MEPlORANDUJIl

ro: FRED S. EILAND

111

PRESS OFFICER

FRO": ROBERT J. COSTA ~y ASSISTANT STAFF DIRECTOR

7)f.~DIT DIVISION

SUBJ~CT: PUBLIC ISSUANCE OF THE FINAL AUDIT REPORT ON THE DOLE ! FOR PRESIDENT COMMITTEE

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FEDERAL ELECTION COMMISSION

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April 30, 1991

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Attached please find a copy of the Final Audit Report on

the Dole for President Committee which was approved by the

Commission on April 25, 1991.

Informational copies of the report have been received by

all parties involved and the report may be released to the

public.

Attachment as stated

cc: Office of General Counsel

Office of Public Disclosure

Reports Analysis Division

FEC Library
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FEDERAL ELECTION COMMISSION

REPORT OF THE AUDIT DIVISION

ON THE

DOLE FOR PRESIDENT COMMITTEE

I. Background

A. Overview

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This report is based on an audit of the D::e for

President Committee ("the Committee") to determine whether there

has been compliance with the provisions of the Federal Election

Campaign Act of 1971, as amended ("the Act") and the Presidential

Primary Matching payment Account Act. The audit was conducted

pursuant to 26 U.S.C. 59038(a) which states that "After each

matching payment period, the Commission shall conduct a thorough

examination and audit of the qualified CampalQ~ expenses of every

candidate and his authorized committees who received payments

under Sec.tion 9037."

In addition, 26 U.S.C. S9039(b) and 11 C.F.R.

59038.1(a)(2) state, in relevant part, that the Commission may

conduct other examinations and audits from time to time as it

deems necessary.

The Committee registered with the Federal Election

Commission on March 13, 1987. The Committee's current mailing

address is in McLean, Virginia.

The audit covered the period from the Committee's

inception, February 1987, through April 30, 1988. In addition,

certain other financial activity relating to the Committee's

Statement of Net outstanding Campaign Obligations was reviewed

through September 12, 1988. Records relating to the Committee's

state allocations were reviewed through March 1989.

The Committee reported an opening cash balance of $-0-

total receipts of $26,856,123.99, total disbursements of

$26,336,211.41, and a closing cash balance of $519,912.58 on April

30, 1988. Under 11 C.F.R. §9038.1(e)(4), additional audit work

may be conducted and addenda to this report issued as necessary.

This report is based upon documents and Yorkpapers which

support each of the factual statements. They form part of the

record upon which the Commission based its decisions on the

matters in the report and were available to Commissioners and

appropriate staff for review.
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B. ~ey Personnel

The treasurers of the Committee from its incept30n to

the present are as follows:

Marynell D. Reece Inception - 5/18/88

James L. Hagen 5/19/88 - 2/1/89

Scott E. Morgan 2/2/89 - 7/14/90

James L. Hagen 7/15/90 - Present

C. Scope

The audit included such tests as verification o( total

reported receipts and expenditures and individual transactions;

review of required supporting documentation; review of

contribution and expenditure limitations; and other audit

procedures as deemed necessary under the circumstances.

II. Audit Findings and Recommenu~Lions Related to Title 2 of the

united States Code

A. Apparent In-Kind Corporate Contributions

Under Section 441b of Title 2 of the United States Code,

it is unlawful for any corporation to make a contribution or

expenditure in connection with any election at which presidential

and vice presidential electors or a Senator or Representative in,

or a Delegate or Resident Commissioner to, Congress are to be

voted for, or in connection with any primary election or political

convention or caucus held to select candidates for any of the

forgoing offices, or for any candidate, political committee or

other person knowingly to accept or receive any contribution

prohibited by this section.

Section lOO.7{A){1){iii) of Title 11 of the Code of

Federal Regulations states that the term "contribution" includes a

gift, subscription, loan, advance, or deposit of money or anything

of value. The term "anything of value" includes all in-kind

contributions. Unless specifically exempted under 11 C.F.R.

S100.7{b), the provision of goods or services without charge or at

a charge which is less than the usual and normal charge for such

goods or services is a contribution.

1. Media Commissions

The Committee contracted with Multi Media Services

Corporation (MMSC) to provide media placement services and they

contracted with Ringe Media, Inc. (RMI) to provide media planning

and production.
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In return for the performance of these services,

the committee paid MMSC a commission equal to 4\ of total gross

billings for commercials placed. In addition, the Committee paid

RMI a commission equal to 1.5% of gross billings for air time for

commercials produced by RMI. Therefore, the Committee paid an

overall commission of 5.5\.

In the Interim Audit Report, the Audit staff

recommended that the Committee provide evidence which demonstrates

that the 4\ commission paid MMSC for media placement and the 1.S\

commission paid to RMI for apparent production costs do not

constitute the provision of services at less than the usual and

normal charge and thus are in-kind contributions from MMSC and

RMI. It was further noted that the Audit staff would review any

information provided and make additional recommendations with

regard to this matter.

In the Committee's response to the Interim Audit

Report, the Committee Treasurer stated that they " ... entered into

arms-length negotiation with Multi Media and reached an agreement

of four percent based on the expected amount of media purchases to

be made by DFP~/ during the campaign." The following statement was

provided by the president of MMSC:

I hereby swear that to the best of my knowledge the fee

charged the Dole for PreSl .... ut Commi t tee Inc., by my £i rm

was competitively priced for the presumed magnitude of

the expenditures. The fee was well within "market

levels" based on the contractual arrangements my firm had

at that time.

The Audit staff acknowledges that the trend in the

advertising industry is toward a fee arrangement and accepts the

representations made by the president of MMSC.

The Audit staff notes that for this analysis, the

1.5% paid to RMI for production costs was combined with the 4%

commission paid to MMSC for placement fees in order to compare the

overall commission to the more common situation where these

services were provided by a single firm. It is our opinion that

based on the industry trends and the statement made by the

president of MMSC, the two firms involved were reasonably

compensated.

Recommendation 11

The Audit staff recommends no further action with regard to

this matter.

~/ DFP refers to the Dole for President Committee.
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2. Non-Salaried Staff Members Employed by Others

During the review of disbursements, the Audit staff

noted six committee staff persons who received no salary from the

Committee./. However, materials contained in Committee files

(business-cards, letterhead, stationery, correspondence, etc.)

indicates that these persons were employed by other organizations.

No information was available to determine if these employees were

receiving regular salary payments from their other employers while

volunteering for the Committee, or if they were using vacation

time.

If four non-Senate staff persons were receiving

salaries from incorporated entities while in a non-vacation

status, possible corporate contributions from their employers to

the Committee may have occurred. If their regular employers were

not incorporated, it appeared likely that excessive contributions

had been received.

At the exit conference, the Committee was provided

with a list of the six staff persons involved along with their

employers, and were requested to provide information to the Audit

staff regarding any outside salary received by these persons.

In the Interim Audit Report, the Audit staff

recommended that the Committee take the following action:

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Provide evidence that the two staff persons

apparently employed by Senator Dole's office were

on the u.S. Senate payroll.

Provide information regarding salaries received by

the other four staff persons from other employers

while performing volunteer services for the

Committee. If one or more of these persons were

being paid by their regular employers, evidence

indicating whether regular vacation time was being

charged. Otherwise, value determinations would be

necessary as well as refunds to their regular

employers.

In the Committee's response to the Interim Audit

Report, the Committee Treasurer stated that a number of volunteers

were employed while working for the Committee and that he suspects

this is a common situation. He notes that they " ...made it very

clear that work done in behalf of DFP was to be done on an

individual's own time, whether after normal hours or on vacation

or other leave time."

~/ Two of these six staff persons were apparently employed by

Senator Dole'S U.S. Senate office.
, '

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Included with the Committee's response are

statements from four of the six Committee staff persons who

received no salary from the Committee. One of these four was

apparently employed by Senator Dole's U.S. Senate office. He adds

that they were unable to locate the other two individuals listed.

Based on the documentation provided by the

Committee, the Audit staff accepts the Committee's explanation.

Recommendation 12

The Audit staff recommends no further action with regard to

this matter.

B. Disclosure of Contribution Reattributions

Sections 434(b)(3)(A) and (B) of Title 2 of the United

States Code state that each report under this section shall

disclose the identification of each person who makes a

contribution to the reporting committee during the reporting

period, whose contributions have an aggre3ate amount or value in

excess of $200 within the calendar year, together with the date

and amount of any such contribution and each political committee

which makes a contribution to the reporting committee during the

reporting period, together with the date and amount of any such

contribution.

Under 11 C.F.R. S104.8(d)(3), if an itemized

contribution is reattributed by the contributor(s) in accordance

with 11 C.F.R. S110.1(k), the treasurer shall report the

reattribution in a memo entry on Schedule A of the report covering

the reporting period in which the reattribution is received. The

memo entry for each reattributed contribution shall be reported in

the following manner:

(i) The first part of the memo entry shall disclose all

of the information for the contribution as it was originally

reported on Schedule A;

(ii) The second part of the memo entry shall disclose

all of the information for the contribution as it was reattributed

by the contributors, including the date on which the reattribution

was received.

During the review of contributions, the Audit staff

identified an apparent problem with the Committee's FEC disclosure

reports. Contributions received by the Committee which were less

than or equal to $1,000 and for which a reattribution letter had

been submitted to the Committee were not amended on the FEC

reports, unless the letter was received in the same reporting

period as the contribution.
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This situation was brought to the Committee's attention

during the audit fieldwork and a comprehensive amendment was filed

on November IB, 19BB which materially corrected this disclosure

problem.

Recommendation 13

As in the Interim Audit Report, the Audit staff recommends no

further action regarding the contribution reattribution disclosure

problem discussed above.

C. possible "Testing the Waters" Expenditures Made by

the Dole for Senate Committee

section 9034.4(a)(2) of Title 11 of the Code of Federal

Regulations states that even though incurred prior to the date an

individual becomes a candidate, payments made for the purpose of

determining whether an individual should become a candidate, such

as those incurred in conducting a poll, shall be considered

qualified campaign expenses if the individual subsequently becomes

a candidate and shall count against the candidate's limits under 2

U.S.C. 441a'b).

Section lOO.8(b)(1) of Title 11 of the Code of Federal

Regulations states, in part, that the term "expenditure" does not

include payments made solely for the purpose of determining

whether an individual should become a candidate. If the

individual subsequently becomes a candidate, the payments made are

subject to the reporting requirements of the Act. Such

expenditures must be reported with the first report filed by the

principal campaign committee of the candidate, regardless of the

date the payments were made.

Section 100.7(a) of Title 11 of the Code of Federal

Regulations states that a contribution includes a gift,

subscription, loan, advance or deposit of money or anything of

value by any person for the purpose of influencing any election

for Federal office. The term "anything of value" includes in-kind

contributions.

