number of Independent contractors (including but not limited to ifiose listed above) wfio received more than •:. •. • 

IZ-ZMO 

Attachment B 
fann99ChB010) COMMISSION ON 

i Part Vlll I Statement of Revenue 

HOPE, GROWTH & OPPORTDNITY 27-1920168 PageS 

W 

Total revenue 

(B) 

Related or 

exempt function 

revenue 

(C) 

Unrelated 

t>usiness 

revenue 

ReSS^ue 

excluded from 

tax under 

iSISSf 

n 

I! 

£ 

1 a Federated campaigns 

b Membership dues 

c Fundraislng events 

d Related organizations 

e Government grants (contributions) 

f All other contrlbulioiis, gills, grants, and 

similar amounts not Included above 

g NomatieontittnitaanalndudsdinllnnlB-irS 

la 

lb 

Id 

10 

If 

4801000. 

Total. Add Dries la-lf 4801000 

2 a 

b 

c 

d 

a 

f AD otfier program senrica revenue . 

Total. Add lines 2a-2f 

Investment income (including dividends, interest, and 

other similar amounts) • 

Income from investment of tax-exempt bond proceeds ^ 

Royalties 

6 a Gross Rents 

b Lass: rental expenses, 

c 

d 

Rental Income or (joss) 

Net rental Income or (loss) 

(DReal (9) Personal 

7 a Gross amount from sales of (1) Securities CO Other 

assets ottier than inventory 

b Less: cost or oltier basis 

and sales expenses 

c Gainor(loss) 

d Net gain or (jos^ . . • 

8 a 

b 

c 

90 

10 

Gross income from fundraislng events (not 

including $ of 

contributians reported on Una 1c). See 

PartlV.Dneie . .. a 

Less: direct expenses b 

Net income or (loss) from fundFBBing events 

Gross tncome from gaming activities. See 

PartlV.DnelO a 

Less: direct expenses b 

Net Income or (loss) from gaming actlvibes .. 

Gross sales of bwentory, lass returns 

and allowances a 

Lass: cost of goods sold b 

Nat Income or (loss) from sales of Inventory 

Miscelianeous Revenue 

11 

12 

JB 

AD other revenue 

Total. Add Ones 11»11d .... 

Total revenoe. See Instructions. 

• T: TTT 

Form 990 (2010) 

Attachment B 
Fwni9MeoiO) COMMISSION ON 

I PaftlXj Statement of Functional Expenses 

COMMISSION ON HOPE. GROWTH & OPPORTUNITY 27-1920168 PagelO 

Section 50;Cc;;|3; and SOlfcX^) orgmbsfOons must complete aff columns. 

At other organballons must completB column W but am not lequted to complete coftimns (B), (C). and (P). 

Do not Include amounts reported on lines 6b, 

7b, 8b, 9b, and lOb of Part VIII. 

W 

Total sx^nsos PiDgraln service 

expenses 

(C) 

Management and 

ganafal oooansos 

Rin£ising 

expenses 

1 Grants and other assistance to eovernments and 

oroanbadons In the U.Si See Part IV, line 21 

2 Grants and other assistance to individuals in 

the U.S. See Part IV, line 22 

. 3 Grmts and other assistance to govemments, 

organizations, and individuals outside the U.S. 

See Part IV, Rnes 15 and 16 . 

4 Benefits paid to or lor memtjeis 

trustees, and key employees . .. 

6 Compensation not Included above, to dsqualdled 

persons (as defined under section 49S8(I)(1)) and 

persons described in section 4958(c)(3KB) 

7 Other salaries and vrages 

8 Pension plan contributions (include section 401(i() 

and section 403(b) employer contributions) 

6 Other employsa benefits 

10 Payroll taxes 

11 Fees for services (norvemployees): 

e Management 

T • • 1 Grants and other assistance to eovernments and 

oroanbadons In the U.Si See Part IV, line 21 

2 Grants and other assistance to individuals in 

the U.S. See Part IV, line 22 

. 3 Grmts and other assistance to govemments, 

organizations, and individuals outside the U.S. 

See Part IV, Rnes 15 and 16 . 

4 Benefits paid to or lor memtjeis 

trustees, and key employees . .. 

6 Compensation not Included above, to dsqualdled 

persons (as defined under section 49S8(I)(1)) and 

persons described in section 4958(c)(3KB) 

7 Other salaries and vrages 

8 Pension plan contributions (include section 401(i() 

and section 403(b) employer contributions) 

6 Other employsa benefits 

10 Payroll taxes 

11 Fees for services (norvemployees): 

e Management 

1 Grants and other assistance to eovernments and 

oroanbadons In the U.Si See Part IV, line 21 

2 Grants and other assistance to individuals in 

the U.S. See Part IV, line 22 

. 3 Grmts and other assistance to govemments, 

organizations, and individuals outside the U.S. 

See Part IV, Rnes 15 and 16 . 

4 Benefits paid to or lor memtjeis 

trustees, and key employees . .. 

6 Compensation not Included above, to dsqualdled 

persons (as defined under section 49S8(I)(1)) and 

persons described in section 4958(c)(3KB) 

7 Other salaries and vrages 

8 Pension plan contributions (include section 401(i() 

and section 403(b) employer contributions) 

6 Other employsa benefits 

10 Payroll taxes 

11 Fees for services (norvemployees): 

e Management 

1 Grants and other assistance to eovernments and 

oroanbadons In the U.Si See Part IV, line 21 

2 Grants and other assistance to individuals in 

the U.S. See Part IV, line 22 

. 3 Grmts and other assistance to govemments, 

organizations, and individuals outside the U.S. 

See Part IV, Rnes 15 and 16 . 

4 Benefits paid to or lor memtjeis 

trustees, and key employees . .. 

6 Compensation not Included above, to dsqualdled 

persons (as defined under section 49S8(I)(1)) and 

persons described in section 4958(c)(3KB) 

7 Other salaries and vrages 

8 Pension plan contributions (include section 401(i() 

and section 403(b) employer contributions) 

6 Other employsa benefits 

10 Payroll taxes 

11 Fees for services (norvemployees): 

e Management 

. 

- • 

1 Grants and other assistance to eovernments and 

oroanbadons In the U.Si See Part IV, line 21 

2 Grants and other assistance to individuals in 

the U.S. See Part IV, line 22 

. 3 Grmts and other assistance to govemments, 

organizations, and individuals outside the U.S. 

See Part IV, Rnes 15 and 16 . 

4 Benefits paid to or lor memtjeis 

trustees, and key employees . .. 

6 Compensation not Included above, to dsqualdled 

persons (as defined under section 49S8(I)(1)) and 

persons described in section 4958(c)(3KB) 

7 Other salaries and vrages 

8 Pension plan contributions (include section 401(i() 

and section 403(b) employer contributions) 

6 Other employsa benefits 

10 Payroll taxes 

11 Fees for services (norvemployees): 

e Management 

1 Grants and other assistance to eovernments and 

oroanbadons In the U.Si See Part IV, line 21 

2 Grants and other assistance to individuals in 

the U.S. See Part IV, line 22 

. 3 Grmts and other assistance to govemments, 

organizations, and individuals outside the U.S. 

See Part IV, Rnes 15 and 16 . 

4 Benefits paid to or lor memtjeis 

trustees, and key employees . .. 

6 Compensation not Included above, to dsqualdled 

persons (as defined under section 49S8(I)(1)) and 

persons described in section 4958(c)(3KB) 

7 Other salaries and vrages 

8 Pension plan contributions (include section 401(i() 

and section 403(b) employer contributions) 

6 Other employsa benefits 

10 Payroll taxes 

11 Fees for services (norvemployees): 

e Management 

1 Grants and other assistance to eovernments and 

oroanbadons In the U.Si See Part IV, line 21 

2 Grants and other assistance to individuals in 

the U.S. See Part IV, line 22 

. 3 Grmts and other assistance to govemments, 

organizations, and individuals outside the U.S. 

See Part IV, Rnes 15 and 16 . 

4 Benefits paid to or lor memtjeis 

trustees, and key employees . .. 

6 Compensation not Included above, to dsqualdled 

persons (as defined under section 49S8(I)(1)) and 

persons described in section 4958(c)(3KB) 

7 Other salaries and vrages 

8 Pension plan contributions (include section 401(i() 

and section 403(b) employer contributions) 

6 Other employsa benefits 

10 Payroll taxes 

11 Fees for services (norvemployees): 

e Management 

1 Grants and other assistance to eovernments and 

oroanbadons In the U.Si See Part IV, line 21 

2 Grants and other assistance to individuals in 

the U.S. See Part IV, line 22 

. 3 Grmts and other assistance to govemments, 

organizations, and individuals outside the U.S. 

See Part IV, Rnes 15 and 16 . 

4 Benefits paid to or lor memtjeis 

trustees, and key employees . .. 

6 Compensation not Included above, to dsqualdled 

persons (as defined under section 49S8(I)(1)) and 

persons described in section 4958(c)(3KB) 

7 Other salaries and vrages 

8 Pension plan contributions (include section 401(i() 

and section 403(b) employer contributions) 

6 Other employsa benefits 

10 Payroll taxes 

11 Fees for services (norvemployees): 

e Management 

1 Grants and other assistance to eovernments and 

oroanbadons In the U.Si See Part IV, line 21 

2 Grants and other assistance to individuals in 

the U.S. See Part IV, line 22 

. 3 Grmts and other assistance to govemments, 

organizations, and individuals outside the U.S. 

See Part IV, Rnes 15 and 16 . 

4 Benefits paid to or lor memtjeis 

trustees, and key employees . .. 

6 Compensation not Included above, to dsqualdled 

persons (as defined under section 49S8(I)(1)) and 

persons described in section 4958(c)(3KB) 

7 Other salaries and vrages 

8 Pension plan contributions (include section 401(i() 

and section 403(b) employer contributions) 

6 Other employsa benefits 

10 Payroll taxes 

11 Fees for services (norvemployees): 

e Management 

1 Grants and other assistance to eovernments and 

oroanbadons In the U.Si See Part IV, line 21 

2 Grants and other assistance to individuals in 

the U.S. See Part IV, line 22 

. 3 Grmts and other assistance to govemments, 

organizations, and individuals outside the U.S. 

See Part IV, Rnes 15 and 16 . 

4 Benefits paid to or lor memtjeis 

trustees, and key employees . .. 

6 Compensation not Included above, to dsqualdled 

persons (as defined under section 49S8(I)(1)) and 

persons described in section 4958(c)(3KB) 

7 Other salaries and vrages 

8 Pension plan contributions (include section 401(i() 

and section 403(b) employer contributions) 

6 Other employsa benefits 

10 Payroll taxes 

11 Fees for services (norvemployees): 

e Management 

1 Grants and other assistance to eovernments and 

oroanbadons In the U.Si See Part IV, line 21 

2 Grants and other assistance to individuals in 

the U.S. See Part IV, line 22 

. 3 Grmts and other assistance to govemments, 

organizations, and individuals outside the U.S. 

See Part IV, Rnes 15 and 16 . 

4 Benefits paid to or lor memtjeis 

trustees, and key employees . .. 

6 Compensation not Included above, to dsqualdled 

persons (as defined under section 49S8(I)(1)) and 

persons described in section 4958(c)(3KB) 

7 Other salaries and vrages 

8 Pension plan contributions (include section 401(i() 

and section 403(b) employer contributions) 

6 Other employsa benefits 

10 Payroll taxes 

11 Fees for services (norvemployees): 

e Management 20,000. 20,000. 

b Legal 

c Accounting 

b Legal 50,000. 50,000. 

c Accounting 

d Lobbying 

e Professkmal fundraisino services. See Part IV, line 17 

f Investment management fees 

g Other 

12 Advertising and promotion 

13 Office expenses 

d Lobbying 

e Professkmal fundraisino services. See Part IV, line 17 

f Investment management fees 

g Other 

12 Advertising and promotion 

13 Office expenses 

- . -V . L-' , 

d Lobbying 

e Professkmal fundraisino services. See Part IV, line 17 

f Investment management fees 

g Other 

12 Advertising and promotion 

13 Office expenses 

d Lobbying 

e Professkmal fundraisino services. See Part IV, line 17 

f Investment management fees 

g Other 

12 Advertising and promotion 

13 Office expenses 

d Lobbying 

e Professkmal fundraisino services. See Part IV, line 17 

f Investment management fees 

g Other 

12 Advertising and promotion 

13 Office expenses 

55,000. 55,000. 

d Lobbying 

e Professkmal fundraisino services. See Part IV, line 17 

f Investment management fees 

g Other 

12 Advertising and promotion 

13 Office expenses 

d Lobbying 

e Professkmal fundraisino services. See Part IV, line 17 

f Investment management fees 

g Other 

12 Advertising and promotion 

13 Office expenses 

20,000. 20,000. 

15 Royalties 

16 Occupancy 

17 Travel 

18 Payments of travel or entsitainnient expenses 

for any federal, state, or local pubHe officials 

15 Royalties 

16 Occupancy 

17 Travel 

18 Payments of travel or entsitainnient expenses 

for any federal, state, or local pubHe officials 

15 Royalties 

16 Occupancy 

17 Travel 

18 Payments of travel or entsitainnient expenses 

for any federal, state, or local pubHe officials 

15 Royalties 

16 Occupancy 

17 Travel 

18 Payments of travel or entsitainnient expenses 

for any federal, state, or local pubHe officials 

15 Royalties 

16 Occupancy 

17 Travel 

18 Payments of travel or entsitainnient expenses 

for any federal, state, or local pubHe officials 

20 Interest .. .. 

21 l>ayments to affifiatas 

23 Insurance 

24 Ottier expenses, itemize expenses not covered 

above. (List miscellaneous expenses in One 241. If line 

241 amoum exceeds 10% of line 25, column (A) 

amourn, bst line 24f expenses on Schedule a) 

20 Interest .. .. 

21 l>ayments to affifiatas 

23 Insurance 

24 Ottier expenses, itemize expenses not covered 

above. (List miscellaneous expenses in One 241. If line 

241 amoum exceeds 10% of line 25, column (A) 

amourn, bst line 24f expenses on Schedule a) 

20 Interest .. .. 

21 l>ayments to affifiatas 

23 Insurance 

24 Ottier expenses, itemize expenses not covered 

above. (List miscellaneous expenses in One 241. If line 

241 amoum exceeds 10% of line 25, column (A) 

amourn, bst line 24f expenses on Schedule a) 

20 Interest .. .. 

21 l>ayments to affifiatas 

23 Insurance 

24 Ottier expenses, itemize expenses not covered 

above. (List miscellaneous expenses in One 241. If line 

241 amoum exceeds 10% of line 25, column (A) 

amourn, bst line 24f expenses on Schedule a) 

20 Interest .. .. 

21 l>ayments to affifiatas 

23 Insurance 

24 Ottier expenses, itemize expenses not covered 

above. (List miscellaneous expenses in One 241. If line 

241 amoum exceeds 10% of line 25, column (A) 

amourn, bst line 24f expenses on Schedule a) 

• 

• 

• MEDIA PLACEMENT 4,319,825. 4,319,825. -

b MEDIA PRODUCTION 275,000. 275,000. 

c WEBSITE MAINTENANCE 25,000. 25,000. 

d ECONOMIC RESEARCH 5,000. 5,000. 

e COPYRIGHT FEES l7i. 175. 

f AO otfier expenses 

4 •'770""DD0" 0 • 4 'lib flOO. Q. 