The Audit staff reviewed the disclosure reports filed

with the Federal Election Commission by the 1986 Dole for Senate

Committee (DFS) to determine if any of the disclosed activity

appeared to relate to the Presidential campaign. A group of

transactions were identified as possible testing-the-water

expenses. A request for the records relating to these

transactions was made by the Audit staff and again by the

Commission. After both were refused, the requested records were

subpoenaed ~y the Commission.

The Audit staff reviewed documentation related to

21 DFS di~LJ'3ements paid between April 24, 1986 and December 18,

1986. Eighteen of these payments were to payees located in

Michigan which were possibly related to the Michigan Caucus held
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in August 1986. The other three items were for newspaper

subscriptions in Iowa and New Hampshire.

Based on our review of the documentation, the Audit

staff noted that the 18 disbursements to Michigan payees appeared

to be related to a Detroit fundraiser held on July 1, 1986.

However, the documentation does not provide any information as to

whether this event was for the candidate's Senate campaign or if

it was possible "testing the waters" activity for his Presidential

campaign. No solicitation materials related to this event were

made available for our review. However, none of the contributions

raised at the event appear to have been received by the Committee.

At the exit conference the Committee Treasurer

stated that he had obtained affidavits from a 1986 DFS consultant

attesting to the fact that this event was related to the

candidate's Senate campaign. This consultant was later a Dole for

president employee. No affidavits were provided to the Audit

staff.

In the Interim Audit Report, it was recommended

that the Committee provide the affidavits attesting to the fact

that this event was related to the candidate's Senate campaign,

and all relevant documents including copies of any solicitation

materials associated with the event.

The Committee's response to this recommendation

included a copy of an affidavit from Kirk Clinkenbeard which

states that in 1986, Senator Dole was seeking reelection to the

United States Senate from Kansas; that a fundraiser was held in

Michigan on July 1, 1986; that the fundraiser was for the

exclusive benefit of Dole for Senate Committee; and that no other

committee received any of the funds from the fundraiser. The

Committee also states that none of the requested solicitations

were found.

The Audit staff notes that the fundraiser was held

in Michigan rather than Kansas; that the event was held in the

month preceding the Michigan election of precinct delegates, the

first step in the selection of Republican National Convention

delegates; that the Dole for Senate Committee had sufficient

excess campaign funds to transfer $1,150,000 to the Committee; and

that Senator Dole received 71% of the vote in the 1986 general

election.

The Commission determined that this activity was

not related to testing the waters and therefore no further action

is warranted.

Recommendation 14

Based on the Commission's determination, no further action is

necessary with regard to this matter.
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D. Itemization of Contributions from Political Committees

and Unregistered organizations

Section 434(b)(3)(B) of Title 2 of the United States

Code states that each report shall disclose the identification of

each political committee which makes a contribution to the

reporting committee during the reporting period, together with the

date and amount of any such contribution.

The Committee's receipt records were reviewed to

determine whether all contributions from political committees were

itemized. The Audit staff determined that 35 contributions from

30 committees, totaling $14,030.00, were not itemized as required.

Twelve of these contributions, from 11 unregistered organizations,

total $2,235.00.

The Committee was provided a schedule of these items at

the exit conference.

At the exit conference, the former Committee Treasurer

stated that they had employed strict controls for the recording of

contributions in excess of $200 and that it was possible that somo

of the ones under $200.01 could have been recorded under an

individual's name (such as the treasurer of the PAC) and that

these items may have been reported in the unitemized contributions

total. He added that some of the contributions in excess of $200

could have been itemized on the FEC reports under an individual's

name.

The Audit staff notes that the explanations provided by

these Committee officials are reasonable since our reconciliation

of the Committee's bank accounts to their disclosure reports

resulted in immaterial differences.

In the Interim Audit Report, the Audit staff recommended

that the Committee file amended Schedules A-P to correct the

itemization of contributions from political committees and

unregistered organizations.

The Committee Treasurer states in his response to the

Interim Audit Report that they agree that the Committee received

15 of the 3S contributions noted in the report, but that 8 of

these items are "not political committees as defined in the

Regulations and are below the $200.01 itemization threshold." He

further states that "if the Commission believes it appropriate,

OFP will amend its reports to reflect these contributions." He

adds that the remaining 7 contributions "should be reported and

OFP will so amend its reports."

The Audit staff notes that 11 C.F.R. S104.3(a)(4){ii)

requires all committees to itemize the identification of each

contributor and the aggregate year-to-date total for such

contributor for all committees {including political committees and

committees which do not qualify as political committees under the
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Act) which make contributions to the reporting committee during

the reporting period, together with the date of receipt and amount

of any such contribution.

The Committee's response further states that the

Committee has no record of the other 20 of the 35 contributions

noted in the report. The Treasurer again points out that one of

these contributions " •.. falls under itemization threshold as it is

not a 'political comittee'." The Committee adds that for the 6

contributions (out of these 20) for which the auditors have check

copies, they believe that "they may have been earmarked

contributions itemized under the name of the actual contributor"

and that "[flor those which the auditors got their information

from the E Index, DFP believes it either did not receive the

contributions or that they were treated as earmarked." He

concludes that "DFP is ready to amend its reports at the direction

of the Commission."

The Committee's suggestion that some contributions may

have been reported in the name of an individual reiterates

comments made at the exit conference. Though the Committee has

provided no additional information in the response to the Interim

Audit Report, the following is noted.

Of 35 contributions noted in the Interim Audit Report, 6

totaling $680.00 appear to have been earmarked and are deleted

from the finding. Six contributions totaling $700.00 are recorded

in the Committee's contribution data base in the name of an

individual but are not itemized on Committee disclosure reports.

All but one of these is $200 or less. Seven contributions are

both recorded in the name of an individual and itemized on the

Committee's reports under the recorded name. These seven

contributions total $3,350.00.

An additional seven items are found recorded in the

Committee's contribution data base under the contributing

committee's name but are not found itemized on Committee

disclosure reports. Only two of these contributions are in excess

of $200.00. These total $1,785.00. The remaining 9 contributions

totaling $7,515.00 were taken from the contributing Committees'

reports and no further information is available concerning these

contributions. The Audit staff has not deleted these items given

the apparent problems that the Committee had with the recording of

contributions from political and other committees in the name of

individuals.

In summary, the Committee has apparently received 29

~"~~ibutions totaling $13,350.00 from political and other

ro.\mLttees which are not itemized or are incorrectly itemized.

~hp. Audit staff acknowledges that some portion of these may have

been earmarked contributions for which no evidence of the

?armarking is available.
The committee's response to the Interim Audit Report did

not include amended Schedules A-P to correct the itemization

problem noted above. Due to the immaterial total of these

omissions, the Commission determined that no further action is

warranted.

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Recommendation *5

Based on the Commission's determination, no further action is

necessary with regard to this matter.

E. Dole for President Delegate Committees

The Audit staff identified eighteen delegate committees

apparently formed to support Senator Dole's campaign. Fifteen of

these committees were located in Illinois and three in Maryland.

Senator Dole authorized thirteen of these delegate committees on

amendments to his Statement of Candldacy. Four of the five nonauthorized delegate committees filed Statements of Organization

with the Federal Election Commission and listed the Committee as

an affiliate.

1. Prohibited Contributions (Delegate Committees)

Under Section 441b of Title 2 of the United States

Code, it is unlawful for any corporation to make a contribution or

expenditure in connection with any election at which presidential

and vice presidential electors or a Senator or Representative in,

or Delegate or Resident Commissioner to, Congress are to be voted

for, or in connection with any primary election or political

convention or caucus held to select candidates for any of the

forgoing offices, or for any candidate, political committee or

other person knowingly to accept or receive any contribution

prohibited by this section.

Section l03.3{b)(1) of Title 11 of the Code of

Federal Regulations states that, contributions that present

genuine questions as to whether they were made by corporations may

be, within ten days of the Treasurer's receipt, either deposited

into a campaign depository or returned to the contributor. If any

such contribution is deposited, the Treasurer shall make his or

her best efforts to determine the legality of the contribution.

If the contribution cannot be determined to be legal, the

Treasurer shall, within thirty days of the Treasurer's receipt of

the contribution, refund the contribution to the contributor.

Section 103.3{b){4) states that any contribution

which appears to be illegal and which is deposited into a campaign

depository shall not be used for any disbursements by the

political committee until the contribution has been determined to

be legal. The political committee must either establish a

separate account in a campaign depository for such contributions

or maintain sufficient funds to make all such refunds.
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Based on our review of the available delegate

committee records, the Audit staff identified 14 contributions

from corporations, totaling $1,350, which were not refunded or not

refunded in a timely manner.~/ These contributions were made to

the Sixth Congressional District Delegate Dole committee

(Illinois), Dole for President 17th District Committee (Illinois),

and the 20th Congressional District Dole Delegates Committee

(Illinois) •

This matter was not noted in the Interim Audit Report

because the records used to make this determination had not yet

been obtained for our review. Due to the immaterial total of

these items, the Commission determined that no further action is

warranted.

Recommendation 16

Based on the Commission's determination, no further action is

necessary with regard to this matter.

2. Apparent Excessive Contributions (Delegate

Commi ttees)

Section 44la(a)(1)(A) of Title 2 of the United

States Code states that no person shall make contributions to any

candidate with respect to any election for Federal office which,

in the aggregate, exceed $1,000.00.

Section 110.1(k) of Title 11 of the Code of Federal

Regulations states, in part, that any contribution made by more

than one person, except for a contribution made by a partnership,

shall include the signature of each contributor on the check,

money order, or other negotiable instrument or in a separate

writing. A contribution made by more than one person that does

not indicate the amount to be attributed to each contributor shall

be attributed equally to each contributor. If a contribution to a

candidate on its face or when aggregated with other contributions

from the same contributor exceeds the limitations on

contributions, the Treasurer may ask the contributor whether the

contribution was intended to be a joint contribution by more than

one person. A contribution shall be considered to be reattributed

to another contributor if the treasurer of the recipient political

committee asks the contributor whether the contribution is

intended to be a joint contribution by more than one person, and

informs the contributor that he or she may request the return of

the excessive portion of the contribution if it is not intended to

be a joint contribution; and within sixty days from the date of

~/ Section 103.3(b) of the Code of Federal Regulations was

amended effective April 8, 1987. However, it is the

opinion of the Audit staff that t~.J contribution refunds

were not made within a reasonabl) ~\me as required by the

previous regulation.
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the treasurer's receipt of the contribution, the contributors

provide the treasurer with a written reattribution of the

contribution, which is signed by each contributor, and which

indicates the amount to be attributed to each contributor if equal

attribution is not intended.

Section 103.3(b)(3) of Title 11 of the Code of

Federal Regulations states, in part, that contributions which

exceed the contribution limitation may be deposited into a

campaign depository. If any such contributions are deposited, the

treasurer may request redesignation or reattribution of the

contribution by the contributor in accordance with 11 C.F.R. S

110.1(b), 110.1(k) or ll0.2(b), as appropriate. If a

redesignation or reattribution is not obtained, the treasurer

shall, within 60 days of the treasurer's receipt of the

contribution, refund the contribution to the contributor.