28 Joint costs. (2ieck here ^ I_J iffOOowmoSOP 

98-2 (ASC 958-720). Complete this line only d the 

organaatlon reported in column (8) jouit costs from a 

combined educatnnai campaign and fundraising 

solicitstnn 

Vf/fVfWwV* V • V f t 1 M t w W • w • 

03»I0 12-21-10 Rmn 990 (2010) 

Attachment B 
Form 990 (201 

liTflfJ ^Riit 

COMMISSION ON HOPE, GROWTH & OPPORTONITY 27-1920168 Page 11 

(A) 

Beginning of year 

(B) 

End of year 

1 Cash-noiHnterest-tieaiing 51,000. 

2 Savings and temporary cash Investments 

3 Pledges and grants receivable, net 

4 Accounts receivable, net 

5 Receivables from current and fbnner officers, directors, trustees, key 

employees, and highest compensated employees. Complete Part II 

ofScheduleL 

6 Receivables from other disqualified persons (as defined under section 

4958(()(1)), persons described in section 49S8(c)(3)(B), and contributing 

employers and sponsoring organizations of section 501(c)(9) voluntary 

employees'beneficiary organizations (sea instructions) 

7 Notes and loans receivable, net 

8 Inventories for sale or use 

9 Prepaid expenses and deferred charges 

10a Land, buildings, and equipment: cost or ottier 

basis. Complete Part VI of Schedule D 

b Less: accumulated depreciatlcn ... 

11 Investments-publicly traded securities 

12 Investments • other secunties. See Part IV, line 11 

13 Investments-prograrrHelated. See Pari IV, line 11 

14 Intangible assets 

15 Other assets. See Part IV, line 11 

18 Total assets. Add lines Itfirouoh 15 (must equal line 341 

10a 

lOi 10c 

11 

12 

13 

14 

15 

JS. 51.000. 

17 20,000. 

18 

19 

20 

21 

22 

24 

25 

S. 

Accounts payable arxf accrued expenses 

Grants payable 

Deferred revenue 

Tax-exempt bond nablSties 

Escrow or custodial account liability. Complete Part IV of Schedule 0 

Payables to current and fonner officers, directors, trustees, key employees, 

highest compensated employees, and disqualifiBd persons. Complsts Part II 

ofSchediHaL 

Secured mortgages and notes payable to unrelated third parties 

Unsecured notes and bans payable to unrelated third parties 

Other liabirities.Cotrsilete Part X of Schedule D .. 

Total llabllltfea. Add Bnes 17 throuoh 25 

17 

18 

19 

20 

21 

22 

24 

Organlzatlansttiatldllow SPAS 117, check here ^ I I and eompletr^ 

20,000. 

27 

30 

31 

34 

txi'. 

lines 27 through 28^ and lines 33 and 34. 

UnresMctad net assets 

Temporanly restricted net assets 

Permanently restrlcied net assets 

OrganlnMons that do not follow SPAS 117, check here ^ 

complete lines 30 through 34. 

Capital stock or trust prfndpaL or current funds 

Paidin or capital surplus, or land, txiilding, or equipment fund 

Retained earnings, endowment, tmcumulated income, or other funds 

Total net assets or fund balances 

Total liablHIes and net assetsffiind balances 

27 

28 

and 

30 

31 

32 

33 

34 

0. 

TTT 

31,000. 

31,000. 

51.000. 

Fonn 990(201(9 

032011 12-31-10 

Attachment B 
Form990gOlO) COMMISSION ON HOPE, GROWTH & OPPORTUNITY 

1 Part XII Reconciliation of Net Assets 

27-1920168 Page12 

Check If Schedule 0 contains a response to any question in this Part XI • 

1 Total revenue (nust equal Part Vlil, column (A), line 12) 1 4,801,000. 

2 Total expenses (must equal Part IX, column (A), Gne 25). 

3 Revenue less expenses. Subtrect line 2 from line 1 

4 Net assets or fund balances at beginning of year (must equal Part X. Una 33, column (A)) ... 

5 Other changes In net assets or fund balances (explain in Schedule Q) 

6 Net assets or lUnd balances at end of year. Combine lines 3,4, and 5 (must equal Pert X line 33, column (B)) 

2 Total expenses (must equal Part IX, column (A), Gne 25). 2 4,770,000. 

3 Revenue less expenses. Subtrect line 2 from line 1 

4 Net assets or fund balances at beginning of year (must equal Part X. Una 33, column (A)) ... 

5 Other changes In net assets or fund balances (explain in Schedule Q) 

6 Net assets or lUnd balances at end of year. Combine lines 3,4, and 5 (must equal Pert X line 33, column (B)) 

3 31,66O. 

2 Total expenses (must equal Part IX, column (A), Gne 25). 

3 Revenue less expenses. Subtrect line 2 from line 1 

4 Net assets or fund balances at beginning of year (must equal Part X. Una 33, column (A)) ... 

5 Other changes In net assets or fund balances (explain in Schedule Q) 

6 Net assets or lUnd balances at end of year. Combine lines 3,4, and 5 (must equal Pert X line 33, column (B)) 

4 0. 

2 Total expenses (must equal Part IX, column (A), Gne 25). 

3 Revenue less expenses. Subtrect line 2 from line 1 

4 Net assets or fund balances at beginning of year (must equal Part X. Una 33, column (A)) ... 

5 Other changes In net assets or fund balances (explain in Schedule Q) 

6 Net assets or lUnd balances at end of year. Combine lines 3,4, and 5 (must equal Pert X line 33, column (B)) 

5 0. 

2 Total expenses (must equal Part IX, column (A), Gne 25). 

3 Revenue less expenses. Subtrect line 2 from line 1 

4 Net assets or fund balances at beginning of year (must equal Part X. Una 33, column (A)) ... 

5 Other changes In net assets or fund balances (explain in Schedule Q) 

6 Net assets or lUnd balances at end of year. Combine lines 3,4, and 5 (must equal Pert X line 33, column (B)) 6 31,000. 

Part Xlll Financial Statements and Reporting 

Check if Schedule 0 contains a resporae to any gueslion In this Part XII. 

1 Accounting method used to prepare the Form 990: (SI Cash CZDAcctual d] Other 

2a 

b 

c 

It the organization charrged its method of accounting llnom a prior year or checked 'Other,* explein in Scfwdule O. 

Were the organization's financial statements compiied or reviewied by an indepandent accountant? 

were tfw organization's financlai statements audited by an Independent accountant? 

if 'Yes' to line 2a or 2b, does die organization have a committee that assumes responsibility for oversigtit of the audit, 

review, or oompilatian of its financlai statements and selection of an Independant accountant? 

If the organization changed elttier its oveislght process or selection process during the tax year, explain in Schedule O. 

If 'Yes* to line 2a or 2b, check a box below to indicate whether the financlai statemente for the year were issued on a 

basis, consolidated basis, or both: 

d] Consolidated basis dD Both consolidated and eeparate basis 

3a As a result of a federal award, was the organization required to undergo an audit or audits as set forth In the Single Audit 

ActandOMBarcularA-133? 

b If 'Yes,* did ttw organization undergo ttie required audit or audits? If the organlzabon did not undergo the lequiied audit 

or audits, exolaln why In Schedule O and describe anv steps taken to underno such audits 

2b 

2c 

Yea No 

X 

Form 990 goto) 

032012 t^21•IO 

Attachment B 
SCHEDULE 0 

(Form990cr990-EZ) 

Dapvtmam Of ttie Tfwwv 

Supplemental Information to Form 990 or 990-EZ 

Complete to provide Informatioii for reeponsee to speolfle questions on 

Farm 990 or 990-EZ or to provtds any additional Information. 

• Attach to Form 900 or 990-EZ. 

SCHEDULE 0 OMBNa154M047 

(Form990cr990-EZ) 

Dapvtmam Of ttie Tfwwv 

Supplemental Information to Form 990 or 990-EZ 

Complete to provide Informatioii for reeponsee to speolfle questions on 

Farm 990 or 990-EZ or to provtds any additional Information. 

• Attach to Form 900 or 990-EZ. 

2010 

..OpentoPutiUo 

' InapeMon 

Name of the organization 

COMMISSION ON HOPE, GROWTH & OPPORTUNITY 

Employer 

27-1 

IdentMoation number 

920168 

FORM 990, PART I, LINE 1, DESCRIPTION OF ORGANIZATION MISSION; 

NECESSARY TO AMERICA'S ECONOMIC FUTURE AND THAT PUBLIC POLICY MAKERS 

MUST UNDERSTAND AND MAKE A COMMITMENT TO THIS PRINCIPLE. THE COMMISSION 

WILL ENGAGE ECONOMIST'S AND OTHER BUSINESS EXPERTS TO INFORM ITS 

UNDERSTANDING OF THE NECESSITY FOR SUSTAINED ECONOMIC GROWTH AND WILL 

BRING THE FRUITS OF THIS EXPERTISE AND RESEARCH DIRECTLY TO THE 

ATTENTION OF DECISION MAKERS AT ALL LEVELS OF GOVERNMENT. THE 

COMMISSION WILL COMMUNICATE ITS PUBLIC WELFARE MESSAGE ON THE ISSUE OF 

SUSTAINED ECONOMIC EXPANSION TO THE PUBLIC THROUGH ALL FORMS OF MASS 

COMMUNICATION, INCLUDING, BUT NOT LIMITED TO, PRINT. ADVERTISING, CABLE 

TELEVISION AND RADIO MESSAGING, AS WELL AS E-MAIL AND DIRECT MAIL 

COMMUNICATIONS. 

FORM 990, PART III, LINE 1, DESCRIPTION OF ORGANIZATION MISSION; 

THE COMMITMENT OF THESE POLICY MAKERS TO IMPLEMENT STATUTES, RULES AND 

REGULATIONS THAT ARE CONSISTENT WITH FREE-MARKET PRINCIPLES AND THAT 

ADHERE ECONOMIC GROWTH AND EXPANSION. 

FORM 990, PART V, LINE SB; N/A 

FORM 990, PART VI, SECTION A, LINE 8A; N/A 

FORM 990, PART VI, SECTION A, LINE SB; N/A 

FORM 990, PART VI, SECTION B, LINE 11; N/A 

LHA FiirPaperwi>1(RedUellanAclNatiee,8aetheliistoucliamtarFann990iir990A Schedule O (Form 990 or saO-EZ) (2010) 

Attachment B 
Sdi9dtJdOfFeini990or990€at201(n p«qe2 

Name of the organization I Employer IdentificBtlan number 

.J COMMISSION ON HOPE, GROWTH & OPPORTUNITY I 27-1920168 

FORM 990, PART VI. SECTION C, LINE 19; INFORMATION IS AVAILABLE AT THE 

ORGANIZATION'S OFFICE LOCATION UPON REQUEST. 

4 

MMIi 

01-24-11 Schedule O (Form 980or 9Bfr€Z) (2010) 

Attachment B 
Foinia8M(Rev.1-201H Paae2 

• If you are firing for an Additional (Not Automatlel 3-Monti« Extension, complete only Part II and cfieck this box . • lil 

N(^ Only complete Part II If you have already been granted an automaUc 5month extension on e previously filed Fomn 8868.. 

• If you are filing for an Automatic 3-Month Extension, complete only Part I ( 

IfTilll ime. Only file the original (no copies needed). 

Type or 

print 

nitbySH 

Name of exempt organizatiGn 

COMMISSION ON HOPE, GROWTH & OPPORTUNITY 

Employer Identification number 

27-1920168 

Hingyow 

reton-Sw 

Number, street, and room or suite na If a P.O. box, sea ratnictions. 

1900 M STREET, NW, NO. 600 

City, town or post office, state, and ZIP coda For a foreign address, see instructions. 

WASHINGTON, DC 20036 

Enter the Return code for the return that this application Is for (file a separate application for each return) I 0 111 

Appllcadon Return Mppucmon Return 

IsFor Code Is For Code 

Form 990 01 

FdrmOOOBL 02 Form 1041A 08 

Fonn990EZ 03 Fomi4720 09 

Fonn990PF 04 Form 5227 10 

Fomn 990T (sec. 401 (d or 408(a) tnrst) 05 Form 6069 11. 

Form 990-T(tnjst other than above) 08 Form 8870 12 

STOP! Do not comolete Part II If vou were not 

STEVI~~ P 

• the books are In the care of • 1900 M STREET - WASHINGTON, DC 20036 

TeiephonoNo.^ 202-530-3332 FAXNo.» 

• If the organization does not have an office or place of busoressin the United States, check this box 

• If this Is fw e Group Return, enter the orqanizatKin's four 

box» •.lfitisforpartoftheQtoup.checkthisbox»l—I andattacha 

4 I request an additional Smonth extension of time unto NOVEMBER 

5 For calendar year 2010 .or other tax year treoinning 

6 If ttre tax year entered m line 5 Is for less than 12 mdnttrs, check reason: 

d] Change In accounting period 

• • 

. If this is for the whole group, check this 

, and ending 

J Initial return L_1 Hnal return 

State in detail why you need the extension 

ADDITIONAL TIME IS NEEDED TO GATHER THE INFORMATION NECESSARY TO FILE A 

COMPLETE AND ACCURATE RETURN. 

8a If this appficabon is for Form 99061. 990PF, 990-7,4720, or6069, enter the tentative tax, lass any 

nonrefundatrie credits. See Instnrctions. 8a 

If this appfication is for Form 990PF, 990T, 4720, or 8069, enter any refundable credits and estimated 

tax payments made. Include any pnor year overpayment allowBd as a credit and any amount paid 

previously with Form 8666. 

c Balance due. Subtract line 8b from line 8a. Include your paymerrt with this fbmi. If required, by using 

EFTPS (Bectronic Federal Tax Payment System). See Instnictions. 8c 0. 

Signature and Verification 

Under penalties of penury, I declare that I have examined this form. Including accompanying schedules and statements, and to the best of my knowledge and belief. 

It B true, correct, and complete, and that I am authorized to prepare this form. 