Section 103.3(b)(4) of Title 11 of the Code of

Federal Regulations states, in part, that any contribution which

appears to be illegal and which is deposited into a campaign

depository shall not be used for any disbursements by the

political committee until the contribution has been determined to

be legal. The political committee must either establish a separate

account in a campaign depository for such contributions or

maintain sufficient funds to make such refunds.

Section 44la(f) of Title 2 of the United States

Code states that no candidate or political committee shall

knowingly accept any contribution in violation of any limitation

on contributions.

Section 110.3(a) states that for the purposes of

the contribution limitations, all contributions made or received

by more than one affiliated committee, regardless of whether they

are political committees, shall be considered to be made or

received by a single political committee.

AS noted above, the Interim Audit Report

recommended that the Committee provide the records for the

delegate committees which are affiliated with the Dole for

President Committee. At the same time, requests were sent by the

Commission directly to the delegate committees and subpoenas for

records were sent to the delegate committees' banks. The records

obtained from these requests and subpoenas were reviewed to

determine if any contributions in excess of the limitations had

been received.

It was determined that one individual had made an

excessive contribution to the Delegates for Dole - 8th

Congressional District-Illinois in the amount of $150.00 and that

two individuals had made excessive contributions to the Sixth

Congressional District Delegate Dole Committee (Illinois) when
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their contributions to the Delegate Committee were aggregated with

their contributions to the Dole for President Committee. The

excessive portion of these two contributions totals $1,040.00.

Since the delegate committee records were not obtained

or reviewed prior to the completion of the Interim Audit Report,

this matter was not addressed in the Interim Audit Report. Due to

the immaterial total of these items, the Commission determined

that no further action is warranted.

Recommendation .7

Based on the Commission's determination, no further action is

necessary with regard to this matter.

F. Matters.Referred to the Office of General Counsel

Other matters noted during the audit have been referred

to the Commission's Office of General Counsel.

III. Findings and Recommendations Related to Title 26 of the

United States Code

A. Calculation of 'Repayment Ratio

'1'" Section 9038(b)(2)(A) of Title 26 of the United States

Code states that if the Commission determines that any amount of

any payment made to a candidate from the matching payment account

was used for any purpose other than to defray the qualified campaign expenses with respect to which such payment was made, it

shall notify such candidate of the amount so used, and the candidate shall pay to the Secretary an amount equal to such amount.

Section 9038.2(b)(2)(iii) of Title 11 of the Code of

Federal Regulations states, in part, that the amount of any

repayment sought under this section shall bear the same ratio to

the total amount determined to have been used for non-qualified

campaign expenses as the amount of matching funds certified to the

candidate bears to the total amount of deposits of contributions

and matching funds, as of the candidate's date of ineligibility.

The formula und appropriate calculation with respect to

the committee's receipt activity is as follows:
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Total Matching Funds Certified through the

Date of Ineligibility - 3/29/88

Numerator plus Private Contributions Received

through 3/29/88

$6,604,354.65

- .278907

$6,604,354.65 + $17,075,095.59

Thus, the repayment ratio for non-qualified campaign

expenses is 27.8907 percent.

B. Determination of Net Outstanding Campaign Obligations

Section 9034.5{a) of Title 11 of the Code of Federal

Regulations requires that within 15 calendar days of the

candidate's date of ineligibility, the candidate shall submit a

statement of net outstanding campaign obligations which contains,

among other items, the total of all outstanding obligations for

qualified campaign expenses and an estimate of necessary winding

down costs.

In addition, 11 C.F.R. S9034.I(b) states, in part, that

if on the date of ineligibility a candidate has net outstanding

obligations as defined under 11 C.F.R. 59034.5, that candidate may

continue to receive matching payments provided that on the date of

payment there are remaining net outstanding campaign obligations.

The statement of Net Outstanding Campaign Obligations

(NOCO) is the basis for determining further matching fund

entitlement. Senator Dole's date of ineligibility was March 29,

1988. Consequently, he may only receive matching fund payments to

the extent that he has net outstanding campaign obligations as

defined in 11 C.F.R. 59034.5.

The Committee filed a NOCO statement which reflected the

Committee's financial activity at March 29, 1988 and filed revised

NOCO statements with each subsequent matching funds request. The

Audit staff analyzed the Committee's September 12, 1988 NOCO,

which accompanied their final matching funds request, and made

adjustments to the NOCO by reviewing the Committee's financial

activity as of that date. A review of the Committee's financial

records through February 28, 1989 and the Committee's disclosure

reports through December 31, 1990 was performed to adjust the NOCO

figures. The Committee's NOCO as adjusted by the Audit staff

appears below:
-15-

Dole for President

Statement of Net outstanding 'campaign obligation.

as of September 12, 1988 ~/

ASSETS

Cash in Banks

Accounts Receivable

Capital Assets

TOTAL ASSETS

LIABILITIES

Accounts Payable for

Qualified Campaign

Expenses as of 9/12/88

Contribution Refunds:

Paid between 9/13/88-

12/31/90

Due for Excessive

Contributions:

Inds/Pol. Comtes

Campaign America

Due for Prohibited

Contributions

Total Contribution Refunds

Payments for Non-Oualified

Campaign Expenses 3/30/88-

9/12/88

winding Down Costs

Salaries/Consulting

Admin and Finance

Additional Winding Down

Costs Noted Subsequent

to Interim Audit Report

Estimated winding Down

Costs (as of 12/31/90)

Total Winding Down Costs

Checks voided Subsequent

to Interim Audit Report

TOTAL LIABILITIES

$115,972.78

178,868.43 ~/

4,500.00

155,262.17 £/

$ 5,900.00 ~/

13,975.00

42,247.24 !/

60,842.38

122,964.62

(33,582.65) !/

40,222.44 c/

51,466. 22 ~/~/

63,308.27 h/

11 , 305 . 75 hi

166,302.68

(42,854.20) h/

$299,341. 21

368,092.64

Net outstanding Campaign Obligations $(68,751.4:
~/

~/

!./

!/

.9/

-16-

Notes to September 12, 1988

Statement of Net Outstanding Campaign Obligations

All figures shown were determined as of 9/12/88 unless

otherwise noted.

Accounts Receivable includes refunds, rebates and

reimbursements received between 9/13/88 and 12/31/90. Amounts

received between 9/13/88 and 11/30/88 were verified via the

Committee's Accounts Receivable records. Figures between

12/1/88 and 12/31 /90 are per reports filed and are subject to

audit verificatlon.

These amounts include actual payments and estimated amounts

based in part on Committee disclosure reports and are thus

subject to change.

Contribution Refunds paid between 9/13/88 and 12/31/90

include refunds of prohibited contributions, contributions

with incorrect payees and other refunds. Figures included

are per reports filed and are subject to audit verification.

Excessive in-kind contribution related to testing the waters

expenditures made by Campaign America (See Finding

III.C.12.).

Under 11 C.F.R. S9034.4(b}(2}, an expenditure which is in

excess of any of the limitations under 11 C.F.R. Part 9035

shall not be considered a qualified campaign expense, which

precludes such expenditures from inclusion in the NOCO

presentation as set forth at 11 C.F.R. S9034.5. These

expenditures were determined by the Audit staff to be

allocable to Iowa or New Hampshire and are included in

Finding C.9. and 10.

Admin and Finance includes travel costs, rent, office space,

other overhead costs and fundraising.

These figures are subject to audit verification.
ltF~!r.·f(,~~-.\\:<~~~~~-;~.:.·;:;·.... -.. -

'-t

-17-

- 1~ .'

Therefore, as of September 12, 1988, the candidate's

maximum remaining entitlement was $68,751.41. Using the

Commission's matching fund records and the Committee's disclosure

reports as verified by the Audit staff, it was determined that the

Committee received $19,962.83 in private and public funds between

September 13, 1988 and September 30, 1988, the date of receipt for

the Committee's final matching funds payment.

Conclusion

As of September 30, 1988, the date of receipt for the

Committee's final matching funds payment, the candidate had not

received matching funds in excess of entitlement. This analysis

is subject to change based on future adjustments to the NOCO

statement.

C. Use of Funds for Non-Qualified Campaiqn Expenses - Allocation of Expenditures to States

Section 9035(a) of Title 26 of the United States Code

states, in part, that no candidate shall knowingly incur qualified

campaign expenses in excess of the expenditure limitations

applicable under section 441a(b)(1)(A) of Ti~le 2.

Section 9038.2(b)(1)(A) of Title 11 of the Code of

Federal Regulations provides, in part, that the Commission may

determine that amount(s) of any payments made to a candidate from

the matching payment account were used for purposes other than to

defray qualified campaign expenses. Section 9038.2(b)(2)(ii)(A)

states that an example of a Commission repayment determination

under paragraph (b)(2) of this section includes determinations

that a candidate, a candidate's authorized committee(s) or agents

have made expenditures in excess of the limitations set forth in

11 C. F.R. 59035.

Sections 441a(b)(1)(A) and 441a(c) of Title 2 of the

United States Code and Section 9035(a) of Title 26 of the United

States Code provide, in part, that no candidate for the office of

President of the United States who is eligible under Section 9033

of Title 26 to receive payments from the Secretary of the Treasury

may make expenditures in anyone State aggregating in excess of

the greater of 16 cents multiplied by the voting age population of

the State, or $200,000, as adjusted by the change in the Consumer

Price Index.

Section 106.2(a)(1) of Title 11 of the Code of Federal

Regulations states, in part, that expenditures incurred by a

candidate's authorized committee(s) for the purpose of influencing

the nomination of that candidate for the office of President with

respect to a particular State shall be allocated to that State.

An expenditure shall not necessarily be allocated to the State in

which the expenditure is incurred or paid. In the event that the

Commission disputes the candidate's allocation or claim of

exemption for a particular expense, the candidate shall
,-

-18-

demonstrate, with supporting documentation, that his or her

proposed method of allocation or claim of exemption was

reasonable. Further, 11 C.F.R. SI06.2(c) describes the various

types of activities that are exempted from state allocation.

Section 106.2(c)(S) of Title 11 of the Code of Federal

Regulations states, in part, that an amount equal to 10\ of

campaign workers salaries and overhead expenditures in a

particular State may be excluded from allocation to that State as

an exempt compliance cost. An additional amount equal to 10\ of

such salaries and overhead expenditures in a particular State may

be excluded from nllocation to that State as exempt fundraising

expenditures, but this exemption shall not apply within 28

calendar days of the primary election.

Section 106.2(b)(2)(iv) of Title 11 of the Code of

Federal Regulations states, in part, that overhead expenditures

include, but are not limited to, rent, utilities, office

equipment, furniture, supplies, and telephone service base

charges.

For the 1988 election, the expenditure limitation for

the State of Iowa was $775,217.60 and for the State of New

Hampshire was $461,000.00. The Committee provided computerized

worksheets to the Audit staff that indicated allocable costs to

Iowa and New Hampshire of $793,230.82 and $462,462.20

respectively, as of October 31, 1988. These totals agreed with

the totals disclosed by the Committee on its FEC Form 3P, Page 3

as of March 31, 1989.

The Audit staff reviewed the Committee's allocation

worksheets and analyzed the Committee's allocation methods. Based

on this review the following additions to the Committee's

allocation totals are required.

1. Twenty-Five Percent Fundraising Exemption -

Travel, Events - Senator Dole and Events -

Elizabeth Dole

The Committee applied a 25 percent fundraising

exemption to the following expense code categories: Travel

(Intra-state), Events - Senator Dole, and Events - Elizabeth Dole.

The Committee did not apply the exemption to expenses within 28

days of either primary election.

The Committee Treasurer stated that the 25 percent

exemption was taken to reflect the fundraising efforts associated

with these three categories. He explained that whenever Senator

Dole and Elizabeth Dole were traveling, they would make a request

for contributions. Twenty-five percent was selected by the

Committee as a "reasonable" judgment of what these requests were
-19-

'~',

worth to the Committee's fundraising efforts. No explanation for

the inclusion of the Travel category in this calculation was

offered by the Committee. No other evidence to support this

exemption was provided.

Neither the Act nor the Commission's Regulations

provide for a fundraising exemption for these expense categories.

In the Interim Audit Report, the Audit staff noted that in the

staff's opinion the Committee had not demonstrated that 25 percent

fundraising exemption is reasonable. It was also noted that,

absent the submission of documentary evidence to demonstrate that

these exemptions are reasonable, the amounts excluded by the

Committee from the Iowa and New Hampshire expenditure limitations

($28,450.36 and $13,997.06, respectively) had been included in the

Audit staff's calculation. Finally, the Commlttee was requested

to submit evidence which revealed the nature of the fundraising

appeal for each event, how the appeal was delivered and the amount

of resulting contributions.

In response to the Interim Audit Report, the

committee Treasurer cites 11 C.F.R. S100.8(b)(21)(i) which he

quotes as follows:

"'Any costs incurred by a candidate •.. in connection

with the solicitation of contributions are not expenditures if

incurred by a candidate who has been certified to receive

Presidential Primary Matching Fund Payments ••. '" He continues

that "'[i]n connection with the solicitation of contributions' is

defined at 11 C.F.R. S100.8(b)(21)(ii) as meaning' ••. any cost

reasonably related to fundraising activity .•• '" The Treasurer

states that "without the transportation of Senator and Secretary

Dole through Iowa and New Hampshire, its fundraising appeal would

have been zilch."

In response to the Audit staff's Interim Audit

Report request for evidence which reveals the nature of the

fundraising appeal for each event, how the appeal was delivered

and the amount of resulting contributions, the Committee states

that "[t]he nature of the fundraising appeal was 'Please give

money,' the appeal was delivered by voice and the amount received

is irrelevant." The Treasurer further argues that the direct

costs listed in 11 C.F.R. SlOO.8(b)(21)(ii) are not exclusive and

that they must only be reasonably related to fund raising. He adds

that "[t]he fact that the Audit staff does not believe the

transportation and event costs associated with the Senator and

Secretary represent 'reasonable' fundraising costs does not

preclude them from being such costs" and adds that the Committee

took only 25\ of these costs as exempt.

The Treasurer concludes that without these costs,

the Committee would not have raised much money and that "a

reasonable person might believe that 25% of Su,h costs were

reasonably associated with fundraising."
~?J~~~~'~~"$t1YJ:~~1:<"';:"'"':~"~''''''--''''''''''" """" .•,-,...«~---,-" -".-'J> - . - "'''"~ -< -'r" -",.-•."". - -- -....-..-- -~ .... -

r'i=-':

1,f

-20-

The Audit staff reiterates that in order to exempt

from allocation the expenditures included in the three categories

discussed above, documentation supporting a fundraising appeal

which can be associated with the expenditures is necessary. Since

no such documentation was provided in the Committee's rosponse to

the Interim Audit Report, no adjustment to the allocations has

been made.

2. Fundraising Exemptions - Direct Mail Costs

The Committee separated their direct mail costs

into two categories: postage/Printing and Newsletter/Postcards.

For allocation purposes, the Committee excluded a percentage of

these direct mail costs as fundraising. This percentage varied

from item to item.

The Audit staff reviewed the documentation related

to the Iowa and New Hampshire direct mail costs which had been

given fundraising exclusions by the Committee to determine if

these exclusions were supported. These mailings were targeted for

these two states. The auditors did not accept the fundraising

exclusions for the costs which had no solicitation samples

available to review or for costs which had solicitation samples

without a request for funds.

The Committee excluded the following amounts as the

fundraising share of the direct mail costs:

Iowa

New Hampshire

$217,643.73

$ 43,877.56

Based on the Audit staff's review of supporting

documentation regarding these direct mail costs, we were able to

verify $23,369.76 of the $217,643.73 excluded by the Committee for

Iowa, leaving the solicitation of funds unverified for direct mail

costs of $194,273.97 ($217,643.73 - $23,369.76). The Audit staff

applied a 100% fundraising allocation to the $23,369.76 of direct

mail costs which contained a fundraising appeal resulting in a

credit of $20,370.42 for items not allocated 100\ by the

Committee. The adjusted unverified Iowa total is $173,903.55

($194,273.97 - $20,370.42).

The Audit staff reviewed the Committee's allocation

worksheets regarding Iowa direct mail costs and noted purposes

such as postcards announcing town meetings, Iowa newsletters,

announcement letters, etc.

For New Hampshire, the Audit staff was able to

verify $129.50 of the $43,877.56 excluded by the Committee. In

addition, the Committee includes an adjusting journal entry in the

amount of $(6,418.91) for which no support has been provided.

Therefore, the Audit staff was unable to verify $43,748.06 of the

$43,877.56 excluded by the Committee for New Hampshire ($43,877.56

- $129.50). The Audit staff applied a 100% fundraising allocation
":r;,'~~~,::i~{!!~i~~:r~;:::r" ...,,·····,,·, '~~~

~,

-21-

to the $129.50 of direct mail costs which contained a fundraising

appeal resulting in a credit of $129.50 for items not allocated

100\ by the Committee. The adjusted unverified New Hampshire

total is $43,618.56 ($43,748.06 - $129.50).

The Committee was provided copies of ~orkpapers in

support of the auditors' figures.

The Committee's response to the Interim Audit

Report includes explanations and documentation related to Iowa

direct mail costs which the Committee believes documents a 50\

fundraising exemption for several items noted as unverified by the

auditors.

Based on our review of this information, the Audit

staff has determined that of the $173,903.55 noted as unverified

Iowa direct mail costs, $121,967.77 of these costs contained a

direct fundraising appeal. Included in this amount is postage

which as a result of material submitted can be associated with a

particular solicitation. Included in this amount is postage which

as a result of documents submitted can be associated with a

particular solicitation. The remaining $51,935.78 ($173,903.55 -

$121,967.77) is still unverified and is allocable to the Iowa

state limit.

The Committee's response did not address the

$43,618.56 of unverified New Hampshire direct mail costs and

therefore $43,618.56 is allocable to the New Hampshire state

limit.

It should be noted that the Audit staff applied

100% of the direct mail costs which contained a fundraising appeal

to exempt fundraising, as opposed to the 50% requested by the

Committee.

3. Allocation of Intra-State Phone Calls Paid for

With Telephone credit Cards

Section 106.2(a)(1) of Title 11 of the Code of

Federal Regulations states, in part, that expenditures incurred by

a candidate's authorized committee(s) for the purpose of

influencing the nomination of that candidate for the office of

President with respect to a particular State shall be allocated to

that State.

The Audit staff reviewed Committee headquarters

telephone bills from April 1987 through March 1988 to determine

the total amounts of intra-statp t~~~pe calls made in Iowa and New

Hampshire which were charged on Co~~\ttee telephone credit cards.

The Committee did not allocate the.:;~ intra-state calls to the

appropriate states. No explanation for this omission was provided

by the Committee.
-22-

The total of intra-state calls, adjusted for the

10\ compliance and 10% fundraising exemptions, are as follows:

Iowa

New Hampshire

$23,280.46

$ 1,696.44

In the Committee's response to the Interim Audit

Report, the Committee states that they agree with these

allocations.

4. Phone Bank Operations

Section 106.2(a)(1) of Title 11 of the Code of

Federal Regulations states, in part, that expenditures incurred by

a candidate's authorized committee{s) for the purpose of

influencing the nomination of the candidate for the office of the

President with respect to a particular State shall be allocated to

that State. An expenditure shall not necessarily be allocated to

the State in which the expenditure is incurred or paid.

Section 110.8(c)(2) of Title 11 of the Code of

Federal Regulations states that for State limitations,

expenditures for fundraising activities targeted at a particular

State and occurring within 28 days before that state's primary

election, convention or caucus shall be presumed to be

attributable to the expenditure limitation for that State.

The Committee had a phone bank operation located in

Kansas City, Kansas from July 1987 through February 1988 and

another in Wisner, Nebraska from October 1987 through February

1988. The auditors requested copies of the phone bank scripts but

the Committee never provided them.

Kansas City Phone Bank

The Audit staff reviewed u.S. Sprint telephone

invoices which contained 42,544 phone calls from the Kansas City

phone bank, of which 5,587 (13%) were calls made to Iowa telephone

numbers. The total cost of the Iowa calls was $1,054.80. Calls

made to New Hampshire were determined to be immaterial.

To derive the Iowa share of the other related phone

bank costs, the Audit staff applied the 13% (Iowa percentage) to

the other cost categories on the phone bills: Federal Excise Tax,

Features Federal Taxes, Wats Equipment Charge and Volume Discount.

The total Iowa share of these costs is $73.01. The 13% was then

applied to Rent, Salaries, and Reimbursements related to the phone

bank. These costs were also adjusted for the 10\ compliance and

10\ fundraising exemptions. The total Iowa share of these costs is

$2,328.30. The total Iowa portion of the Kansas City phone bank

is therefore $3,456.11 ($t,OS4.80 + $73.01 + $2,328.30).

The Commi t i..~L lid not a lloca te any of the costs

associated with the Kansas City phone bank to Iowa. At the exit
,-

-23-

conference, the Treasurer stated that the Kansas City phone bank

was set up to influence the entire country and therefore, the

costs are not allocable to Iowa. He cited 11 C.F.R.

Sl06.2(b}(2)(v) which states that expenditures for telephone calls

between two States need not be allocated to any state.