Signature • ^^^TiMe • Dale • (11/W («I 

Form 8868 (Rev. 1-2011) 

?SSi 

Attachment B 
ATTACHMENT C 

I CHGO's Tax Return for Calendar Year 2011 

4 

(IRS Form 990) 
lefile GRAPHIC rint - DO NOT PROCESS I As Filed Data - I DLN:934931260060121 

For^990 

s 

DGpounent of the Treasuy 

tfliemal Reranue Seiv«ce 

Return of Organization Exempt From Income Tax 

under section 501(c), 527, or 4947(s)(l) of the Internal Revenue Code (except black lung 

benefit trust or private foundation) 

b- The organization may have to use a copy of this return to satisfy state reporting requirements 

OMBNo 1S4S-0047 

2011 

A For the 2011 calenc 

0 Check If applicable 

f Address change 

Name change 

f~ Initial return 

F Terminated 

F Amended return 

F Application pending 

^r tax \ 

C Name of organization 

COMMISSION ON HOPE GROWTH & OPPORTUNITY 

I Ql-01-2011 and ending 12-31-2011 

Doing Business As 

THE COMMISSION 

Number and street <or P 0 box if mail e not delivered to street address) 

1900 M STREET NW NO 600 

City or town, state orcoumty, and ZIP « 4 

WASHINGTON, DC 20036 

Room/suite 

27-1920168 

Ication number 

E Telephone number 

(202)530-3332 

G Gross receipts $ 0 

F Name and address of principal officer 

J STEPHEN POWELL 

1900 M STREET NW 

WASHINGTON,DC 20036 

J Tax-exempt status F S0l(c)(3) F 501(c) ( 4 ) ^ (insert no ) F 4947(a)(1) or F 527 

; Website: • WWW HOPEGROWTHOPPORTUNITY COM 

^ 

K Form of organaation F Corporatcn |~ Trust F" Assocetx>n |~ Other • 

Summary 

H(a) Is this a group return for 

affiliates' F Yes F No 

H(b) Are all affiliates Included? F Yes F No 

If No," attach a list (see instructions) 

H(c) Group exemption number ^ 

I L Year of formation 2010 | M State of legal domnle X 

Briefly describe the organization^ mission or most significant activities 

THE COMMISSION BELIEVES AND INTENDS TO INFORM THE AMERICAN PUBLIC THAT ECONOMIC EXPANSION IS 

NECESSARY TO AMERICA'S ECONOMIC FUTURE AND THAT PUBLIC POLICY MAKERS MUST UNDERSTAND AND MAKE A 

COMMITMENT TO THIS PRINCIPLE THE COMMISSION WILL ENGAGE ECONOMIST'S AND OTHER BUSINESS EXPERTS 

TO INFORM ITS UNDERSTANDING OF THE NECESSITY FOR SUSTAINED ECONOMIC GROWTH AND WILL BRING THE 

FRUITS OF THIS EXPERTISE AND RESEARCH DIRECTLY TO THE ATTENTION OF DECISION MAKERS AT ALL LEVELS OF 

GOVERNMENT THE COMMISSION WILL COMMUNICATE ITS PUBLIC WELFARE MESSAGE ON THE ISSUE OF SUSTAINED 

ECONOMIC EXPANSION TO THE PUBLIC THROUGH ALL FORMS OF MASS COMMUNICATION. INCLUDING, BUT NOT 

LIMITED TO, PRINT; ADVERTISING, CABLE TELEVISION AND RADIO MESSAGING, AS WELL AS E-MAIL AND DIRECT 

MAIL COMMUNICATIONS 

2 C heck this box bp* if the organization discontinued its operations or disposed of more than 25% of its 

3 Number of voting members of the governing body (Part VI, line la) .... 

4 Number of independent voting members of the governing body (Part VI, line lb) .... 

5 Total number of individuals employed in calendar year 2011 (Part V, line 2a) . 

6 Total number of volunteers (estimate if necessary) .... 

7a Total unrelated business revenue from Part Vlll, column (C). line 12 . . 

b Net unrelated business taxable income from Form 990-T, line 34 . . 

net assets 

3 

s 

I 

8 Contributions and grants (Part VIII, line Ih) 

9 Program service revenue (Part VIII, line 2g) 

10 Investment income (Part VIII, column (A), lines 3, 4, and 7d ) .... 

11 Other revenue (Part VIII, column (A), lines 5, 6d, Be, 9c, lOc, and lie) 

12 Total revenue—add lines 6 through 11 (must equal Part VlII, column (A), line 

12) . . : 

Prior Year 

4,801,000 

4,801,000 

Current Year 

& 

iS 

13 Grants and similar amounts paid (Part IX, column (A), lines 1-3 ) . . . 

14 Benefits paid CO or for members (Part IX, column (A), line 4) .... 

15 Salaries, other compensation, employee benefits (Part IX, column (A), lines 

5-10) 

16a Professional fundraismg fees (Part IX,column (A), line lie) .... 

b Total fundraising expenses (Part K. column (D), fane 25) 

17 Other expenses (Part IX, column (A), lines 1 la-lld, llf-24e) . . . . 

18 Total expenses Add lines 13-17 (mustequal Part IX, column (A), line 25) 

19 Revenue less expenses Subtract line 18 from line 12 

4,770,000 31,000 

4,770,000 31,000 

31,000 -31,000 

Beglni ing of Current 

Year End of Year 

20 Total assets (Part X. line 16) 

21 TotaMiabiiities (Part X. line 26) 

22 Net assets orfund balances Subtract line 21 from line 20 

51,000 

20,000 

31,000 

Signature Block 

Under penalties of perjury. 1 declare that 11 

knowledge and belief It Is Crv^ correct, and complete. Declaration of preparer (other than officer) Is based 

knowledge. 

this return. Including accompanying schedules and statements, and 

on Ul Information 

to the best of my 

of which preparo- has any 

Sign 

Here 

Signature of offcer 

) STePHEN powea PRCSIDENT y EXECUTIVE DIRECTOR 

I 7017 05-M 

' Type or pnnt name and title 

Paid 

Preparei's 

Use Only 

Preparer's L 

signature W )AMES D WARRING CPA 

Date Check If 

SGirempbyed fa F 

Preparer's taxpayer identification rwmbcr 

(see instnjaons) Paid P00173611 

Preparei's 

Use Only 

Firm's name (or yours k WARRING A COMPANY UC CPAS 

If self-empbyed). i EIN fa 51-0608962 

Paid 

Preparei's 

Use Only address, and ZIP + 4 ' n NORTH WASHINGTON ST SUITE 720 

ROCKVOlf. MD 20850 Phone no fa (301) 260-0809 

May the IRS discuss this return with the preparer shown above' (see instructions) . . 

Attachment C 

F Yes r No 

for Paperwork Reduction Act Notice, see the separate Instructions. Cat No il282Y Form 990 (2011) 
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Form 990 (2011) Page 3 

Checklist of Required Scheduies 

2 

3 

4 

5 

4 ' 

10 

11 

Is the organization described in section 501(c)(3) or 4947(a)(1) (other than a private foundation)? If "Yes," 

complete Schedule A 

Is the organization required to complete Schedules, Schedule of Contnbutors{see instructions)? 

Did the organization engage in direct or indirect political campaign activities on behalf of or in opposition to 

candidates for public office? If "Yes,"complete Schedule C, Part I 

Section 501(c)(3) organizations. Did the organization engage in lobbying activities, or have a section 501(h) 

election in effect during the tax year? If "Yes,"complete Schedule C, Part II 

Is the organization a section 501(c)(4), 501(c)(5), or 501(c)(6) organization that receives membership dues, 

assessments, or similar amounts as defined in Revenue Procedure 98-19? ff "Yes,"complete Schedule C, Part 

III 

Did the organization maintain any donor advised funds or any similar funds or accounts for which donors have the 

right to provide advice on the distribution or investment of amounts in such funds or accounts? If "Yes,"complete 

Schedule D, Part / 

Did the organization receive or hold a conservation easement, including easements to preserve open space, 

the environment, historic land areas or historic structures? If "Yes,"complete Schedule D, Part II .. . 

Did the organization maintain collections of works of art, historical treasures, or other similar assets? If "Yes," 

complete Schedule D, Part III 

Did the organization report an amount in Part X, line 21, serve as a custodian for amounts not listed in Part X, or 

provide credit counseling, debt management, credit repair, or debt negotiation services? If "Yes," 

complete Schedule D, Part IV 

Did the organization, directly or through a related organization, hold assets in temporarily restricted endowments, 

permanent endowments, or quasi-endowments? If "Yes,"complete Schedule D, Part V 

If the organization's answerto any of the following questions is 'Yes,'then complete Schedule D, Parts VI, VII, 

VIII, IX, or X as applicable 

a Did the organization report an amount for land, buildings, and equipment in Part X, linelO? If "Yes,"complete 

Schedule 0, Part VI. 

b Did the organization report an amount for investments—other securities in Part X, line 12 that is 5% or more of 

Its total assets reported in Part X, line 16? If "Yes,"complete Schedule D, Part VII. 

c Did the organization report an amount for investments—program related in Part X, line 13 that is 5% or more of 

Its total assets reported in Part X, line 16? ff "Yes,"complete Schedule D, Part VIII. 

d Did the organization report an amount for other assets in Part X, line 15 that is S% or more of its total assets 

reported in Part X, line 16? ff "Yes," complete Schedule D, Part IX. 

e Did the organization report an amount for other liabilities in Part X, line 25? If "Yes,"complete Schedule D, Part X. 

f Did the organization's separate or consolidated financial statements for the tax year include a footnote that 

addresses the organization's liability for uncertain tax positions under FIN 48 (ASC 740)? If "Yes,"complete 

Schedule D, Part X. 

12a Did the organization obtain separate, independent audited financial statements forthe tax year? If "Yes,"complete 

Schedule D, Parts XI, XII, artd XIII 

b Was the organization included in consolidated, independent audited financial statements for the tax year? If 

"Yes," and if the organization ans vtered 'No' to line 12a, then complying Schedule D, Parts XI, XII, and XIII is optional 

13 Is the organization a school described in section 170(b)(l)(A)(ii)? If "Yes,"complete Schedule E 

14a Did the organization maintain an office, employees, or agents outside ofthe United States? .... 

b Did the oiganizaton have aggregate revenues or expenses of more than $10,000 from grantmaking, fundraising, business, investment, 

and program servne activities outside the United States, or aggregate foreign investments valued at $100,000 or more? If "Yes," complete 

Schedule F, Parti 

Did the organization report on Part IX, column (A), line 3, more than $5,000 of grants or assistance to any 

organization or entity located outside the U S ? If "Yes,"complete Schedule F, Part II and IV . 

Did the organization report on Part IX, column (A), line 3, more than $5,000 of aggregate grants or assistance to 

individuals located outside the U S ? /F "Yes,"complete Schedule F, Part III and IV . . 

Did the organization report a total of more than $15,000, of expenses for professional fundraising services on 

Part IX, column (A), lines 6 and lie? If "Yes," compile Schedule G, Part I 

Did the organization report more than $15,000 total of fundraising event gross income and contributions on Part 

VIII, lines Ic and 8a? If "Yes,"complete Schedule G, l^rt II 

Did the organization report more than $15,000 of gross income from gaming activities on Part VIII, line 9a? If 

"Yes," complete Schedule G, Part III 

20a Did the organization operate one or more hospitals? If "Yes,"ctmplete Schedule H 

15 

16 

17 

18 

19 

b If "Yes' to line 20a, did the organization attach its audited hna 

filers that operated one or more hospitals must attach audited fin'anTilf sta't'emenis 

IS return? Note. All Form 990 

Yes No 

1 

No 

2 No 

3 

No 

4 

5 No 

6 No 

7 No 

a No 

9 No 

10 No 

11a No 

lib No 

11c No 

lid No 

lie No 

llf No 

12a No 

12b No 

13 No 

14a No 

14b No 

15 No 

16 No 

17 No 

18 No 

19 No 

20a No 

20b 

Form 990 (2011) 
Form 990 (2011) 

KSBn^n Checklist of Required Schedules (continued) 

21 Did the organization report more than $5,000 of grants and other assistance to governments and organizations in 

the United States on Part IX, column (A), line if If "Yes," complete Schedule I, Parts I and II . 

22 Did the organization report more than $5,000 of grants and other assistance to individuals in the United States 

on Part IX, column (A), line 2' If "Yes.'complete Schedule I,.Parts I and III 

23 Did the organization answer "Yes" to Part VII, Section A, questions 3, 4, or 5, about compensation of the 

organization's current and former officers, directors, trustees, key employees, and highest compensated 

employees? If "Yes," complete Schedule J 

24a Did the organization have a tax-exempt bond issue with an outstanding principal amount of more than $100,000 

as of the last day of the year, that was issued after December 31, 2002?/f "Yes,'answerguesf/ons 24b-24tY and 

complete Schedule K. If "No,"go to line 25 

b Did the organization invest any proceeds of tax-exempt bonds beyond a temporary period exception? . 

c Did the organization maintain an escrow account other than a refunding escrow at any time during the year 

to defease any tax-exempt bonds? 

d Did the organization act as an "on behalf of issuer for bonds outstanding at any time during the year? . 

25a Section 501(c)(3) and 501(c)(4) organizations. Did the organization engage in an excess benefit transaction with 

a disqualified person during the year? If "Yes,"complete Schedule L, Part I 

b Is the organization aware that it engaged in an excess benefit transaction with a disqualified person in a prior 

year, and that the transaction has not been reported on any of the organization's prior Forms 990 or 990-EZ? If 

"Yes," complete Schedule L, Part I 

26 Was a loan to or by a current or former officer, director, trustee, key employee, highly compensated employee, or 

disqualified person outstanding as of the end of the organization's tax year? If "Yes,"complete Schedule L, 

Part II 

27 Did the organization provide a grant or other assistance to an officer, director, trustee, key employee, substantial 

contributor, or a grant selection committee member, or to a person related to such an individual? If "Yes," 

complete Schedule L, Part III 

28 Was the organization a party to a business transaction with one of the following parties? (see Schedule L, Part IV 

instructions for applicable filing thresholds, conditions, and exceptions) 

a A current or former officer, director, trustee, or key employee? If "Yes," complete Schedule!, Part 

IV 

b A family member of a current or former officer, director, trustee, or key employee? If "Yes," 

complete Schedule L, Part IV 

c An entity of which a current or former officer, director, trustee, or key employee (ore family member thereof) was 

an officer, director, trustee, or owner? If "Yes," complete Schedule L, Part IV . 

29 Did the organization receive more than $25,000 in non-cash contributions? If "Yes,"complete Schedule M 

30 Did the organization receive contributions of art, historical treasures, or other similar assets, or qualified 

conservation contributions? If "Yes,"complete Schedule M 

31 Did the organization liquidate, terminate, or dissolve and cease operations? If "Yes,"complete Schedule N, 

Parti ® 

32 Did the organization sell, exchange, dispose of, or transfer more than 25% of its net assets? If "Yes,"compile 

Schedule N, Part II "S 

33 Did the organization own 100% of an entity disregarded as separate from the organization under Regulations 

sections 301 7701-2 and 301 7701-3? If "Yes,"complete Schedule R, Part I 

34 Was the organization related to any tax-exempt or taxable entity? If "Yes,"complete Schedule R, Parts II, III, IV, 

and V, line I 

35a Is any related organization a controlled entity of the filing organization within the meaning of section 512(b)(13)? 

b Did the organization receive any payment from or engage in any transaction with a controlled entity within the 

meaning of section 512(b)(l 3)? /f "Yes,"complete Schedule R, Part V, line 2 .. . 

36 Section 501(c)(3) organizations. Did the organization make any transfers to an exempt non-chantable related 

organization? If "Yes,"complete Schedule R, /brt V, line 2 

37 Did the organization conduct more than 5% of its activities through an entity that is not a related organization 

and that is treated as a partnership fbr federal income tax purposes? If "Yes,"complete Schedule R, Part VI 

38 Did the organization complete Schedule O and provide explanaAttSSlSfTi^int CforPart VI, lines 11 and 19? 

Note. All Form 990 filers are required to complete Schedule O 

Page 4 

21 No 

22 No 

23 No 

24a No 

24b 

24c 

24d 

25a No 

25b No 

26 No 

27 No 

28a No 

28b No 

28c No 

29 No 

30 No 

31 Yes 

32 No 

33 No 

34 No 

35a No 

35b No 

36 

37 No 

38 Yes 

Form 990(2011) 
Form 990 (2011) Page 5 

Statements Regarding Other IRS Filings and Tax Compliance 

Check if Schedule 0 contains a response to any question in this Part V .r 

la Enter the number reported in Box 3 of Form 1096 Enter -0- if not applicable 

b Enter the number of Forms W-2G included in line la Enter-0- if not applicable 

la 

lb 

c Did the organization comply with backup withholding rules for reportable payments to vendors and reportable 

gamrng (gambling) winnings to prize winners? 