The Committee was provided with copies of

vorkpapers in support of the auditors' figures at the exit

conference.

In the response to the Interim Audit Report, the

Committee stated that they agreed with the Audit staff's

allocation of $73.01 to Iowa as the Iowa share of the other

related Kansas City phone bank costs. They also agreed with the

allocation of $2,328.30 to Iowa as the Io~a share of Rent,

Salaries and Reimpursements related to the Kansas City phone bank.

However, the Committee did not agree with the

allocation to Iowa of $1,054.80 of Iowa telephone call charges

made from the Kansas City phone bank. The Committee cited 11

C.F.R. S106.2(b)(2)(v} which states that expenditures for

telephone calls between two states need not be allocated to any

state. The Committee asserted that "OFP fails to see how such

plain language can be interpreted in any vay except to exempt toll

charges from state allocation."

The Committee added that they did not find any

language in the Regulations or appropriate Explanations and

Justifications, as cited by the auditors in the Interim Audit

Report, that refuted the "plain meaning" of 11 C.F.R.

SI06.2(b} (2) (v).

The Committee also cited 11 C.F.R. SI06.2(b)(1)

which states that unless otherwise specified under 11 C.F.R.

SI06.2(b)(2), an expenditure incurred by a candidate's authorized

committee(s) for the purpose of influencing the nomination of that

candidate in more than one state shall be allocated to each state

on a reasonable and uniformly applied basis. The Committee then

noted that "[i)n case anyone wonders if the toll charges involved

here qualify as an 'expenditure' for interstate calls, it should

be noted that OFP paid the cost of these calls directly and that

no third party was involved.

The Committee Treasurer additionally quoted the

Explanation and Justification from the February 4, 1983 Federal

Register which states that "Subsection (b)(2)(v) sets forth a new

method for allocating telephone charges other than base service

charges. All calls made within a particular State must be

allocated to that state. Calls made between two states, whether

or not using toll free service, are exempted from allocation." He

added that the phrase II a re exempted f r'-ffi "llocation" was simple to

understand. The Committee Treasurer .~. -.tnued that "(i]n the 1987

rewrite of many of the state allocation cegulations the Commission

again states that 'li]nter-state calls remain exempt from
~~;'?A!~:;~':;"ki'i\' " ~~.> ....

-~\

::

-24-

allocation under paragraph (b)(2)(v).,n He added that "I again do

not see any meaning beyond what that simple statement states" and

that "[t]he Commission specifically considered the exemption and

chose not to change the language."

A similar issue arose in the audit of the 1984

presidential campaign of Senator John Glenn. In that case, the

Final Audit Report stated that the interstate telephone call

exemption was designed to eliminate the problems of trying to

allocate telephone calls between offices of a campaign committee.

Eventually, the dispute over these costs went to litigation. John

Glenn presidential Committee v. FEC, 822 F.2d 1097 (D.C. Cir. ----

1987). The Commission maintained that the regulation only applies

when an expenditure is directed at attracting voters in more than

one state. The court accepted this as a "rational explanation of

the Commission's regulations." 822 F.2d at 1102. Since Iowa

voters alone were the objectives of the telephone expenses, the

court held that the "Commission reasonably concluded that the

governing prescription was contained in 11 C.F.R. Sl06.2(a)(l)."

822 F.2d at 1102.

Since the telephone calls from the Kansas City

phone bank were not exclusively targeted to Iowa, the Commission

has determined that the $1,054.80 of telephone charges for calls

made to Iowa are not allocable to the Iowa spending limitation.

However, the $2,401.31 ($73.01 + $2,328.30) of other costs

associated with the Kansas City phone bank are allocable to Iowa.

In their response to the Interim Audit Report, the Committee

agreed with this allocation.

Nebraska Phone Bank

The Committee had a phone bank operation in Wisner,

Nebraska .•/ The Audit staff reviewed the Great Plains

Communication telephone invoices which contained 445,914 toll

calls. Of these calls 338,675 (75.95%) were calls made to Iowa

phone numbers. The cost of these Iowa calls was $106,612.38 .

..... To derive the Iowa share of the other related phone

bank costs, the Audit staff applied the 75.95% (Iowa percentage)

to the other cost categories on the phone bills: Equipment

Charges, Federal Tax, Volume Discount and Telephone Facility Fee.

The total Iowa share of these costs is a credit

of $(2,452.73). The 75.95% was then applied to Salaries and

Overhead Costs related to the phone bank. These costs were

adjusted for the 10% compliance and 10% fundraising exemptions.

The total Iowa share of these costs is $64,634.96. The total Iowa

portion of the Nebraska phone bank is therefore $168,794.61

($106,612.38 + $(2,452.73) + $64,634.96).

~/ Wisner, Nebraska is located in northeast Nebraska about 40

miles from the Iowa border.
~ti~:!$~~h1~;{?1;5\~;:';"~:'I'~';!}~;::~'" .".' '''F:·:;'· ,~.; ;,.;.~. ....., ..

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-25-

During the fieldwork the Committee Treasurer stated

that they allocated phone bank salaries and overhead costs to Iowa

but that the telephone calls made from the phone bank to Iowa were

not allocated to Iowa because they were considered interstate

calls and therefore not allocable pursuant to 11 C.F.R.

S106.2(b)(2)(v).

At the exit conference the Treasurer reiterated

that in his opinion, calls from Nebraska to Iowa were not

allocable to Iowa and the Committee had complied with the

regulations. The Audit staff explained that in our opinion, the

phone bank was set up primarily to target Iowa and therefore all

calls to Iowa are allocable to Iowa.

Based on the rationale as set forth above, the

Commission has determined that since telephone calls from the

Nebraska phone bank were not exclusively targeted to Iowa, the

$106,612.38 of telephone charges for calls made to Iowa are not

allocable to the Iowa spending limitation. Since the Committee

allocated $64,136.94 in non-telephone costs to Iowa from the

Nebraska phone bank, the Audit staff concludes that a credit in

the amount of $(1,954.71) ($64,634.96 + ($2,452.73) - $64,136.94)

should be applied to the Committee's Iowa allocations.

·r Conclusion

The Committee agrees with the Audit staff's additional

allocation related to the Kansas City phone bank for costs

associated with the phone calls made to Iowa. After the deletion

of the Iowa phone calls, the allocation to the Iowa spending

limitation for the Nebraska phone bank is overstated by a similar

amount. The resulting change to the existing allocations is

immaterial.

s. New England (NE) Regional Office

Section 106.2(b)(2)(iv)(B) of Title 11 of the Code

of Federal Regulations states, in part, that except for

expenditures exempted under paragraph (c) of this section,

overhead expenditures of a committee regional office or any

committee office with responsibilities in two or more states shall

be allocated to each State on a reasonable and uniformly applied

basis. For purposes of this section, overhead expenditures

include but are not limited to, rent, utilities, office equipment,

furniture, supplies and telephone service base

charges.

Section 106.2(a)(1) of Title 11 of the Code of

Federal Regulations states, in part, that in the event that the

Commission disputes the candidate's allocation or claim of

exemption for a particular expense, the candidate sh.,ll

demonstrate, with supporting documentation, that I'~~ or her

proposed method of allocation or claim of exemption was

reasonable.
-26-

,., ,. "<",,,,!,\;,,<.:;.,:t~~Wt''":Y''''i.:;F~~

.,'i

The Committee maintained an office in Manchester,

New Hampshire which they treated as a regional office for six

states in New England. The six states, along with the Committee's

allocation percentages, and their respective primary/caucus dates

are as follows:

New Hampshire (60%)

Massachusetts (20%)

Maine (5%)

Vermont (5\)

Rhode Island (5\)

Connecticut (5\)

2/16/88

3/08/88

2/26/88

3/01/88*/

3/08/88-

3/29/88

The Committee Treasurer stated that the allocation

percentages were developed in the Fall of 1987 and were based on a

weighted average of anticipated hours to be worked by "regional"

staff persons on each of the six states. The Audit staff asked if

any adjustments to these percentages were made by the Committee

during the operation of the regional office or after it ceased to

exist to reflect actual experience. The Treasurer responded that

no adjustments were made.

A request was made by the auditors that the

Committee provide any planning documents used for the set-up and

operation of the Manchester office as the NE Regional Office. The

Committee Treasurer stated he would attempt to locate any

documentation related to the planning of the regional office.

In an attempt to evaluate the reasonableness of the

Committee's allocation of the Manchester office as the NE Regional

Office, the auditors performed a number of analyses to identify

the activities which related to the states involved.

a. Review of Payroll and Overhead Costs

A review was performed to identify payroll and

overhead costs which the Committee allocated directly to the six

states. with this information, a determination was to be made as

to the extent the Committee offices located in the NE Region

functioned autonomously.

The Committee allocated $123,550.54 of payroll

costs (Salaries**/ - $43,937.39, Consultants - $79,613.15) directly

to the six states whereas $86,348.36 of payroll was allocated to

the NE Region. In addition, the Committee allocated $110,810.51

of overhead costs directly to the six states whereas $86,668.67 of

overhead was allocated to the NE Region. Categories of overhead

costs include Telephone (Intra-state), Rent/utilities, Supplies

and Equipment (see Attachment 1).

~/ Non-binding Primary. Republican Caucus - 4/26/88.