2a Enter the number of employees reported on Form W-3, Transmittal of Wage and Tax 

Statements hied for the calendar year ending with or within the year covered by this 

return 

b If at least one is reported on line 2a, did the organization file all required federal employment tax returns' 

Note. If the sum of lines la and 2a is greater than 250, you may be required to e-ftle (see instructions) 

la Did the organization have unrelated business gross income of $1,000 or more dunng the 

year' 

b If "Yes," has it filed a Form 990-T for this year' If "No,"provide an explanation in Schedule O 

b At anytime dunng the calendar year, did the organization have an interest in, or a signature or other authonty 

over, a financial account in a foreign country (such as a bank account or secunties 

account)' 

5a 

b 

c 

13 

If "Yes," enter the name of the foreign country • 

See instructions for hiing requirements for Form TD F90-22 1, Report of Foreign Bank and Financial Accounts 

Was the organization a party to a prohibited tax shelter transaction at any time during the tax year' . . 

Did any taxable party notify the organization that it was oris a party to a prohibited tax shelter transaction' 

If "Yes" to line 5a or 5b, did the organization file Form 88B6-T' 

Does the organization have annual gross receipts that are normally greater than $ 100,000, and did the 

organization solicit any contributions that were not tax deductible' 

If "Yes," did the organization include with every solicitation an express statement that such contributions or gifts 

were not tax deductible' 

Organizations that may receive deductible contributions under section 170(c). 

Did the organization receive a payment in excess of $75 made partly as a contribution and partly for goods and 

services provided to the payor' 

If "Yes," did the organization notify the donor of the value of the goods or services provided' 

Did the organization sell, exchange, or otherwise dispose of tangible personal property for which it was required to 

file Form 8282' 

If "Yes," indicate the number of Forms 8282 filed during the year .... | 7d | 

Did the organization receive any funds, directly or indirectly, to pay premiums on a personal benefit 

contract' 

Did the organization, during the year, pay premiums, directly or indirectly, on a personal benefit contract' . 

If the organization received a contribution of qualified intellectual property, did the organization hie Form 8899 as 

required' 

If the organization received a contribution of cars, boats, airplanes, or other vehicles, did the organization hie a 

Forml098-C' 

Sponsoring organizations maintaining donor advised funds and section S09(a)(3) supporting organizations. Did 

the supporting organization, or a donor advised fund maintained by a sponsoring organization, have excess 

business holdings at any time during the year' 

Spo I organizations maintaining donor advised funds. 

a 

b 

10 

11 

Did the organization make any taxable distributions under section 4966' ... 

Did the organization make a distnbutioh to a donor, donor advisor, or related person' 

Section 501(c)(7) organizations. Enter 

Initiation fees and capital contributions included on Part VIII, line 12 . 

Gross receipts, included on Form 990, Part VIII, line 12, for public use of club 

facilities 

Section 501(c)(12) organizations. Enter 

Gross income from members or shareholders 

Gross income from other sources (Do not net amounts due or paid to other 

sources against amounts due or received from them ) 

10a 

10b 

11a 

lib 

12b 

12a Section 4947(a)(1) non-exempt charitable trusts. Is the organization filing Form 990 in lieu of Form 1041' 

b If "Yes," enter the amount of tax-exempt interest received or accrued during the 

year 

Section 501(c)(29) quaiified nonprofit health insurance issuers. 

Is the orgaiiization licensed to issue qualihed health plans in more than one state' 

Note. All 501(c)(29) organizations must list in Schedule D each state in which they are licensed to issue 

qualified health plans, the amount of reserves required by each state, and the amount of reserves the organization 

allocated to each state 

Enter the aggregate amount of reserves the organization is required to maintain by 

the states in which the organization is licensed to issue qualified health plans 

Enter the aggregate amount of reserves on hand 

13b 

13c 

14a Did the organization receive any payments for indoortanning year' . 

b If "Yes," has it filed a Form 7 20 to report these payments' If 'No.'piovide an explanation in Schedule 0 

Ic 

2b 

5b 

6b 

Yes No 

7e 

7f 

12a 

13a 

14a 

14b 

No 

No 

No 

No 

No 

No 

No 

No 

Form 990 (2011) 
Form 990 (2011) 

Part VI 

Page 6 

Governance, Management, and Disclosure For each "Yes" response to lines 2 through 7b below, and for 

a "No" response to lines 8a, Sb, or 10b below, describe the circumstances, processes, or changes in Schedule 

O. See instructions. 

Check if Schedule O contains a response to any question in this Part VI F 

Section A. Governing Body and Management 

lb 

la Enter the number of voting members of the governing body at the end of the tax 

year .... 

b Enter the number of voting members included m line la, above, who are 

independent . . . . i 

2 Did any officer, director, trustee, or key employee have a family relationship or a business relationship with any 

other officer, director, trustee, or key employee^ 

3 Did the organization delegate control over management duties customarily performed by or under the direct 

supervision of officers, directors or trustees, or key employees to a management company or other person? . 

4 Did the organization make any significant changes to its governing documents since the prior Form 990 was 

filed' 

5 Did the organization become aware dunng the year of a significant diversion of the organization's assets' . 

6 Did the organization have members or stockholders' 

,7a Did the organization have members, stockholders, or other persons who had the power to elect or appoint one or 

more members of the governing body' 

b Are any governance decisions of the organization reserved to (or subject to approval by) members, stockholders, 

or persons other than the governing body' . 

8 Did the organization contemporaneously document the meetings held or written actions undertaken during the 

year by the following 

a The governing body' 

b Each committee with authority to act on behalf of the governing body' 

9 Is there any officer, director, trustee, or key employee listed in Part VII, Section A, who cannot be reached at the 

organization's mailing address' If "Yes," provide the names and addresses in Schedule O 

7a 

7b 

8b 

Yes No 

No 

No 

No 

No 

No 

No 

No 

No 

No 

No 

Section B. Poiicies (This Section B requests information about policies not required by the Internal 

Revenue Code.) 

lOa Did the organization have local chapters, branches, or affiliates' 

b If "Yes," did the organization have written policies and procedures governing the activities of such chapters, 

affiliates, and branches to ensure their operations are consistent with the organization's exempt 

purposes' .... 

11a Has the organization provided a complete copy of this Form 990 to all members of its governing body before filing 

the form' 

b Describe in Schedule 0 the process, if any, used by the organization to review the Form 990 

12a Did the organization have a written conflict of interest policy' If "No,'go to line 13 

b Were officers, directors or trustees, and key employees required to disclose annually interests that could give 

rise to conflicts' 

c Did the organization regularly and consistently monitor and enforce compliance with the policy' If "Yes," describe 

in Schedule 0 how this was done 

13 Did the organization have a written whistleblower policy' 

14 Did the organization have a written document retention and destruction policy' 

15 Did the process for determining compensation of the following persons include a review and approval by 

independent persons, comparability data, and contemporaneous substantiation of the deliberation and decision' 

a The organization's CEO, Executive Director, or top management official 

b Other officers or key employees of the organization 

If "Yes," to line ISa or 15b, describe the process in Schedule 0 (see instructions) 

16a Did the organization invest in, contribute assets to, or participate in a joint venture or similar arrangement with a 

taxable entity during the year' 

b If "Yes,"did the organization follow a written policy or procedure requiring the organization to evaluate its 

participation in joint venture arrangements under applicable federal tax law, and take steps to safeguard the 

organization's exempt status with respect to such arrangements' 

10a 

10b 

11a 

12a 

12b 

12c 

13 

14 

ISa 

15b 

16a 

16b 

Yes 

Yes 

No 

No 

No 

No 

No 

No 

No 

No 

Section C. Disclosure 

17 List the States with which a copy of this Form 990 is required to be filedb18 Section 6104 requires an organization to make its Form 1023 (or 1024 if applicable), 990, and 990-T (SO 1(c) 

(3)s only) available for public inspection Indicate how you made these available Check all that apply 

|~ Own website |~ Another's website F Upon request 

19 Describe in Schedule O whether (and if so, how), the organization made its governing documents, conflict of 

interest policy, and financial statements available to the public See Additional Data Table 

20 State the name, physical address, and telephone number of the person who possesses the books and records of the organization b3 STEPHEN POWELL 

1900 M STREET A« u WASHINGTON,DC 20036 Attacnment U 

(202)530-3332 

Form 990 (2011) 
Form 990 (2011) Page 7 

Compensation of Officers, Directors,Trustees, Key Employees, Highest Compensated 

Empioyees, and Independent Contractors 

Check if Schedule 0 contains a response to any question in this Part VII f" 

Section A. Officers. Directors. Trustees. Key Employees, and Highest Compensated Empioyees 

la Complete this table for all persons required to be listed Report compensation for the calendar year ending with or within the organization's 

tax year 

• List all of the organization's current officers, directors, trustees (whether individuals or organizations), regardless of amount 

of compensation, and current key employees Enter -0- in columns (D), (E), and (F) if no compensation was paid 

* List all of the organization's current key employees, if any See instructions for definition of "key employee " 

» List the organization's five current highest compensated employees (other than an officer, director, trustee or key employee) 

who received reportable compensation (Box S of Form W-2 and/or Box 7 of Form 1099-MISC) of more than $100,000 from the 

organization and any related organizations 

* List all of the organization's former officers, key employees, or highest compensated employees who received more than $100,000 

of reportable compensation from the organization and any related organizations 

• List all of the organization's foimer directors or trustees that received, in the capacity as a former director or trustee of the 

organization, more than $10,000 of reportable compensation from the organization and any related organizations 

List persons in the following order individual trustees or directors, institutional trustees, officers, key employees, highest 

compensated employees, and former such persons 

(A) 

Name and Title 

(B) 

Average 

hours 

per 

week 

(describe 

hours 

for 

related 

organizations 

in 

Schedule 

0) 

(C) 

Position (do not check 

more than one box, 

unless person is both 

an officerand a 

director/trustee) 

(D) 

Reportable 

compensation 

from the 

organization (W2/1099-MISC) 

(E) 

Reportable 

compensation 

from related 

organizations 

(W- 2/1099-

MISC) 

(F) 

Estimated 

amount of other 

compensation 

from the 

organization and 

related 

organizations 

(A) 

Name and Title 

(B) 

Average 

hours 

per 

week 

(describe 

hours 

for 

related 

organizations 

in 

Schedule 

0) 

-I 

|| 

1 

3 

sa 

5 

2 

3 

I 

Officei 

! 

o 

g 

3-

Sa 

0,0 

3 

& 

<p 

o. 

-n 

g 

(D) 

Reportable 

compensation 

from the 

organization (W2/1099-MISC) 

(E) 

Reportable 

compensation 

from related 

organizations 

(W- 2/1099-

MISC) 

(F) 

Estimated 

amount of other 

compensation 

from the 

organization and 

related 

organizations 

(1) J STEPHEN POWEll 

PRESIDENT / EXECUTIVE DIRE 5 00 X 15,000 0 15,000 

(2) WmiAM CANFIEIO 

GENERAL COUNSEL 2 00 X 0 0 0 

iia ;nnn|en : C 

Form 990(2011) 
Form 990 (2011) 

Part VII 

Page 8 

Section A. Officers, Directors, Trustees, Key Empioyees, and Highest Compensated Empioyees (continued) 

(A) 

Name and Title 

(B) 

Average 

hours 

per 

week 

(describe 

hours 

for 

related 

organizations 

in 

Schedule 

0) 

(C) 

Position (do not check 

more than one box, 

unless person is both 

an officer and a 

director/trustee) 

(D) 

Reportable 

compensation 

from the 

organization (W2/1099-MISC) 

(E) 

Reportable 

compensation 

from related 

organizations 

(W- 2/1099-

MISC) 

(F) 

Estimated 

amount of other 

compensation 

from the 

organization and 

related 

organizations 

(A) 

Name and Title 

(B) 

Average 

hours 

per 

week 

(describe 

hours 

for 

related 

organizations 

in 

Schedule 

0) 

P i"! B S-a 

f. 

3 

1 i 

5i 

s 

g 

s 

(D 

o" 

s 

3 -

o g 

ID g 

•a 

<p 

s 

e 

i 

(D) 

Reportable 

compensation 

from the 

organization (W2/1099-MISC) 

(E) 

Reportable 

compensation 

from related 

organizations 

(W- 2/1099-

MISC) 

(F) 

Estimated 

amount of other 

compensation 

from the 

organization and 

related 

organizations 

lb Sub-Total • 

c Total from continuation sheets to Part VII, Section A . . . b 

d Total (add lines lb and Ic) . . • 15,000 • 0 15,000 

Total number of individuals (including but not limited to those listed above) who received more than 

$100,000 of reportable compensation from the organizationH) 

Did the organization list any former officer, director or trustee, key employee, or highest compensated employee 

on line la' If Yes," complete Schedule J for such individual 

For any individual listed on line 1 a, is the sum of reportable compensation and other compensation from the 

organization and related organizations greater than $150,000' If "Yes," complete Schedule J for such 

individual 

Did any person listed on line la receive or accrue compensation from any unrelated organization or individual for 

services rendered to the organization'If *Tes,'camp/eteSc/ie(/u/e7farsuc/) person ..... 

Yes No 

No 

No 

No 

Section B. Independent Contractors 

Complete this table for your five highest compensated independent contractors that received more than 

$100,000 of compensation from the organization Report compensation for the calendar year ending with 

or within the organization's tax year 

(A) 

Name and business address 

(B) 

Descnpton of services 

(C) 

Compensatnn 

2 Total number of independent contractors (including but not limitsfttt30)3EnG6t Qove) who received more than 

$100,000 of compensation from the organization bO 

Form 990(2011) 
Form 990 (2011) 

Part VIII 

Page 9 

Statement of Revenue 

(A) 

Total revenue 

(B) 

Related or 

exempt 

function 

revenue 

(C) 

Unrelated 

business 

revenue 

(0) 

Revenue 

excluded from 

tax under 

sections 

512, 513, or 

514 

E 

o'" II 

II 

la Federated campaigns . 

b Membership dues .... 

c Fundraising events .... 

d Related organizations . 

e Government giants (contnbutnns) 

f All other contnbutnns, gifts, giants, and 

similar amounts not included above 

g Noncash contributions included m 

lines la-lf $ 

h Total. Add lines la-lf . . . 

la 

lb 

Ic 

Id 

ie 

If 

f 

s 

41 

E 

Of 

o 

§ I 

2a 

b 

c 

d 

e 

f All other program service revenue 

Business Code 

Total. Add lines 2a-2f • 

s 

s 

a. 

4 

5 

6a 

b 

c 

d 

7a 

c 

d 

8a 

b 

c 

9a 

b 

c 

Investment income (including dividends, interest 

and other similar amounts) ^ 

Income from investment of tax-exempt bond proceeds . . • 

Royalties '. . . P' 

(i)Real 

Gross rents 

tess rental 

expenses 

Rental income 

or (toss) 

Net rental income or (loss) ^ 

(ii) Personal 

(i) Securities (II) Other 

Gross amount 

from sales of 

assets other 

than inventoiv 

Less cost or 

other basis and 

sales expenses 

Gam or (loss) 

Net gam or (loss) - . . . .P' 

Gross income from fundraising 

events (not including 

$ 

of contributions reported on line Ic) 

See Part IV, line 18 . . . 

Less direct expenses 

Net income or (loss) from fundraising events 

Gross income from gaming activities 

See Part IV, line 19 . . . 

Less direct expenses 

Net income or (loss) from gaming activities . 

10a Gross sales of inventory, less 

returns and allowances 

b Less cost of goods sold fa 

c Net income or (loss) from sales of inventory . 

Miscellaneous Revenue 

11a 

b 

c 

d All other revenue . . . . 

e TotaLAdd lines lla-1 Id . . 

Business Code 

12 Total revenue. See Instructions . Ayachr lyril C 

Form 990(2011) 
Form 990 (2011) Page 10 

Statement of Functional Expenses 

Section 501(c)(3)and 501(c)(4) organizations must complete all columns 

All other organizations must complete column (A) but are not required to complete columns (B), (C), and (0) 

Do not include amounts reported on lines 6b, 

7b, 8b, 9b, and 10b of Part VIII. 

(A) 

Total expenses 

(B) 

Program service 

expenses 

(C) 

Management and 

general expenses 

(D) 

Fundraising 

expenses 

1 Grants and other assistance to governments and organizations 

in the United States See Part IV, line 21 

2 Grants and other assistance to individuals in the 

United States See Part IV, line 22 

3 Grants and other assistance to governments, 

organizations, and individuals outside the United 

States See Part IV, lines 15 and 16 

4 Benefits paid to or for members 

5 Compensation of current officers, directors, trustees, and 

key employees .... 

6 Compensation not included above, to disqualified persons 

(as defined under section 4958(f)(1)) and persons 

described in section 4958(c)(3)(B) .... 

7 Other salaries and wages 

8 Pension plan contributions (include section 401 (k) and section 

403(b) employercontributions) .... 

9 Other employee benefits 

10 Payroll taxes 

11 Fees for services (non-employees) 

a Management 

b Legal 

c Accounting 

d Lobbying 

e Professional fundraising See Part IV, line 17 . 

f Investment management fees 

9 Other 

12 Advertising and promotion .... 

13 Office expenses 

14 Information technology 

15 Royalties 

16 Occupancy 

17 Travel 

18 Payments of travel or entertainment expenses for any federal, 

state, or local public officials 

19 Conferences, conventions, and meetings .... 

20 Interest 

21 Payments to affiliates 

22 Depreciation, depletion, and amortization 

23 Insurance 

24 Other expenses Itemize expenses not covered above (List 

miscellaneous expenses in line 24f If line 24f amount exceeds 10% of 

line 25, column (A)amount, list line 24fexpenses on Schedule 0 ) 

a WEBSITE MAINTENANCE 

1 Grants and other assistance to governments and organizations 

in the United States See Part IV, line 21 

2 Grants and other assistance to individuals in the 

United States See Part IV, line 22 

3 Grants and other assistance to governments, 

organizations, and individuals outside the United 

States See Part IV, lines 15 and 16 

4 Benefits paid to or for members 

5 Compensation of current officers, directors, trustees, and 

key employees .... 

6 Compensation not included above, to disqualified persons 

(as defined under section 4958(f)(1)) and persons 

described in section 4958(c)(3)(B) .... 

7 Other salaries and wages 

8 Pension plan contributions (include section 401 (k) and section 

403(b) employercontributions) .... 

9 Other employee benefits 

10 Payroll taxes 

11 Fees for services (non-employees) 

a Management 

b Legal 

c Accounting 

d Lobbying 

e Professional fundraising See Part IV, line 17 . 

f Investment management fees 

9 Other 

12 Advertising and promotion .... 

13 Office expenses 

14 Information technology 

15 Royalties 

16 Occupancy 

17 Travel 

18 Payments of travel or entertainment expenses for any federal, 

state, or local public officials 

19 Conferences, conventions, and meetings .... 

20 Interest 

21 Payments to affiliates 

22 Depreciation, depletion, and amortization 

23 Insurance 

24 Other expenses Itemize expenses not covered above (List 

miscellaneous expenses in line 24f If line 24f amount exceeds 10% of 

line 25, column (A)amount, list line 24fexpenses on Schedule 0 ) 

a WEBSITE MAINTENANCE 

1 Grants and other assistance to governments and organizations 

in the United States See Part IV, line 21 

2 Grants and other assistance to individuals in the 

United States See Part IV, line 22 

3 Grants and other assistance to governments, 

organizations, and individuals outside the United 

States See Part IV, lines 15 and 16 

4 Benefits paid to or for members 

5 Compensation of current officers, directors, trustees, and 

key employees .... 

6 Compensation not included above, to disqualified persons 

(as defined under section 4958(f)(1)) and persons 

described in section 4958(c)(3)(B) .... 

7 Other salaries and wages 

8 Pension plan contributions (include section 401 (k) and section 

403(b) employercontributions) .... 

9 Other employee benefits 

10 Payroll taxes 

11 Fees for services (non-employees) 

a Management 

b Legal 

c Accounting 

d Lobbying 

e Professional fundraising See Part IV, line 17 . 

f Investment management fees 

9 Other 

12 Advertising and promotion .... 

13 Office expenses 

14 Information technology 

15 Royalties 

16 Occupancy 

17 Travel 

18 Payments of travel or entertainment expenses for any federal, 

state, or local public officials 

19 Conferences, conventions, and meetings .... 

20 Interest 

21 Payments to affiliates 

22 Depreciation, depletion, and amortization 

23 Insurance 

24 Other expenses Itemize expenses not covered above (List 

miscellaneous expenses in line 24f If line 24f amount exceeds 10% of 

line 25, column (A)amount, list line 24fexpenses on Schedule 0 ) 

a WEBSITE MAINTENANCE 

1 Grants and other assistance to governments and organizations 

in the United States See Part IV, line 21 

2 Grants and other assistance to individuals in the 

United States See Part IV, line 22 

3 Grants and other assistance to governments, 

organizations, and individuals outside the United 

States See Part IV, lines 15 and 16 

4 Benefits paid to or for members 

5 Compensation of current officers, directors, trustees, and 

key employees .... 

6 Compensation not included above, to disqualified persons 

(as defined under section 4958(f)(1)) and persons 

described in section 4958(c)(3)(B) .... 

7 Other salaries and wages 

8 Pension plan contributions (include section 401 (k) and section 

403(b) employercontributions) .... 

9 Other employee benefits 

10 Payroll taxes 

11 Fees for services (non-employees) 

a Management 

b Legal 

c Accounting 

d Lobbying 

e Professional fundraising See Part IV, line 17 . 

f Investment management fees 

9 Other 

12 Advertising and promotion .... 

13 Office expenses 

14 Information technology 

15 Royalties 

16 Occupancy 

17 Travel 

18 Payments of travel or entertainment expenses for any federal, 

state, or local public officials 

19 Conferences, conventions, and meetings .... 

20 Interest 

21 Payments to affiliates 

22 Depreciation, depletion, and amortization 

23 Insurance 

24 Other expenses Itemize expenses not covered above (List 

miscellaneous expenses in line 24f If line 24f amount exceeds 10% of 

line 25, column (A)amount, list line 24fexpenses on Schedule 0 ) 

a WEBSITE MAINTENANCE 

1 Grants and other assistance to governments and organizations 

in the United States See Part IV, line 21 

2 Grants and other assistance to individuals in the 

United States See Part IV, line 22 

3 Grants and other assistance to governments, 

organizations, and individuals outside the United 

States See Part IV, lines 15 and 16 

4 Benefits paid to or for members 

5 Compensation of current officers, directors, trustees, and 

key employees .... 

6 Compensation not included above, to disqualified persons 

(as defined under section 4958(f)(1)) and persons 

described in section 4958(c)(3)(B) .... 

7 Other salaries and wages 

8 Pension plan contributions (include section 401 (k) and section 

403(b) employercontributions) .... 

9 Other employee benefits 

10 Payroll taxes 

11 Fees for services (non-employees) 

a Management 

b Legal 

c Accounting 

d Lobbying 

e Professional fundraising See Part IV, line 17 . 

f Investment management fees 

9 Other 

12 Advertising and promotion .... 

13 Office expenses 

14 Information technology 

15 Royalties 

16 Occupancy 

17 Travel 

18 Payments of travel or entertainment expenses for any federal, 

state, or local public officials 

19 Conferences, conventions, and meetings .... 

20 Interest 

21 Payments to affiliates 

22 Depreciation, depletion, and amortization 

23 Insurance 

24 Other expenses Itemize expenses not covered above (List 

miscellaneous expenses in line 24f If line 24f amount exceeds 10% of 

line 25, column (A)amount, list line 24fexpenses on Schedule 0 ) 

a WEBSITE MAINTENANCE 

1 Grants and other assistance to governments and organizations 

in the United States See Part IV, line 21 

2 Grants and other assistance to individuals in the 

United States See Part IV, line 22 

3 Grants and other assistance to governments, 

organizations, and individuals outside the United 

States See Part IV, lines 15 and 16 

4 Benefits paid to or for members 

5 Compensation of current officers, directors, trustees, and 

key employees .... 

6 Compensation not included above, to disqualified persons 

(as defined under section 4958(f)(1)) and persons 

described in section 4958(c)(3)(B) .... 

7 Other salaries and wages 

8 Pension plan contributions (include section 401 (k) and section 

403(b) employercontributions) .... 

9 Other employee benefits 

10 Payroll taxes 

11 Fees for services (non-employees) 

a Management 

b Legal 

c Accounting 

d Lobbying 

e Professional fundraising See Part IV, line 17 . 

f Investment management fees 

9 Other 

12 Advertising and promotion .... 

13 Office expenses 

14 Information technology 

15 Royalties 

16 Occupancy 

17 Travel 

18 Payments of travel or entertainment expenses for any federal, 

state, or local public officials 

19 Conferences, conventions, and meetings .... 

20 Interest 

21 Payments to affiliates 

22 Depreciation, depletion, and amortization 

23 Insurance 

24 Other expenses Itemize expenses not covered above (List 

miscellaneous expenses in line 24f If line 24f amount exceeds 10% of 

line 25, column (A)amount, list line 24fexpenses on Schedule 0 ) 

a WEBSITE MAINTENANCE 

1 Grants and other assistance to governments and organizations 

in the United States See Part IV, line 21 

2 Grants and other assistance to individuals in the 

United States See Part IV, line 22 

3 Grants and other assistance to governments, 

organizations, and individuals outside the United 

States See Part IV, lines 15 and 16 

4 Benefits paid to or for members 

5 Compensation of current officers, directors, trustees, and 

key employees .... 

6 Compensation not included above, to disqualified persons 

(as defined under section 4958(f)(1)) and persons 

described in section 4958(c)(3)(B) .... 

7 Other salaries and wages 

8 Pension plan contributions (include section 401 (k) and section 

403(b) employercontributions) .... 

9 Other employee benefits 

10 Payroll taxes 

11 Fees for services (non-employees) 

a Management 

b Legal 

c Accounting 

d Lobbying 

e Professional fundraising See Part IV, line 17 . 

f Investment management fees 

9 Other 

12 Advertising and promotion .... 

13 Office expenses 

14 Information technology 

15 Royalties 

16 Occupancy 

17 Travel 

18 Payments of travel or entertainment expenses for any federal, 

state, or local public officials 

19 Conferences, conventions, and meetings .... 

20 Interest 

21 Payments to affiliates 

22 Depreciation, depletion, and amortization 

23 Insurance 

24 Other expenses Itemize expenses not covered above (List 

miscellaneous expenses in line 24f If line 24f amount exceeds 10% of 

line 25, column (A)amount, list line 24fexpenses on Schedule 0 ) 

a WEBSITE MAINTENANCE 

1 Grants and other assistance to governments and organizations 

in the United States See Part IV, line 21 

2 Grants and other assistance to individuals in the 

United States See Part IV, line 22 

3 Grants and other assistance to governments, 

organizations, and individuals outside the United 

States See Part IV, lines 15 and 16 

4 Benefits paid to or for members 

5 Compensation of current officers, directors, trustees, and 

key employees .... 

6 Compensation not included above, to disqualified persons 

(as defined under section 4958(f)(1)) and persons 

described in section 4958(c)(3)(B) .... 

7 Other salaries and wages 

8 Pension plan contributions (include section 401 (k) and section 

403(b) employercontributions) .... 

9 Other employee benefits 

10 Payroll taxes 

11 Fees for services (non-employees) 

a Management 

b Legal 

c Accounting 

d Lobbying 

e Professional fundraising See Part IV, line 17 . 

f Investment management fees 

9 Other 

12 Advertising and promotion .... 

13 Office expenses 

14 Information technology 

15 Royalties 

16 Occupancy 

17 Travel 

18 Payments of travel or entertainment expenses for any federal, 

state, or local public officials 

19 Conferences, conventions, and meetings .... 

20 Interest 

21 Payments to affiliates 

22 Depreciation, depletion, and amortization 

23 Insurance 

24 Other expenses Itemize expenses not covered above (List 

miscellaneous expenses in line 24f If line 24f amount exceeds 10% of 

line 25, column (A)amount, list line 24fexpenses on Schedule 0 ) 

a WEBSITE MAINTENANCE 

1 Grants and other assistance to governments and organizations 

in the United States See Part IV, line 21 

2 Grants and other assistance to individuals in the 

United States See Part IV, line 22 

3 Grants and other assistance to governments, 

organizations, and individuals outside the United 

States See Part IV, lines 15 and 16 

4 Benefits paid to or for members 

5 Compensation of current officers, directors, trustees, and 

key employees .... 

6 Compensation not included above, to disqualified persons 

(as defined under section 4958(f)(1)) and persons 

described in section 4958(c)(3)(B) .... 

7 Other salaries and wages 

8 Pension plan contributions (include section 401 (k) and section 

403(b) employercontributions) .... 

9 Other employee benefits 

10 Payroll taxes 

11 Fees for services (non-employees) 

a Management 

b Legal 

c Accounting 

d Lobbying 

e Professional fundraising See Part IV, line 17 . 

f Investment management fees 

9 Other 

12 Advertising and promotion .... 

13 Office expenses 

14 Information technology 

15 Royalties 

16 Occupancy 

17 Travel 

18 Payments of travel or entertainment expenses for any federal, 

state, or local public officials 

19 Conferences, conventions, and meetings .... 

20 Interest 

21 Payments to affiliates 

22 Depreciation, depletion, and amortization 

23 Insurance 

24 Other expenses Itemize expenses not covered above (List 

miscellaneous expenses in line 24f If line 24f amount exceeds 10% of 

line 25, column (A)amount, list line 24fexpenses on Schedule 0 ) 

a WEBSITE MAINTENANCE 

1 Grants and other assistance to governments and organizations 

in the United States See Part IV, line 21 

2 Grants and other assistance to individuals in the 

United States See Part IV, line 22 

3 Grants and other assistance to governments, 

organizations, and individuals outside the United 

States See Part IV, lines 15 and 16 

4 Benefits paid to or for members 

5 Compensation of current officers, directors, trustees, and 

key employees .... 