~/ Includes FICA calculations as determined by auditors.
~~~~:~f,"~1~~1~W!~~~;~~~:t~'}:t"""'::..'#·\"'~ .';' ,- -;~~·"'&..ft~~~-···_~· ~~ "t-" .. *,'(1" .... '" ""

r

-27-

The Audit staff noted that of the $43,937.39 in

salaries allocated directly to the six states by the Committee,

$-0- was allocated directly to New Hampshire. Massachusetts

received the largest portion - $37,085.69. Of the $79,613.15 in

consultant fees allocated to the six states, only $15,313.55 was

allocated directly to Ne~ Hampshire by the Committee. Therefore,

direct charges to New Hampshire represent only 12% of salaries and

consulting fees direct charged to the states within the region.

The Audit staff further noted that of the

$110,810.50 allocated to the six states for the overhead

categories, only $15,241.11 (or 14%) was allocated directly to New

Hampshire by the Committee. Massachusetts again received the

largest portion - $56,052.93 (or 51%).

,,-

It is the opinion of the Audit staff that based on

the Committee's direct allocations of payroll/overhead to the NE

Region states, the Committee had independent offices in all these

states but did not ackno~ledge an office for New Hampshire. For

example, the Committee made direct allocations to New Hampshire of

payroll and overhead in the amount of $30,554.66, compared to

Massachusetts - $107,383.62, Maine - $28,574.47 and vermont -

$35,838.79. The primary dates for Massac' ",etts, Maine and

Vermont were 3/8/88, 2/26/88 and 3/1/88 re~pectively, whereas the

New Hampshire primary was held on 2/16/88 and is traditionally the

most signiflcant primary in the region.

b. Review of Staff Vendor Files

.......

The Audit staff reviewed all available vendor files

and travel reimbursement documentation for Committee staff whose

salaries or consulting fees were included in the payroll costs

allocated to the NE Region by the Committee. A determination was

attempted as to whether these employees appeared to be performing

~regional" activities or activities associated with just one of

the states•

Of the five staff persons whose salaries were

allocated to NE Region, four of them traveled extensively for the

Committee. However, these four persons only left New Hampshire

occasionally and no trips to the other states were documented

after October 24, 1987. The Audit staff noted that many of these

trips were to Boston, Massachusetts for staff training and staff

meetings. The available documentation did not indicate any

training or meetings occurring in New Hampshire. The fifth person

apparently did not travel. Because of the nature of the available

documentation, the Audit staff was unable to determine the

assignments or project~ these persons were involved in during

their employment with the Committee.

The Regional Director for the New England Region

worked out of the Committee's headquarters in Washington, D.C.

after 6/1/87. His consulting fees were allocated 100% to

rieldstaff - Consultants (i.e., National Operations). A review of
O~~$~~if~~~\fig:;~~~;f''''''~~'-''''';~''''-'' -~: .. --.. -.",-.-" '-'

,

.

.'-'" ~, '~"- '.'~. ,~- -

-28-

-- ~~

.~

-;

'="

his vendor files revealed that he traveled from D.C. to New

Hampshire frequently for short visits and occasionally visited the

other NE states. Again, no documentation was available to

determine the projects he worked on.

Of the three staff persons whose consulting fees

were allocated to the NE Region, one was the Executive Director

for the Massachusetts state office. A review of his vendor files

did not show him leaving Massachusetts while employed by the

Committee. The Committee originally allocated his $18,500 in

consulting fees to NE Region but later adjusted it by

reclassifying $15,500 of these fees to Massachusetts.

The second consultant, who was a resident of

Vermont, was the Executive Director for the Vermont office and the

only staff person for the Maine office. He primarily traveled in

Vermont and Maine with a few trips to New Hampshire. The Committee

originally allocated his $15,500 of consulting fees to NE Region

but later reclassified $14,000 of these fees to Vermont.

The third consultant performed computer services

from 8/9/87 through 2/27/88. Because she was a Manchester, New

Hampshire resident and had no travel reimbursements, the auditors

concluded that she worked at the Manchester office. This person

received eight checks from the Committee for her services - five

were allocated to NE Region - Equipment ($1,522.50, 8/9/87-

11/14/87), one was allocated to New Hampshire - Consultants

($457.50, 11/15/87-12/19/87), one was allocated to NE Region -

Consultants ($365.00, 12/20/87-1/31/88) and the final one was

allocated to New Hampshire - Consultants ($142.50, 2/1/88-

2/27/88). The auditors were unable to identify the projects she

worked on from the available documentation.

c. Review of Committee's NE Region Allocations

The auditors performed a review of the available

supporting documentation for all the Committee's allocations to

the NE Region account codes to evaluate the allocations. Direct

allocations by the Audit staff to the six states was undertaken

based on our review of the vendor files (see Attachment 2).

Based on our review of the information made

available, it is the opinion of the Audit staff that the Committee

has not demonstrated that the office in Manchester, New Hampshire

functioned as a regional office. Therefore, the Audit staff has

determined that the $150,506.55 of costs allocated to the NE

Region by the Committee are allocable to New Hampshire. Since the

Committee has allocated 60% of this total to New Hampshire through

its regional allocations, the additional allocation to New

Hampshire is $54,341.62, determined as follows:
.....Jt~ilZ.~;:::;''''iJ:::{;;~>~''>'''':--'"'"~"'~ ·''''':·''l~;'\~~~~lf,j1.';:~'i;-~l<:;·~52·''''';':··-;;;''';;':;-;:;:~,\~5~,f\.;t~~·,,~~,r":;i··>;;"~~·~i\~:~-:":;;:;:i'·_····;"'~t"'£:'i ~··'.~:~'>;Fi:,~{i.t!fr1~~~:}~L:,i~r- ".. .'..:::,,~ --- ...

':\

-29-

Audit Allocations to

New Hampshire

Additional Portion to

New Hampshire

LESS:

Audit Allocations of New

England Regional Expenses to

Other 5 NE Region States

Overallocated % to

New Hampshire

Additional New Hampshire

Allocation

$150,506.55

x .40

9,768.33

x .60

60,202.62

(S,861.00)

S54. 341, 62

d. Committee Comments

At the exit conference the Committee Treasurer

stated that control of the offices in the other NE states was from

the office in Manchester, New Hampshire and that expenses

allocated directly to these states does not preclude the use of

percentage allocations in a regional office concept. The former

Treasurer stated that the "regional" office in Manchester remained

open after the New Hampshire primary (2/16/88) which he believes

supports their regional allocations. It appears from the auditors

review of the vendor files that the NE Region's salaried employees

were paid for the last time on 3/2/88 for the period 2/16/88-

2/29/88, or one pay period after the New Hampshire primary. No

~ecords were available to show the duties of the NE Region office

or employees.

At the exit conference, the Committee was provided

with copies of work papers in support of the auditors' figures.

In the Committee's response to the Interim Audit

Report, the Committee Treasurer explains that "[a]t the beginning

of the campaign, OFP knew that a number of New England states

would have early electoral tests of one sort or another" and that

"[b]ecause of this, it was important that we utilize our resources

in the months leading up to the various tests so as to maximize

our success.-

The Committee Treasurer states that in June of

1987, the Committee reviewed its staffing needs for the six New

England states and they determined to s~~ up a regional office in

New Hampshire. He further states that '0 .the decision was, in

some part, made with the beneficial affects it would have on the

spending limit problem" but that "the decision was primarily made
}~"At~~i!j'~'\~~1~~~'t~;;R~1';;'"\<''<:~fi'V''''O''''~:'-' -'", ;" '>" <.-. ·4"- --

',<

'.-

-30-

because of the understanding that the region's top people would

necessarily spend most of their time in New Hampshire and

therefore that state made the most sense to host a regional

office."

He continues by stating that "[o]nce a decision was

reached to place a regional office in New Hampshire, staff was

asked to review the duties of the five New England staff people

and make a determination of how much time each was expected to

spend on New Hampshire versus the other New England states over

the next several months as a whole. For any given week the time

actually spent on one state or another might be different but I

thought it appropriate to have an allocation formula based on the

entire campaign rather than adjust it from one week to the next."

The Committee provided a copy of a memo dated June

23, 1987 in which the Treasurer points out that with the exception

of the 70% estimated for the New Hampshire Executive Director, all

employees were estimated to spend 40% of their time on New

Hampshire (see Attachment 3). The Committee Treasurer states that

~[gliven the extreme doubt with which I knew the auditors would

view a regional office, I set the regional allocation to 60\ for

New Hampshire, 20% for Massachusetts and 5% for the other four

states." The Committee also provided a New England Regional

Committee newsletter from November 1987 which contains articles

regarding the Committee's regional approach to the New England

states (see Attachment 4).

The Committee takes exception to the Audit staff's

analysis of the direct costs to the other NE Region states. They

state that "(t]he fact that DFP chose to have a regional office

does not preclude it from having offices in the states covered by

that regional office. That would be like saying that because we

had a national office, we shouldn't have offices in the field. Of

course we had significant direct costs in the states outside of

New Hampshire, we were trying to win everywhere."

The Audit staff contends that based on our analysis

of direct costs allocated to the NE Region states that it appeared

that the Committee had independent offices in the five states

other than New Hampshire. Since the direct costs allocated to New

Hampshire were minimal, the "Regional Office" more closely

resembled a New Hampshire state office than a regional office.

The Committee points out that the Audit staff notes

that $173,017 of payroll/overhead was allocated to the NE Region

but that the Audit staff does not acknowledge that 60% of that

figure was allocated to New Hampshire via the NE Region

allocations. This 60% allocation is acknowledged in several

places in the interim audit report. They add that they believe

that a state with a regional office would have little in direct

costs but would have the lion share of regional costs, which they

point out is supported by the auditors' figures.
-31-

The Committee also contends that the Audit staff

does not mention that the Committee paid $700 in January for

another office in Manchester, New Hampshire and over $3,000 for

space it took over from the Haig Committee, which was all

allocated directly to New Hampshire. They add that as in the

other states, the Committee had space dedlcated directly to New

Hampshire. The Audit staff points out that the Committee paid

$1,400 on November 30, 1987 to the same vendor that the $700 was

paid to in January 1988. This $1,400, for one month's rent plus a

$700 security deposit, was allocated to the NE Region. Also, of

the $3,013.66 paid to the Haig Committee in February 1988; $66.66

was for rent, $47 was for utilities and $2,900 was for the

purchase of yard signs.

Therefore, office rent allocated by the Committee

directly to New Hampshire totalled only $766.66. Contrary to the

Committee's assertion, these expenses, which they direct charged

to New Hampshire, were taken into account by the Audit staff as

lllustrated by Attachment 1, which was also attached to the

interim audit report. Available documentation does not allow a

determination to be made regarding that portion of NE Region rent

expense which relates solely to New Hampshire.

In the Committee's response, the Treasurer states

that he was confused by the $150,506.55 figure on page 21 of the

Interim Audit Report. This figure was the portion of costs

allocated to the NE Region by the Committee which the auditors

determined, from a review of the available supporting

documentation, was allocable to New Hampshire.

The Committee also takes exception with the Audit

staff's statement that the New Hampshire primary is traditionally

the most significant primary in the region. The Committee states

that they are not claiming that New Hampshire was unimportant and

that the 60% allocation reflects this belief.

,'"

The Committee further states that if the Audit