6 Compensation not included above, to disqualified persons 

(as defined under section 4958(f)(1)) and persons 

described in section 4958(c)(3)(B) .... 

7 Other salaries and wages 

8 Pension plan contributions (include section 401 (k) and section 

403(b) employercontributions) .... 

9 Other employee benefits 

10 Payroll taxes 

11 Fees for services (non-employees) 

a Management 

b Legal 

c Accounting 

d Lobbying 

e Professional fundraising See Part IV, line 17 . 

f Investment management fees 

9 Other 

12 Advertising and promotion .... 

13 Office expenses 

14 Information technology 

15 Royalties 

16 Occupancy 

17 Travel 

18 Payments of travel or entertainment expenses for any federal, 

state, or local public officials 

19 Conferences, conventions, and meetings .... 

20 Interest 

21 Payments to affiliates 

22 Depreciation, depletion, and amortization 

23 Insurance 

24 Other expenses Itemize expenses not covered above (List 

miscellaneous expenses in line 24f If line 24f amount exceeds 10% of 

line 25, column (A)amount, list line 24fexpenses on Schedule 0 ) 

a WEBSITE MAINTENANCE 

1 Grants and other assistance to governments and organizations 

in the United States See Part IV, line 21 

2 Grants and other assistance to individuals in the 

United States See Part IV, line 22 

3 Grants and other assistance to governments, 

organizations, and individuals outside the United 

States See Part IV, lines 15 and 16 

4 Benefits paid to or for members 

5 Compensation of current officers, directors, trustees, and 

key employees .... 

6 Compensation not included above, to disqualified persons 

(as defined under section 4958(f)(1)) and persons 

described in section 4958(c)(3)(B) .... 

7 Other salaries and wages 

8 Pension plan contributions (include section 401 (k) and section 

403(b) employercontributions) .... 

9 Other employee benefits 

10 Payroll taxes 

11 Fees for services (non-employees) 

a Management 

b Legal 

c Accounting 

d Lobbying 

e Professional fundraising See Part IV, line 17 . 

f Investment management fees 

9 Other 

12 Advertising and promotion .... 

13 Office expenses 

14 Information technology 

15 Royalties 

16 Occupancy 

17 Travel 

18 Payments of travel or entertainment expenses for any federal, 

state, or local public officials 

19 Conferences, conventions, and meetings .... 

20 Interest 

21 Payments to affiliates 

22 Depreciation, depletion, and amortization 

23 Insurance 

24 Other expenses Itemize expenses not covered above (List 

miscellaneous expenses in line 24f If line 24f amount exceeds 10% of 

line 25, column (A)amount, list line 24fexpenses on Schedule 0 ) 

a WEBSITE MAINTENANCE 

1 Grants and other assistance to governments and organizations 

in the United States See Part IV, line 21 

2 Grants and other assistance to individuals in the 

United States See Part IV, line 22 

3 Grants and other assistance to governments, 

organizations, and individuals outside the United 

States See Part IV, lines 15 and 16 

4 Benefits paid to or for members 

5 Compensation of current officers, directors, trustees, and 

key employees .... 

6 Compensation not included above, to disqualified persons 

(as defined under section 4958(f)(1)) and persons 

described in section 4958(c)(3)(B) .... 

7 Other salaries and wages 

8 Pension plan contributions (include section 401 (k) and section 

403(b) employercontributions) .... 

9 Other employee benefits 

10 Payroll taxes 

11 Fees for services (non-employees) 

a Management 

b Legal 

c Accounting 

d Lobbying 

e Professional fundraising See Part IV, line 17 . 

f Investment management fees 

9 Other 

12 Advertising and promotion .... 

13 Office expenses 

14 Information technology 

15 Royalties 

16 Occupancy 

17 Travel 

18 Payments of travel or entertainment expenses for any federal, 

state, or local public officials 

19 Conferences, conventions, and meetings .... 

20 Interest 

21 Payments to affiliates 

22 Depreciation, depletion, and amortization 

23 Insurance 

24 Other expenses Itemize expenses not covered above (List 

miscellaneous expenses in line 24f If line 24f amount exceeds 10% of 

line 25, column (A)amount, list line 24fexpenses on Schedule 0 ) 

a WEBSITE MAINTENANCE 

15,000 15,000 

1 Grants and other assistance to governments and organizations 

in the United States See Part IV, line 21 

2 Grants and other assistance to individuals in the 

United States See Part IV, line 22 

3 Grants and other assistance to governments, 

organizations, and individuals outside the United 

States See Part IV, lines 15 and 16 

4 Benefits paid to or for members 

5 Compensation of current officers, directors, trustees, and 

key employees .... 

6 Compensation not included above, to disqualified persons 

(as defined under section 4958(f)(1)) and persons 

described in section 4958(c)(3)(B) .... 

7 Other salaries and wages 

8 Pension plan contributions (include section 401 (k) and section 

403(b) employercontributions) .... 

9 Other employee benefits 

10 Payroll taxes 

11 Fees for services (non-employees) 

a Management 

b Legal 

c Accounting 

d Lobbying 

e Professional fundraising See Part IV, line 17 . 

f Investment management fees 

9 Other 

12 Advertising and promotion .... 

13 Office expenses 

14 Information technology 

15 Royalties 

16 Occupancy 

17 Travel 

18 Payments of travel or entertainment expenses for any federal, 

state, or local public officials 

19 Conferences, conventions, and meetings .... 

20 Interest 

21 Payments to affiliates 

22 Depreciation, depletion, and amortization 

23 Insurance 

24 Other expenses Itemize expenses not covered above (List 

miscellaneous expenses in line 24f If line 24f amount exceeds 10% of 

line 25, column (A)amount, list line 24fexpenses on Schedule 0 ) 

a WEBSITE MAINTENANCE 

2,922 2,922 

1 Grants and other assistance to governments and organizations 

in the United States See Part IV, line 21 

2 Grants and other assistance to individuals in the 

United States See Part IV, line 22 

3 Grants and other assistance to governments, 

organizations, and individuals outside the United 

States See Part IV, lines 15 and 16 

4 Benefits paid to or for members 

5 Compensation of current officers, directors, trustees, and 

key employees .... 

6 Compensation not included above, to disqualified persons 

(as defined under section 4958(f)(1)) and persons 

described in section 4958(c)(3)(B) .... 

7 Other salaries and wages 

8 Pension plan contributions (include section 401 (k) and section 

403(b) employercontributions) .... 

9 Other employee benefits 

10 Payroll taxes 

11 Fees for services (non-employees) 

a Management 

b Legal 

c Accounting 

d Lobbying 

e Professional fundraising See Part IV, line 17 . 

f Investment management fees 

9 Other 

12 Advertising and promotion .... 

13 Office expenses 

14 Information technology 

15 Royalties 

16 Occupancy 

17 Travel 

18 Payments of travel or entertainment expenses for any federal, 

state, or local public officials 

19 Conferences, conventions, and meetings .... 

20 Interest 

21 Payments to affiliates 

22 Depreciation, depletion, and amortization 

23 Insurance 

24 Other expenses Itemize expenses not covered above (List 

miscellaneous expenses in line 24f If line 24f amount exceeds 10% of 

line 25, column (A)amount, list line 24fexpenses on Schedule 0 ) 

a WEBSITE MAINTENANCE 

3,048 3,048 

1 Grants and other assistance to governments and organizations 

in the United States See Part IV, line 21 

2 Grants and other assistance to individuals in the 

United States See Part IV, line 22 

3 Grants and other assistance to governments, 

organizations, and individuals outside the United 

States See Part IV, lines 15 and 16 

4 Benefits paid to or for members 

5 Compensation of current officers, directors, trustees, and 

key employees .... 

6 Compensation not included above, to disqualified persons 

(as defined under section 4958(f)(1)) and persons 

described in section 4958(c)(3)(B) .... 

7 Other salaries and wages 

8 Pension plan contributions (include section 401 (k) and section 

403(b) employercontributions) .... 

9 Other employee benefits 

10 Payroll taxes 

11 Fees for services (non-employees) 

a Management 

b Legal 

c Accounting 

d Lobbying 

e Professional fundraising See Part IV, line 17 . 

f Investment management fees 

9 Other 

12 Advertising and promotion .... 

13 Office expenses 

14 Information technology 

15 Royalties 

16 Occupancy 

17 Travel 

18 Payments of travel or entertainment expenses for any federal, 

state, or local public officials 

19 Conferences, conventions, and meetings .... 

20 Interest 

21 Payments to affiliates 

22 Depreciation, depletion, and amortization 

23 Insurance 

24 Other expenses Itemize expenses not covered above (List 

miscellaneous expenses in line 24f If line 24f amount exceeds 10% of 

line 25, column (A)amount, list line 24fexpenses on Schedule 0 ) 

a WEBSITE MAINTENANCE 

1 Grants and other assistance to governments and organizations 

in the United States See Part IV, line 21 

2 Grants and other assistance to individuals in the 

United States See Part IV, line 22 

3 Grants and other assistance to governments, 

organizations, and individuals outside the United 

States See Part IV, lines 15 and 16 

4 Benefits paid to or for members 

5 Compensation of current officers, directors, trustees, and 

key employees .... 

6 Compensation not included above, to disqualified persons 

(as defined under section 4958(f)(1)) and persons 

described in section 4958(c)(3)(B) .... 

7 Other salaries and wages 

8 Pension plan contributions (include section 401 (k) and section 

403(b) employercontributions) .... 

9 Other employee benefits 

10 Payroll taxes 

11 Fees for services (non-employees) 

a Management 

b Legal 

c Accounting 

d Lobbying 

e Professional fundraising See Part IV, line 17 . 

f Investment management fees 

9 Other 

12 Advertising and promotion .... 

13 Office expenses 

14 Information technology 

15 Royalties 

16 Occupancy 

17 Travel 

18 Payments of travel or entertainment expenses for any federal, 

state, or local public officials 

19 Conferences, conventions, and meetings .... 

20 Interest 

21 Payments to affiliates 

22 Depreciation, depletion, and amortization 

23 Insurance 

24 Other expenses Itemize expenses not covered above (List 

miscellaneous expenses in line 24f If line 24f amount exceeds 10% of 

line 25, column (A)amount, list line 24fexpenses on Schedule 0 ) 

a WEBSITE MAINTENANCE 

1 Grants and other assistance to governments and organizations 

in the United States See Part IV, line 21 

2 Grants and other assistance to individuals in the 

United States See Part IV, line 22 

3 Grants and other assistance to governments, 

organizations, and individuals outside the United 

States See Part IV, lines 15 and 16 

4 Benefits paid to or for members 

5 Compensation of current officers, directors, trustees, and 

key employees .... 

6 Compensation not included above, to disqualified persons 

(as defined under section 4958(f)(1)) and persons 

described in section 4958(c)(3)(B) .... 

7 Other salaries and wages 

8 Pension plan contributions (include section 401 (k) and section 

403(b) employercontributions) .... 

9 Other employee benefits 

10 Payroll taxes 

11 Fees for services (non-employees) 

a Management 

b Legal 

c Accounting 

d Lobbying 

e Professional fundraising See Part IV, line 17 . 

f Investment management fees 

9 Other 

12 Advertising and promotion .... 

13 Office expenses 

14 Information technology 

15 Royalties 

16 Occupancy 

17 Travel 

18 Payments of travel or entertainment expenses for any federal, 

state, or local public officials 

19 Conferences, conventions, and meetings .... 

20 Interest 

21 Payments to affiliates 

22 Depreciation, depletion, and amortization 

23 Insurance 

24 Other expenses Itemize expenses not covered above (List 

miscellaneous expenses in line 24f If line 24f amount exceeds 10% of 

line 25, column (A)amount, list line 24fexpenses on Schedule 0 ) 

a WEBSITE MAINTENANCE 

1 Grants and other assistance to governments and organizations 

in the United States See Part IV, line 21 

2 Grants and other assistance to individuals in the 

United States See Part IV, line 22 

3 Grants and other assistance to governments, 

organizations, and individuals outside the United 

States See Part IV, lines 15 and 16 

4 Benefits paid to or for members 

5 Compensation of current officers, directors, trustees, and 

key employees .... 

6 Compensation not included above, to disqualified persons 

(as defined under section 4958(f)(1)) and persons 

described in section 4958(c)(3)(B) .... 

7 Other salaries and wages 

8 Pension plan contributions (include section 401 (k) and section 

403(b) employercontributions) .... 

9 Other employee benefits 

10 Payroll taxes 

11 Fees for services (non-employees) 

a Management 

b Legal 

c Accounting 

d Lobbying 

e Professional fundraising See Part IV, line 17 . 

f Investment management fees 

9 Other 

12 Advertising and promotion .... 

13 Office expenses 

14 Information technology 

15 Royalties 

16 Occupancy 

17 Travel 

18 Payments of travel or entertainment expenses for any federal, 

state, or local public officials 

19 Conferences, conventions, and meetings .... 

20 Interest 

21 Payments to affiliates 

22 Depreciation, depletion, and amortization 

23 Insurance 

24 Other expenses Itemize expenses not covered above (List 

miscellaneous expenses in line 24f If line 24f amount exceeds 10% of 

line 25, column (A)amount, list line 24fexpenses on Schedule 0 ) 

a WEBSITE MAINTENANCE 

5,000 5,000 

1 Grants and other assistance to governments and organizations 

in the United States See Part IV, line 21 

2 Grants and other assistance to individuals in the 

United States See Part IV, line 22 

3 Grants and other assistance to governments, 

organizations, and individuals outside the United 

States See Part IV, lines 15 and 16 

4 Benefits paid to or for members 

5 Compensation of current officers, directors, trustees, and 

key employees .... 

6 Compensation not included above, to disqualified persons 

(as defined under section 4958(f)(1)) and persons 

described in section 4958(c)(3)(B) .... 

7 Other salaries and wages 

8 Pension plan contributions (include section 401 (k) and section 

403(b) employercontributions) .... 

9 Other employee benefits 

10 Payroll taxes 

11 Fees for services (non-employees) 

a Management 

b Legal 

c Accounting 

d Lobbying 

e Professional fundraising See Part IV, line 17 . 

f Investment management fees 

9 Other 

12 Advertising and promotion .... 

13 Office expenses 

14 Information technology 

15 Royalties 

16 Occupancy 

17 Travel 

18 Payments of travel or entertainment expenses for any federal, 

state, or local public officials 

19 Conferences, conventions, and meetings .... 

20 Interest 

21 Payments to affiliates 

22 Depreciation, depletion, and amortization 

23 Insurance 

24 Other expenses Itemize expenses not covered above (List 

miscellaneous expenses in line 24f If line 24f amount exceeds 10% of 

line 25, column (A)amount, list line 24fexpenses on Schedule 0 ) 

a WEBSITE MAINTENANCE 

1 Grants and other assistance to governments and organizations 

in the United States See Part IV, line 21 

2 Grants and other assistance to individuals in the 

United States See Part IV, line 22 

3 Grants and other assistance to governments, 

organizations, and individuals outside the United 

States See Part IV, lines 15 and 16 

4 Benefits paid to or for members 

5 Compensation of current officers, directors, trustees, and 

key employees .... 

6 Compensation not included above, to disqualified persons 

(as defined under section 4958(f)(1)) and persons 

described in section 4958(c)(3)(B) .... 

7 Other salaries and wages 

8 Pension plan contributions (include section 401 (k) and section 

403(b) employercontributions) .... 

9 Other employee benefits 

10 Payroll taxes 

11 Fees for services (non-employees) 

a Management 

b Legal 

c Accounting 

d Lobbying 

e Professional fundraising See Part IV, line 17 . 

f Investment management fees 

9 Other 

12 Advertising and promotion .... 

13 Office expenses 

14 Information technology 

15 Royalties 

16 Occupancy 

17 Travel 

18 Payments of travel or entertainment expenses for any federal, 

state, or local public officials 

19 Conferences, conventions, and meetings .... 

20 Interest 

21 Payments to affiliates 

22 Depreciation, depletion, and amortization 

23 Insurance 

24 Other expenses Itemize expenses not covered above (List 

miscellaneous expenses in line 24f If line 24f amount exceeds 10% of 

line 25, column (A)amount, list line 24fexpenses on Schedule 0 ) 

a WEBSITE MAINTENANCE 

1 Grants and other assistance to governments and organizations 

in the United States See Part IV, line 21 

2 Grants and other assistance to individuals in the 

United States See Part IV, line 22 

3 Grants and other assistance to governments, 

organizations, and individuals outside the United 

States See Part IV, lines 15 and 16 

4 Benefits paid to or for members 

5 Compensation of current officers, directors, trustees, and 

key employees .... 

6 Compensation not included above, to disqualified persons 

(as defined under section 4958(f)(1)) and persons 

described in section 4958(c)(3)(B) .... 

7 Other salaries and wages 

8 Pension plan contributions (include section 401 (k) and section 

403(b) employercontributions) .... 

9 Other employee benefits 

10 Payroll taxes 

11 Fees for services (non-employees) 

a Management 

b Legal 

c Accounting 

d Lobbying 

e Professional fundraising See Part IV, line 17 . 

f Investment management fees 

9 Other 

12 Advertising and promotion .... 

13 Office expenses 

14 Information technology 

15 Royalties 

16 Occupancy 

17 Travel 

18 Payments of travel or entertainment expenses for any federal, 

state, or local public officials 

19 Conferences, conventions, and meetings .... 

20 Interest 

21 Payments to affiliates 

22 Depreciation, depletion, and amortization 

23 Insurance 

24 Other expenses Itemize expenses not covered above (List 

miscellaneous expenses in line 24f If line 24f amount exceeds 10% of 

line 25, column (A)amount, list line 24fexpenses on Schedule 0 ) 

a WEBSITE MAINTENANCE 

1 Grants and other assistance to governments and organizations 

in the United States See Part IV, line 21 

2 Grants and other assistance to individuals in the 

United States See Part IV, line 22 

3 Grants and other assistance to governments, 

organizations, and individuals outside the United 

States See Part IV, lines 15 and 16 

4 Benefits paid to or for members 

5 Compensation of current officers, directors, trustees, and 

key employees .... 

6 Compensation not included above, to disqualified persons 

(as defined under section 4958(f)(1)) and persons 

described in section 4958(c)(3)(B) .... 

7 Other salaries and wages 

8 Pension plan contributions (include section 401 (k) and section 

403(b) employercontributions) .... 

9 Other employee benefits 

10 Payroll taxes 

11 Fees for services (non-employees) 

a Management 

b Legal 

c Accounting 

d Lobbying 

e Professional fundraising See Part IV, line 17 . 

f Investment management fees 

9 Other 

12 Advertising and promotion .... 

13 Office expenses 

14 Information technology 

15 Royalties 

16 Occupancy 

17 Travel 

18 Payments of travel or entertainment expenses for any federal, 

state, or local public officials 

19 Conferences, conventions, and meetings .... 

20 Interest 

21 Payments to affiliates 

22 Depreciation, depletion, and amortization 

23 Insurance 

24 Other expenses Itemize expenses not covered above (List 

miscellaneous expenses in line 24f If line 24f amount exceeds 10% of 

line 25, column (A)amount, list line 24fexpenses on Schedule 0 ) 

a WEBSITE MAINTENANCE 

1 Grants and other assistance to governments and organizations 

in the United States See Part IV, line 21 

2 Grants and other assistance to individuals in the 

United States See Part IV, line 22 

3 Grants and other assistance to governments, 

organizations, and individuals outside the United 

States See Part IV, lines 15 and 16 

4 Benefits paid to or for members 

5 Compensation of current officers, directors, trustees, and 

key employees .... 

6 Compensation not included above, to disqualified persons 

(as defined under section 4958(f)(1)) and persons 

described in section 4958(c)(3)(B) .... 

7 Other salaries and wages 

8 Pension plan contributions (include section 401 (k) and section 

403(b) employercontributions) .... 

9 Other employee benefits 

10 Payroll taxes 

11 Fees for services (non-employees) 

a Management 

b Legal 

c Accounting 

d Lobbying 

e Professional fundraising See Part IV, line 17 . 

f Investment management fees 

9 Other 

12 Advertising and promotion .... 

13 Office expenses 

14 Information technology 

15 Royalties 

16 Occupancy 

17 Travel 

18 Payments of travel or entertainment expenses for any federal, 

state, or local public officials 

19 Conferences, conventions, and meetings .... 

20 Interest 

21 Payments to affiliates 

22 Depreciation, depletion, and amortization 

23 Insurance 

24 Other expenses Itemize expenses not covered above (List 

miscellaneous expenses in line 24f If line 24f amount exceeds 10% of 

line 25, column (A)amount, list line 24fexpenses on Schedule 0 ) 

a WEBSITE MAINTENANCE 

1 Grants and other assistance to governments and organizations 

in the United States See Part IV, line 21 

2 Grants and other assistance to individuals in the 

United States See Part IV, line 22 

3 Grants and other assistance to governments, 

organizations, and individuals outside the United 

States See Part IV, lines 15 and 16 

4 Benefits paid to or for members 

5 Compensation of current officers, directors, trustees, and 

key employees .... 

6 Compensation not included above, to disqualified persons 

(as defined under section 4958(f)(1)) and persons 

described in section 4958(c)(3)(B) .... 

7 Other salaries and wages 

8 Pension plan contributions (include section 401 (k) and section 

403(b) employercontributions) .... 

9 Other employee benefits 

10 Payroll taxes 

11 Fees for services (non-employees) 

a Management 

b Legal 

c Accounting 

d Lobbying 

e Professional fundraising See Part IV, line 17 . 

f Investment management fees 

9 Other 

12 Advertising and promotion .... 

13 Office expenses 

14 Information technology 

15 Royalties 

16 Occupancy 

17 Travel 

18 Payments of travel or entertainment expenses for any federal, 

state, or local public officials 

19 Conferences, conventions, and meetings .... 

20 Interest 

21 Payments to affiliates 

22 Depreciation, depletion, and amortization 

23 Insurance 

24 Other expenses Itemize expenses not covered above (List 

miscellaneous expenses in line 24f If line 24f amount exceeds 10% of 

line 25, column (A)amount, list line 24fexpenses on Schedule 0 ) 

a WEBSITE MAINTENANCE 

1 Grants and other assistance to governments and organizations 

in the United States See Part IV, line 21 

2 Grants and other assistance to individuals in the 

United States See Part IV, line 22 

3 Grants and other assistance to governments, 

organizations, and individuals outside the United 

States See Part IV, lines 15 and 16 

4 Benefits paid to or for members 

5 Compensation of current officers, directors, trustees, and 

key employees .... 

6 Compensation not included above, to disqualified persons 

(as defined under section 4958(f)(1)) and persons 

described in section 4958(c)(3)(B) .... 

7 Other salaries and wages 

8 Pension plan contributions (include section 401 (k) and section 

403(b) employercontributions) .... 

9 Other employee benefits 

10 Payroll taxes 

11 Fees for services (non-employees) 

a Management 

b Legal 

c Accounting 

d Lobbying 

e Professional fundraising See Part IV, line 17 . 

f Investment management fees 

9 Other 

12 Advertising and promotion .... 

13 Office expenses 

14 Information technology 

15 Royalties 

16 Occupancy 

17 Travel 

18 Payments of travel or entertainment expenses for any federal, 

state, or local public officials 

19 Conferences, conventions, and meetings .... 

20 Interest 

21 Payments to affiliates 

22 Depreciation, depletion, and amortization 

23 Insurance 

24 Other expenses Itemize expenses not covered above (List 

miscellaneous expenses in line 24f If line 24f amount exceeds 10% of 

line 25, column (A)amount, list line 24fexpenses on Schedule 0 ) 

a WEBSITE MAINTENANCE 

1 Grants and other assistance to governments and organizations 

in the United States See Part IV, line 21 

2 Grants and other assistance to individuals in the 

United States See Part IV, line 22 

3 Grants and other assistance to governments, 

organizations, and individuals outside the United 

States See Part IV, lines 15 and 16 

4 Benefits paid to or for members 

5 Compensation of current officers, directors, trustees, and 

key employees .... 

6 Compensation not included above, to disqualified persons 

(as defined under section 4958(f)(1)) and persons 

described in section 4958(c)(3)(B) .... 

7 Other salaries and wages 

8 Pension plan contributions (include section 401 (k) and section 

403(b) employercontributions) .... 

9 Other employee benefits 

10 Payroll taxes 

11 Fees for services (non-employees) 

a Management 

b Legal 

c Accounting 

d Lobbying 

e Professional fundraising See Part IV, line 17 . 

f Investment management fees 

9 Other 

12 Advertising and promotion .... 

13 Office expenses 

14 Information technology 

15 Royalties 

16 Occupancy 

17 Travel 

18 Payments of travel or entertainment expenses for any federal, 

state, or local public officials 

19 Conferences, conventions, and meetings .... 

20 Interest 

21 Payments to affiliates 

22 Depreciation, depletion, and amortization 

23 Insurance 

24 Other expenses Itemize expenses not covered above (List 

miscellaneous expenses in line 24f If line 24f amount exceeds 10% of 

line 25, column (A)amount, list line 24fexpenses on Schedule 0 ) 

a WEBSITE MAINTENANCE 

1 Grants and other assistance to governments and organizations 

in the United States See Part IV, line 21 

2 Grants and other assistance to individuals in the 

United States See Part IV, line 22 

3 Grants and other assistance to governments, 

organizations, and individuals outside the United 

States See Part IV, lines 15 and 16 

4 Benefits paid to or for members 

5 Compensation of current officers, directors, trustees, and 

key employees .... 

6 Compensation not included above, to disqualified persons 

(as defined under section 4958(f)(1)) and persons 

described in section 4958(c)(3)(B) .... 

7 Other salaries and wages 

8 Pension plan contributions (include section 401 (k) and section 

403(b) employercontributions) .... 

9 Other employee benefits 

10 Payroll taxes 

11 Fees for services (non-employees) 

a Management 

b Legal 

c Accounting 

d Lobbying 

e Professional fundraising See Part IV, line 17 . 

f Investment management fees 

9 Other 

12 Advertising and promotion .... 

13 Office expenses 

14 Information technology 

15 Royalties 

16 Occupancy 

17 Travel 

18 Payments of travel or entertainment expenses for any federal, 

state, or local public officials 

19 Conferences, conventions, and meetings .... 

20 Interest 

21 Payments to affiliates 

22 Depreciation, depletion, and amortization 

23 Insurance 

24 Other expenses Itemize expenses not covered above (List 

miscellaneous expenses in line 24f If line 24f amount exceeds 10% of 

line 25, column (A)amount, list line 24fexpenses on Schedule 0 ) 

a WEBSITE MAINTENANCE 

1 Grants and other assistance to governments and organizations 

in the United States See Part IV, line 21 

2 Grants and other assistance to individuals in the 

United States See Part IV, line 22 

3 Grants and other assistance to governments, 

organizations, and individuals outside the United 

States See Part IV, lines 15 and 16 

4 Benefits paid to or for members 

5 Compensation of current officers, directors, trustees, and 

key employees .... 

6 Compensation not included above, to disqualified persons 

(as defined under section 4958(f)(1)) and persons 

described in section 4958(c)(3)(B) .... 

7 Other salaries and wages 

8 Pension plan contributions (include section 401 (k) and section 

403(b) employercontributions) .... 

9 Other employee benefits 

10 Payroll taxes 

11 Fees for services (non-employees) 

a Management 

b Legal 

c Accounting 

d Lobbying 

e Professional fundraising See Part IV, line 17 . 

f Investment management fees 

9 Other 

12 Advertising and promotion .... 

13 Office expenses 

14 Information technology 

15 Royalties 

16 Occupancy 

17 Travel 

18 Payments of travel or entertainment expenses for any federal, 

state, or local public officials 

19 Conferences, conventions, and meetings .... 

20 Interest 

21 Payments to affiliates 

22 Depreciation, depletion, and amortization 

23 Insurance 

24 Other expenses Itemize expenses not covered above (List 

miscellaneous expenses in line 24f If line 24f amount exceeds 10% of 

line 25, column (A)amount, list line 24fexpenses on Schedule 0 ) 

a WEBSITE MAINTENANCE 

1 Grants and other assistance to governments and organizations 

in the United States See Part IV, line 21 

2 Grants and other assistance to individuals in the 

United States See Part IV, line 22 

3 Grants and other assistance to governments, 

organizations, and individuals outside the United 

States See Part IV, lines 15 and 16 

4 Benefits paid to or for members 

5 Compensation of current officers, directors, trustees, and 

key employees .... 

6 Compensation not included above, to disqualified persons 

(as defined under section 4958(f)(1)) and persons 

described in section 4958(c)(3)(B) .... 

7 Other salaries and wages 

8 Pension plan contributions (include section 401 (k) and section 

403(b) employercontributions) .... 

9 Other employee benefits 

10 Payroll taxes 

11 Fees for services (non-employees) 

a Management 

b Legal 

c Accounting 

d Lobbying 

e Professional fundraising See Part IV, line 17 . 

f Investment management fees 

9 Other 

12 Advertising and promotion .... 

13 Office expenses 

14 Information technology 

15 Royalties 

16 Occupancy 

17 Travel 

18 Payments of travel or entertainment expenses for any federal, 

state, or local public officials 

19 Conferences, conventions, and meetings .... 

20 Interest 

21 Payments to affiliates 

22 Depreciation, depletion, and amortization 

23 Insurance 

24 Other expenses Itemize expenses not covered above (List 

miscellaneous expenses in line 24f If line 24f amount exceeds 10% of 

line 25, column (A)amount, list line 24fexpenses on Schedule 0 ) 

a WEBSITE MAINTENANCE 

1 Grants and other assistance to governments and organizations 

in the United States See Part IV, line 21 

2 Grants and other assistance to individuals in the 

United States See Part IV, line 22 

3 Grants and other assistance to governments, 

organizations, and individuals outside the United 

States See Part IV, lines 15 and 16 

4 Benefits paid to or for members 

5 Compensation of current officers, directors, trustees, and 

key employees .... 

6 Compensation not included above, to disqualified persons 

(as defined under section 4958(f)(1)) and persons 

described in section 4958(c)(3)(B) .... 

7 Other salaries and wages 

8 Pension plan contributions (include section 401 (k) and section 

403(b) employercontributions) .... 