staff does not believe the allocation formula was reasonable then

the Audit staff should provide the Committee with the allocation

formula it deems as reasonable. Without documentation in support

of the programs, activities and staff assignments involving the

six states deemed NE Region states by the Committee, the Audit

staff is unable to determine an allocation formula. If these

materials had been provided by the Committee to the Audit staff

when requested during the fieldwork and again in the Interim Audit

Report, the Committee's allocation formula could have been

reviewed for reasonableness or an alternative could have been

proposed once it had been demonstrated that the Manchester office

was actually a regional office.

The Audit staff concludes that, based on available

information, the Committee's Manchester, New Hampshire office

functioned primarily as the New Hampshire office. As noted above,

the New Hampshire primary is traditionally the most significant
-32-

primary in the region. The Committee acknowledges this in their

response to the interim audit report and notes that their 60\

allocation of the NE Region to New Hampshire reflects the State's

importance. The Audit staff also believes that 60% is conceivably

a reasonable allocation of any regional expenses incurred by the

Committee. As noted in the Interim Audit Report and discussed

above (Page 20), the Committee allocated no salary and relatively

small amounts of consulting and overhead directly to New Hampshire

(see Attachment 1). For the majority of expenses related to the

New Hampshire office. the Committee does not distinguish between

expenses which were incurred for their New Hampshire campaign and

those which may have been "regional". Rather, the regional

expense allocation was applied to the total of these two types of

expenses. This point is demonstrated by Attachment 3. In this

memorandum, the Committee makes estimates of the portion of

certain individuals' time that would be dedicated to New Hampshire

versus regional work.*/ However, when the allocations were done,

rather than applying the regional allocation formula to the

regional portion of these salaries, it was applied to the sum of

the New Hampshire and regional portions. No documentation is

available to allow the Audit staff to determine the regional

versus New Hampshire portions of tI,e expenses associated with the

NE Region. Finally, it is noted that when all salaries, overhead

and other expenses for the states in the NE Region are taken

together, the Audit staff's New Hampshire allocation represents

only 46\ of the total.

, )

No changes have been made to the Interim Audit Report

allocations.

6. Compliance Exemptions - Media Costs

Section 106.2(B)(2)(i)(B) states that expenditures

for radio, television and similar types of advertising, including

any commission, purchased in a particular media market that covers

more than one State shall be allocated to each state in proportion

to the estimated audience. It further states that the allocation

shall be done using industry market data.

section l06.2(c)(5)(i) of Title 11 of the Code of

Federal Regulations states, in part, that exempt compliance costs

are those legal and accounting costs incurred solely to ensure

compliance with 26 U.S.C. 9031, 2 U.S.C. 431 AND 11 C.F.R. Chapter

I, including the costs of preparing matching fund submissions.

The costs of preparing matching fund submissions shall be limited

to those functions not required for general contribution

processing_

section 441d(a)(1) of Title 2 of the united states

Code states that whenever any person makes an expenditure for the

No information is available to determine if these estimates

proved to be accurate.

,~.~

~~:}~);;;j>;'~"j;.'b~t~~;::~:,,:,},,:.;,, ~-------'--~~~~~~~~~~~~
-33-

purpose of financing communications expressly advocating the

election or defeat of a clearly identified candidate, or solicits

any contribution through any broadcasting station, newspaper,

magazine, outdoor advertising facility, direct mailing, or any

other type of ~eneral public political advertising, such

communication, if paid for and authorized by a candidate, an

authorized political committee of a candidate, or its agents,

shall clearly state that the communication has been paid for by

such authorized political committee.

The Committee applied a 10% compliance exemption to

their media costs which according to the Committee treasurer

represents the costs incurred for including the disclaimer notice

required by 2 U.S.C. S441d(a) on broadcast media. The amounts

exempted by the Committee were as follows:

~,,

Iowa

New Hampshire

$16,061. 46

$13,961.15

The Audit staff disagrees with the Committee's

application of compliance exemptions to their media costs.

The cited regulations on media allocation make no

provlslon for a compliance allocation. Further, the definition of

a compliance cost speaks in terms of cost solely to ensure

compliance. The section goes on to explain one category of

expense where an incremental cost analysis is used to determine

which costs will be considered solely to ensure compliance. Though

not contemplated by the regulation, if a similar analysis was

attempted on media, the incremental cost would appear to be at the

production stage rather than for air time. Production costs need

not be allocated to any state.

Some exceptions to the "solely to ensure

compliance" test have been provided by Commission regulations.

These relate to salary and overhead costs for both state and

national headquarters operations. Percentages are given for

compliance deductions for these categories of expenses. These

exceptions are, however, very specific and narrowly drawn and do

not cover broadcast media.

At the exit conference, the committee treasurer

referred to advisory opinion 1988-6 which allowed the allocation

of 50\ of media air time costs to fundraising if a request for

funds as short as 3 seconds occurred. The Audit staff does not

believe that a deduction for compliance is analogous. First, the

advisory opinion notes that ads have two purposes, the raising of

funds and influencing of voters. The required notice does not add

a third reason for running the broadcast, but is required as a

condition of accomplishing one or both of the two campaign

purposes. Second, to qualify for a fundraising exemption, 11

C.F.R. SlOO.8(b)(21) requires that expenditures need only be "in

connection with the solicitation of contributions" while to

qualify as a compliance expense, 11 C.F.R. S100.8(b)(15) requires
-34-

;~~~·~:;~5;-t;~:"'·"=~~·~~;~··\-;"'\~';~::\·"':-~"\-·.i"·-}~"".J~~ ~~~

,.'

that expenditures be "solely to ensure compliance."

At the exit conference, the Committee was informed

of the Audit staff's position. No documentation supporting the

Committee's application of a 10% compliance exemption to broadcast

media costs has been provided.

In the Committee's response to the Interim Audit

Report, the committee reiterates that they incurred costs to air

the required disclaimer. They further state that "[w]hether or

not DFP would have incurred such costs in any event is, at best,

difficult to determine. DFP believes 10\ was reasonable, the

auditors did not."

Since the Committee did not provide any

documentation in support of their application of a 10\ compliance

exemption to broadcast media costs, no adjustment will be made to

the auditors' allocations for the compliance exemptions related to

media costs.

7. Broadcast Media

.-...

Section 106.2(b)(2)(i){B) of Title 11 of the Code

of Federal Regulations requires that expenditures for radio,

television and similar types of advertisements purchased in a

particular media market that cover more than .• State shall be

allocated to each State in proportion to the estimated audience.

This allocation of expenditures, including any commission charged

for the purchase of broadcast media, shall be made using industry

market data.

The Committee contracted with Multi Media Services

Corporation (MMSC) to provide media placement services and they

contracted with Ringe Media, Inc. (RMI) to provide media planning

and production.

The Audit staff reviewed all available radio and

television station invoices to determine if Committee allocations

to Iowa and New Hampshire were reasonable. The reasonableness of

the allocations was tested by referring to the Arbitron television

market share percentages and the Arbitron Ratings Radio Station

Reference Report (19B? edition).

The major difference between the Committee's media

allocations and the allocations determined by the Audit staff was

due to the auditors' use of the Arbitron Radio book for New

Hampshire. At the exit conference, the Treasurer stated that he

was unaw~~e of the existence of this book. The Committee had used

the television percentages for their radio allocation which for

New Hampshire resulted in a much lower allocation figure.
-35-

~;M'l:~~J~?*3?:4w~~~~'f~''':C;'1:'-r::~"t:"'''·'' '";W.:;:',<,"''' •."',,."rF">.•"r.:."."'. -"""·:'<··~~·.\A';·".~." . '" ~',.,•. -. ',.•

;:?'

,

The allocation figures for broadcast media are as

follows:

Audited Committee Differenc@

Iowa $163,210.60 $160,614.62 $ 2,595.98

Ne",' Hampshi re 176,907.39 139,611.50 37,295.89

Therefore, the additional allocations are $2,595.98

and $37,295.89 to Iowa and New Hampshire respectively.

The Committee was provided with copies of work

papers in support of the auditors' figures.

The Committee agrees with the Audit staff's

additional allocations regarding broadcast media.

8. Media Commissions (Production)

The Committee paid RMI a commission equal to 1.5\

of gross air time costs for all placem€~~~ ~f commercials produced

by RMI. This was in addition to the 4~ c ~ission paid to MMSC

for commercials placed and a $40,000 monthly fee paid to RMI. No

allocations were made by the Committee to Iowa and New Hampshire

for the 1.5\ commission paid to RMI. At the exit conference the

Treasurer stated that the RMI commissions were considered

production costs and therefore not allocable to the state limits

pursuant to 11 C.F.R. S106.2(c)(2). However, the auditors contend

that the amount of these fees was dependent on the usage of the

commercials and was therefore directly related to air time.

The following amounts were allocable:

Iowa

New Hampshire

$177,642.75 x 1.5\ - $2,664.64

$199,205.42 x 1.5\ - $2,988.08

In the Committee's response to the Interim Audit

Report, the Committee takes exception to these allocations. They

state that " ..•its contract with its media producer (Ringe Media)

called for a flat monthly fee plus an additional payment based on

the extent we used the commercials he produced." The Committee

adds that they do not understand the relevance of the auditors'

contention that the amount of these fees was dependent on the

usage of the commercials and was therefore directly related to air

time. They continue that a producer would receive more funds as

the frequency of airing the commercials increased and that they do

not know what "directly related to air time" has to do with the

fee being considered a production cost.

Although the Committee feels that the 1.5\

commissions paid to Ringe Media, Inc. were media production costs

and therofore not allocable pursuant to 11 C.F.R. S106.2(c)(2),
·-'~~f~;::~~':~~i.·';j~,,;'~~~\.:;~{~;:j;'~.';\~ ----=

"~.1";"

.,

-36-

the Audit staff contends that the 1.5% of gross billings for air

time paid to RMI is a cost of media placement and like other such

costs is allocable to Iowa and New Hampshire.

9. Individuals' Travel and Salary

Section 106.2(b)(2)(ii) of Title 11 of the Code of

Federal Regulations states that salaries paid to persons working

in a particular state for five consecutive days or more, including

advance staff, shall be allocated to each State in proportion to

the amount of time spent in that State during a payroll period.

Section 106.2(b)(2)(iii) of Title 11 of the Code of

Federal Regulations states that travel and subsistence

expenditures for persons working in a State for five consecutive

days or more shall be allocated to that State in proportion to the

amount of time spent in each State during a payroll period. For

purposes of this section "subsistence" includes only expenditures

for personal living expenses related to a particular individual

traveling on committee business, such as food or lodging.

Section 106.2(c)(S) of Title 11 of the Code of

Federal Regulations states that an amount equal to 10% of campaign

workers' salaries and overhead expenditures in a particular State

may be excluded frem allocation to that State as an exempt

compliance cost. An additional amount equal to 10% of such

salaries and overhead expenditures in a particular State may be

excluded from allocation to that State as exempt fund raising

expenditures, but this exemption shall not apply within 28 days of

the primary election.

The Audit staff reviewed the vendor files related