9 Other employee benefits 

10 Payroll taxes 

11 Fees for services (non-employees) 

a Management 

b Legal 

c Accounting 

d Lobbying 

e Professional fundraising See Part IV, line 17 . 

f Investment management fees 

9 Other 

12 Advertising and promotion .... 

13 Office expenses 

14 Information technology 

15 Royalties 

16 Occupancy 

17 Travel 

18 Payments of travel or entertainment expenses for any federal, 

state, or local public officials 

19 Conferences, conventions, and meetings .... 

20 Interest 

21 Payments to affiliates 

22 Depreciation, depletion, and amortization 

23 Insurance 

24 Other expenses Itemize expenses not covered above (List 

miscellaneous expenses in line 24f If line 24f amount exceeds 10% of 

line 25, column (A)amount, list line 24fexpenses on Schedule 0 ) 

a WEBSITE MAINTENANCE 

1 Grants and other assistance to governments and organizations 

in the United States See Part IV, line 21 

2 Grants and other assistance to individuals in the 

United States See Part IV, line 22 

3 Grants and other assistance to governments, 

organizations, and individuals outside the United 

States See Part IV, lines 15 and 16 

4 Benefits paid to or for members 

5 Compensation of current officers, directors, trustees, and 

key employees .... 

6 Compensation not included above, to disqualified persons 

(as defined under section 4958(f)(1)) and persons 

described in section 4958(c)(3)(B) .... 

7 Other salaries and wages 

8 Pension plan contributions (include section 401 (k) and section 

403(b) employercontributions) .... 

9 Other employee benefits 

10 Payroll taxes 

11 Fees for services (non-employees) 

a Management 

b Legal 

c Accounting 

d Lobbying 

e Professional fundraising See Part IV, line 17 . 

f Investment management fees 

9 Other 

12 Advertising and promotion .... 

13 Office expenses 

14 Information technology 

15 Royalties 

16 Occupancy 

17 Travel 

18 Payments of travel or entertainment expenses for any federal, 

state, or local public officials 

19 Conferences, conventions, and meetings .... 

20 Interest 

21 Payments to affiliates 

22 Depreciation, depletion, and amortization 

23 Insurance 

24 Other expenses Itemize expenses not covered above (List 

miscellaneous expenses in line 24f If line 24f amount exceeds 10% of 

line 25, column (A)amount, list line 24fexpenses on Schedule 0 ) 

a WEBSITE MAINTENANCE 

1 Grants and other assistance to governments and organizations 

in the United States See Part IV, line 21 

2 Grants and other assistance to individuals in the 

United States See Part IV, line 22 

3 Grants and other assistance to governments, 

organizations, and individuals outside the United 

States See Part IV, lines 15 and 16 

4 Benefits paid to or for members 

5 Compensation of current officers, directors, trustees, and 

key employees .... 

6 Compensation not included above, to disqualified persons 

(as defined under section 4958(f)(1)) and persons 

described in section 4958(c)(3)(B) .... 

7 Other salaries and wages 

8 Pension plan contributions (include section 401 (k) and section 

403(b) employercontributions) .... 

9 Other employee benefits 

10 Payroll taxes 

11 Fees for services (non-employees) 

a Management 

b Legal 

c Accounting 

d Lobbying 

e Professional fundraising See Part IV, line 17 . 

f Investment management fees 

9 Other 

12 Advertising and promotion .... 

13 Office expenses 

14 Information technology 

15 Royalties 

16 Occupancy 

17 Travel 

18 Payments of travel or entertainment expenses for any federal, 

state, or local public officials 

19 Conferences, conventions, and meetings .... 

20 Interest 

21 Payments to affiliates 

22 Depreciation, depletion, and amortization 

23 Insurance 

24 Other expenses Itemize expenses not covered above (List 

miscellaneous expenses in line 24f If line 24f amount exceeds 10% of 

line 25, column (A)amount, list line 24fexpenses on Schedule 0 ) 

a WEBSITE MAINTENANCE 5,000 5,000 

b BANK FEES 30 30 

c 

d 

e 

f All other expenses 

25 Total functional expenses. Add lines 1 through 24f 31,000 0 31,000 0 

26 Joint costs. Check here b-p if following 

SOP 98-2 (ASC 958-720) Complete this line only If the 

organization reported in column (B) joint costs from a AttSChr 

combined educational campaign and fiindraismg solicitation 

lentC 

4 

4 

Form 990 (2011) 
Form 990 (2011) 

•-.gHM Balance Sheet 

Page 11 

(A) 

Beginning of year 

(B) 

End of year 

R & S ^ 

0 I 4 

1 Cash—non-mterest-bearing 

2 Savings and temporary cash investments 

3 Pledges and grants receivable, net 

4 Accounts receivable, net 

5 Receivables from current and former officers, directors, trustees, key employees, and 

highest compensated employees Complete Part II of 

Schedule L 

6 Receivables from other disqualified persons (as defined under section 495B(f)(l)) and 

persons described in section 49S8(c)(3)(B) Complete Part II of 

Schedule L 

7 Notes and loans receivable, net 

8 Inventories for sale or use 

9 Prepaid expenses and deferred charges 

10a Land, buildings, and equipment cost or other basis Complete Part 

VI of Schedule 0 

b Less accumulated depreciation 

11 Investments—publicly traded securities 

12 Investments—other securities See Part IV, line 11 .... 

13 Investments—program-related See Part IV, line 11 . 

14 Intangible assets 

15 Other assets See Part IV, line 11 

16 Totalassets. Add lines 1 through IS (must equal line 34) . 

51,000 

10a 

10b 10c 

11 

12 

13 

14 

15 

51,000 16 

.2 

17 Accounts payable and accrued expenses . 

18 Grants payable 

19 Deferred revenue 

20 Tax-exempt bond liabilities 

21 Escrow or custodial account liability Cbmp/ete Part/V of Scfiedi/feO . 

22 Payables to current and former officers, directors, trustees, key 

employees, highest compensated employees,- and disqualified 

pe rs 0 ns Complete Part II of Schedule L 

23 Secured mortgages and notes payable to unrelated third parties . 

24 Unsecured notes and loans payable to unrelated third parties .... 

25 Other liabilities (including federal income tax, payables to related third parties, 

and other liabilities not included on lines 17-24) Complete Part X of Schedule 

20,000 17 

18 

19 

20 

21 

22 

23 

24 

25 

26 Total liabilities. Add lines 17 through 2S 20,000 26 

•A 

o 

c 

o 

•A 

27 

28 

29 

30 

31 

32 

33 

34 

Organizations that follow SFAS117, check here • p and complete lines 27 

through 29, and lines 33 and 34. 

Unrestncted net assets 

Temporarily restricted net assets 

Permanently restricted net assets 

Organizations that do not follow SFAS 117, check here • {7 and complete 

lines 30 through 34. 

Capital stock or trust principal, or current funds 

Paid-in or capital surplus, or land, building or equipment fund .... 

Retained earnings, endowment, accumulated income, or other funds 

Total net assets or fund balances Attachment C 

Total liabilities and net assets/fund balances 

27 

28 

29 

30 

31 

31,000 32 

31,000 33 

51,0W 34 

Form 990 (2011) 
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ATTACHMENT D 

§ CHGO document stating, e.g., 

I its "goal" and "potential targets" 
Cdniinissidn on Hope, GfoWth & Opportoriity 

GOAL: 

To make an impact using express advocacy in targeted Senate races on key issues 

including financial, reform., energy, taxes, pharmaceuticals, health care and other key 

concerns, with the primary focus on the policies-of the current Congress and the Obama 

Administration specific to job creation, business growth aiid economic recovery. 

GROUP DETAILS: 

Group Name: Comniission o.n Hope, Growth & Opportunity 

.Established: February I ^ 2010 

Legal Counsel: Bill Canlleld, Esq. 

Board Members: 

Steve Powell, San Diego 

Jim Warring, Bethesda 

Bill Canfreldj WaslimgtOni DC 

POTENTIAL TARGETS: 

Arkansas 

Delaware 

Illinois 

Missouri 

New Hampshire: 

Pennsylvania 

Colorado 

.Florida 

Indiana 

Nevada 

.North.Dakota 

Ohio 

Targets wijl be. further identified based on .media cost estimates, issue, strength jn any 

particular state, polling data, primary races and Other factors. 

PRELGVONARY LAUNCH TIMELtNE: 

Week of.May 4"' 

Week of May 17"' 

Week, of June ist 

Week of June 7''' 

Week, of June 14th' 

Post Basic Website 

Conduct Tnitiar Benchmark Survey 

with Over Sample in Target States 

Refine Media Targets 

Develop- Fundrai.singT airgets 

Ftha'ltze .Initial Creative. 

Launch, Initial Ad Flight in Top Tafget(s). 

Use Initial Ad Flight to Fundraiise 

Set Fuiidraising Meetings in DC/NYC 

Launch Website and Social Media 

Roll Out Ads in Other Targeted States 

Launch Gpllateral Activities such as 

RadiPi. Direct Mail, Print etc. 

Finalize Creative for Second Ad Flight 

Attachment D MMM-FEC-000001 
MESSAGING: 

The Commission on Hope, Growth & Opportunity will utilize all options availabie'to it 

for direct, express advocacy under the recent SCPTDS decision.. Because it can be 

anticipated the media, will focus.itiiich attentiOh.on most groups operating under this, new 

regime, the Commission, will focus its messaging on market research and strategically 

driven, compelling creative that will engage the public directly with, a documented, 

substantiated approach. In essence,, the creative will get. stakeholders' attention that can 

help with fundraising and .profile. However, it .is the group's preference to let the ads 

speak for themselves. We do not. intend to engage the media unless there is a clear 

advantage gained by doing, so. 

We will create ads. that get the viewers attention,, engage the public, document the 

statements m^e in the. ads and present them iii a;m.anne.r thdt leaves, lio opportunity for 

the rhedia to question our groupy our content, or.biir approach. 

TIMING: 

The June timing of the launch is predicated on: l )::the assumption that we want to: be one 

ofthe first groups (post S.COTUS decision) to gb.live so as to atp-act potenpal-additional 

funding; 2) how we can have an. impact in potential primaries either with positive br 

negative approach; and 3) getting pur first ad flight up so. both candidates and funders see 

the impact we intend to have in these targeted states \\'ell. before the run-up to the 

November election. 

In addition; giyen the recent activity on health care,, it is clear that this will be selling 

poiiit h for CbngressionaJ "Demberats.; We need to get into, some of these states, with bur 

own .messaging before this^single issue, can be linked to claims of econQ'mic; .recovery:. 

BUbGET: 

Given the large number of Senate: races in contention; iye Will focus on identifying a 

minimum of 4r6. rapes wherc.medi.a; costS; political dynamics and other factors jusfify our 

activity.. Instead.ormakihg a smaU impacl in'the dozen or.sb faces under consideration, 

bur st.raiegi' is predicated on. doing mbre in a .small er number of races as opposed to a 

broad, shallow approach. 

fb. db.this prbperly, we can.^ecr a working budget fbf the Cotnmissiori fqr 2010 

activities to-be a .minihmm. of .$S - $10 million dollars.for 4r6 rabes depehding bn the' 

states selected: 

Attachment D MHM-FEC-Q00002 
•ig.'-'r;;;i J y •••V." 'J'>—"—j,.'•.••••'•' • jjiji4 n... u„ . • m.-! , 

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Commissidn on Hope, Gro>vth & Oppprtariity 

GOAL: 

To make an iinpact using express advocacy in targeted Senate races on key issiies: 

including financial, refornii energy, taxes, pharmaceuticals, health care and other key 

concerns, with the primary focus on the policies^of the cuirent Congress and the Obaraa 

Administration specific to job creation, business growth, and economic recovery. 

GROUP DETAILS: 

Group Name; Commission oh Hope, Growth .& Opportunity 

lEstablishcd: Febniary .1., 20l b 

Legal Counsel; Bill Canfield, Esq. 

.Board Members: 

Steve Powell,. San Diego 

Jim Warring, Bethesda 

Bill Canfield, Washingtohi DC 

POT ENTIA L TA RG ETS: 

Arkansas 

Delaware 

Illinois 

Missouri 

New HampshirePennsylvania 

Coloradb 

.Flpfida 

Indiana 

Nevada 

North Dakota 

OhiO' 

Targets will he further identified based .ph media post. estimateSi issue strength in aiiy 

particular state, polling datSj primary races.and of her.factors. 

PRELIMINARY LAUNCH TIMELINE: 

Week of.May 4'" 

Week of .May 17"' 

Week of June 1st 

Week of June f' 

<Veek of June 14th' 

Post Basic,Wobsite 

Conduct jnitial' Benchmark Survey 

with Over Sample in Target States" 

Refine. Media Targets 

Develop Fundraising Targets 

Finalize initial Creative 

Launch .Initial Ad Flight in Top Tafget(sT 

Use Initial Ad Flight to Fundraise 

Set Fundraising Meetings in DC/NYC 

Launch Wdbsite and Social Media 

Roll Out Ads in Other Targpte^: States 

Launch GplJatefal Activities siich as. 

jRadiQi. Pirtct Maili Print etc. 

Finalize Creafive for Second Ad Flight 

Attachment D MHiVI-FEC-dOOOOl 
I 

MESSAGING: 

The Commission on Hope, Growth & Opportunity will utilize ail options availabib to it 

for direct, express advocacy under tli& recent SCOTUS' decision. Because it can be 

anticipated the media will focus much attention.on most groups operating under this new 

regime, the-Commission will focus its messaging on market research and strategically 

driven, compelling creative that will engage the public directly with a documented, 

substantiated approach. In essence,, the creative will get. stakeholders' attention.thai can 

help with fundraising and profile. However, it is thegroup'.s preference to let the.adsspeak for themselves. We.do not intend to ongage the media unless:.there fs a clear 

advantage gained by doing so. 

We will create ads that get: the.viewers attention, engage the piiblic, dpcumentthe 

statements niade iii the ads an.d.:present'them. ih a.mnhner that1eaves.no opportunity for 

the media to question our group, our cohtent orour approach. 

TIMING: 

The-June timing of the launch is predicated on: 1) the assumptibn that we want to be one 

of the first groups (post SCQTUS decision) to go live so as to athact potential-additional 

funding; 2) how we cati have an impact in potential primaries either with.positi:ve or 

4 nisgatlve. approach; arid 3) getting our first ad. flight up so,both caiwlidafe.s^d fiinder§;see 

g the impact we intend "to have in these targeted statPs. well befpre the run;up.tb the 

November election. 

In addition, given the recent activity on health care, it is clear that this will be selling: 

poiiit M for Congressional pemQcrats, We needto get into-soine of these.states.-W!th..our 

own messaging before this-single issue can be linked to claims of economic.recovery.. 

Btrt)GET: 

Given the large huniber of Senate races in contention, .we will focus on identifying a . 

.minimum of'4r6. races where media costs, political dynamics and other .factors justify our 

activity. Instead of tnaking aamall imp.adt in the dozen 0r sa^ rac.es utider cpnsideratipn, 

6ur strategy is. prediba.ted on.dbihg inpre in a smaller number of races as opposed, to a 

broad, shallow approach. 

To db this properly, we.can: expect a working budjget fprtheCQriimissibn fpr 201.0 

activities-to be a minimum of .SS > $10 'mijiion dpllars-for 4-6 races depending bn. the 

states selected. 

Attachment D MHM.FEC.qo6002. 
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