to Committee staff travel in Iowa and New Hampshire to identify

travel and salary costs which although allocable were not

allocated to these states by the Committee.

This review revealed that expenditures for intrastate travel and subsistence had been incurred by staff persons in

Iowa and New Hampshire who were in these states on five or more

consecutive days but were not allocated to the states by the

Committee. The related payroll costs for these persons was also

calculated and included as expenses allocable to these states. The

payroll was calculated for the period of time in which these

persons were documented as being in these states and was adjusted

for the compliance and fundraising exemptions as appropriate.

Based on this review, the Audit staff determined

that the following travel and salary cost totals be allocated to

Iowa and New Hampshire:
'~~~~~~~:~~~z1t':i~::;;~\!:~"";;~~'''';' 'f.. ; \i:J)~"""." '.., ~':""l.r"':."..}"':!$"-~' ......... ~.";. .• ... ...,o.:~, ... ....:.~.-~ -', ......', • J'....., -;.;: ••s:;.~':.-'< ':-\' .......__ - .. ""

~~..

-37-

--. "' ··~"'·:J:"".r~~:::'I;.'"~>;;l;j~.~":(;~~~:H-"''''''''''~ .' .~~ -

~;~;~

Travel

Salary

TOTAL

I 0""a

$46,584.43

60,193.18

$107.378.21

New Hampshire

$51,309.52

15,039.13

$66.349.25

The Committee was provided schedules of these

travel and salary costs at the exit conference.

In the Committee's response to the Interim Audit

Report, they provide arguments on a few of the travel and salary

costs allocated to Iowa and New Hampshire by the auditors.

The Audit staff allocated to Iowa the salary of Tom

Synhorst (co-Regional Director for Iowa) for paydays from March

13, 1987 through March 1, 1988 (also see Exhibit H). The

Committee agre~s ....ith the Iowa allocations for the salary payments

for paydays January 1, 1988 through February 15, 1988 ($1,059.78).

They disagree with the allocation of his 1987 salary payments

($42,867.20) and one salary payment covering the period February

15, 1988 through March 1, 1988 which the Committee notes was after

the Iowa caucus ($2,418.98) Salary payments allocated to Io....a by

the Audit staff totaled $52,345.96.

The Committee states that for the 1981 salary

payments, the auditors need more than a person's position to

allocate the costs to Iowa. They add that they do not believe

that the auditors have any record of Mr. Synhorst being in Iowa

more than four consecutive days and that "[t}his is not because we

were being cute and hiding his expenses somehow." The Committee

further states that " •.• in the beginning, Mr. Synhorst was

responsible for Kansas, a state DFP placed a great deal of

importance in" and that "Mr. Synhorst returned to Washington on a

regular and frequent basis." The Committee then states that "Mr.

Synhorst may have violated the four day rule at some point of

which I am unaware, but I believe the burden is still on the Audit

staff to make such a showing. w

The Audit staff notes that it included Tom

Synhorst's 1987 salary payments as allocable to Iowa because of

his position as co-Regional Director for Iowa, because the

Committee provided him with an apartment in Des Moines, Iowa from

March 1987 through February 1988 and because we were unable to

determine from the documentation provided by the Committee the

exact dates Mr. Synhorst was in Iowa or when he had returned to

his permanent residence in washington D.C., which he apparently

did quite frequently. The auditors did note, from airline
-38-

reservation./ and expense reimbursement documentation, at least

sixteen occasions where Mr. Synhorst appeared to be in Iowa for

five consecutive days or more.

As far as the inclusion of the paycheck covering

the period February 15 through March 1, 1988, which the Committee

disagrees with, the Audit staff notes that we included his salary

through the end of February because the Committee paid for the

rental of his Des Moines apartment for the month of February. The

available documentation for Mr. Synhorst's expenses indicates that

he was in Iowa through the date of the Iowa caucus (2/8/88), but

that the auditors were unable to determine if he remained in Iowa

through the end of February. Based on the Committee's argument,

the Audit staff has deleted the S2,418.98 of salary to Tom

Synhorst for the February 15 through March 1, 1988 pay period.

The Committee objects to the auditors' allocation

of one-fifth of a payment (S597) to Long Lines Limited for airfare

which represents Tom Synhorst's share of the payment. He was one

of the five Committee officials on the flight. They state that

the trip was in April of 1987 and that "[u]nless the auditors have

evidence that he had broken the four day rule this charge should

be removed." The Audit staff notes that the date of travel was

April 14, 1987, that the trip was within Iowa only, and that

according to airline reservation documentation for Tom Synhorst,

he was in Iowa from April 8 through April 1S, 1987. Based on this

information, the $597 allocation to Iowa will remain unchanged.

Given that Committee records do not establish Mr.

Synhorst's whereabouts, his position with the campaign, and his

association with a Committee-provided apartment in Des Moines, the

Audit staff made no further adjustments to Mr. Synhorst's salary.

When the Commission considered this matter, it was determined that

$17,858.87 of his 1987 salary was allocable. This amount is based

on the number of days during 1987 that available documentation

indicated he was in Iowa for periods of five consecutive days or

more. This documentation generally established an Iowa arrival

date and an Iowa departure date but did not always account for his

whereabouts for each of the days in between.

Next, the Committee disagrees with $15,377.20 in

air charter service charges which the auditors have allocated to

Iowa. This figure is comprised of amounts from three payments.

The first amount allocated by the auditors to Iowa

was $3,448.00 for two flights on February 7, 1988. the first

flight was from Omaha, Nebraska to Ft. Dodge, Iowa and included

Senator and Mrs. Dole and six other Committee officials and staff.

It should be noted that the Audit staff considered this Iowa

~/ This information shows only reservations not actual flights

and does not include travel not arranged by the Committee's

travel agency.
c=·"{r"1~:t~f~~.•:\{!~~~~~:-~ ..~~..,>." ....~~\~~ -

~~:

-39-

intra-state travel because the entourage attended an event in

Glenwood, Iowa prior to flying to Ft. Dodge, Iowa via an Omaha,

Nebraska airport. The second flight was from Ft. Dodge, Iowa to

Des Moines, Iowa with the same eight persons aboard.

In the Committee's response, they point out that

Mrs. Dole was in Iowa from February 7 through 9 (less than five

days) and therefore her costs were not allocable. The Audit staff

concurs with this statement and therefore backs out her share of

these two flights, as well as an additional share for the

Committee staff person who accompanied her on these trips. The

adjusted total for the first amount is therefore $2,586.00

($3,448.00 - $862.00).

The second amount allocated by the auditors to Iowa

was $6,091.20 for two Iowa intra-state flights for Senator Dole

and five other staff members who were in Iowa for at least five

days. No change to this amount has been made.

The third amount allocated by the auditors to Iowa

was $5,838.00 which, according to the check tissue, was for "air

travel E. Dole and staff." The auditors were unable to

determine from the Committee's records where this trav-l occurred,

when thi s travel occur red, and except for Mr s. Dole, ,·.}0 the

travelers were.

The Committee provided documentation which

demonstrated that this payment was for inter-state travel and

therefore not allocable to Iowa. The Audit staff has adjusted the

allocable amount to Iowa by $5,838.00.

The Committee further objects to the $5,212.18 in

Visa card charges which the auditors have allocated to Iowa. This

total is for six charges ($5,128.42) by Senator Dole, for which

the transaction dates were 12/29/81 for one item and early

February 1988 for the other five items, and one charge by Mrs.

Dole ($83.76) with a transaction date of 2/7/88. The 12/29/87

charge by Senator Dole ($72.02) was for a purchase at Radio Shack

in Keokuk, Iowa and the other five charges by Senator Dole in

early February 1988 were travel-related and were around the

February 3 through February 9, 1988 time period he was documented

to be in Iowa.

Since Mrs. Dole was documented to be in Iowa from

February 6 through February 9, 1988, the Audit staff concurs with

the Committee for this item and has deleted the $83.76 from Iowa

allocation.

The Committee states that it is confused over the

auditors' allocation of charges to New Hampshire related to costs

inc\lned at the Merrimack Hilton.

The Committee made 2 payments to the Merrimack

Hilton totaling $9,184.88. The first on August 24, 1987, was a
"'; l<.! .... ~"J:''r;{i~.;'~~'''':~11~~~3~t;~1~t;:~~'~-I.'''-',.

:,

-40-

deposit for "election night/week." This $4,000 was allocated to

New Hampshire by the Committee. The second payment was $5,184.88

made on January 28, 1988 and represents the balance due on the

charges. Of this amount, $802.50 was allocated to New Hampshire

by the Committee. The amount billed by the Merrimack Hilton

includes charges for Senator Dole and Committee staff between

February 9 and February 16, 1988. Among these charges are a suite

for one week for the Doles ($1,917.44), one staff room

($1,917.44), two rooms for seven nights ($1,168.44), ten rooms for

three nights ($2,503.80), use of the grand ballroom ($802.50), and

an unspecified charge of $714.76. The Audit staff allocation of

$4,221.88 was determined as follows:

The charge for the ten rooms for 3 nights is

included though the documentation does not indicate who, if

anyone, occupied the rooms. This charge is therefore allocable

under the general allocation provisions of 11 C.F.R. S

106.2(a)(1). Since no d==umentation was provided by the Committee

to refute the auditors' allocation, the $4,221.88 amount remains

unchanged.

-.-

Total Payments

Less: Press Filing Room

Committee Allocations

Additional Allocation

$ 9,184.88

( 160.50)

(4,802.50)

$ 4.221.88

10. Non-Travel and Salary

During the review of vendor files the Audit staff

noted non-travel and salary costs which were allocable to Iowa and

New Hampshire but were not allocated to these states by the

Committee. Examples of costs in these categories include meeting

expenses, car rentals, telephone, event expenses, and newspaper

subscriptions. The Audit staff determined that non-travel and

salary costs, which were allocable to Iowa and New Hampshire,

totaled $64,008.61 and $34,170.96 respectively.~/

The Audit staff provided schedules of these nontravel and salary costs to the Committee at the exit conference.

Iowa

The Committee objects to the following charges

allocated to Iowa by the Audit staff:

~/ These allocable amoull~~ have been reduced due to polling

Expenses having been moved to section 11 below ($16,200.00

in Iowa and $14,697.52 in New Hampshire).
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(a) Southwestern Bell, $379.95

The Committee states that the equipment was

sent to Iowa for the announcement tour but did not remain there

since it was used by the advance staff after Iowa. The Audit

staff notes that since no information was provided regarding

how long the equipment was used in Iowa, the $379.95 allocated to

Iowa remains unchanged. The invoice date for this equipment was

November 24, 1987 so it is possible the equipment was in Iowa for

at least two months through the date of the Iowa caucus (2/8/88).

(b) R.G. Dickinson & Co., $72.00

The Committee states that this item was

charged to an account which was subsequently allocated to Iowa.

The Audit staff concurs and has deleted this item.

(c) RST Marketing, $32,189.33

The Committee provided a sample of the

fundraising letter from Senator Chuck Gra~~ley (Iowa) which the

auditors agree demonstrates that the ce" ~ssociated with this

mailing are exempt fundraising. Of the ~~_,189.33 allocated by

the auditors, $25,880.86 was related to the Grassley mailing and

has been deleted. In addition, since the Committee allocated 10\

of the cost of this mailing to the lo~a state limitation

($2,875.65), the auditors have allowed a credit in this amount to

Iowa.

The Committee did not provide any information

regarding the remaining $6,308.47 paid to RST Marketing, so that

amount will remain allocated to Iowa.

(d) Postmaster, $7,076.41

This item was included in the documentation

provided to the Committee at the exit conference but was not

included in the Interim Audit Report figures. The Committee was

provided with the revised documentation shortly after the exit

conference.

New Hampshire

The Committee also objects to the following charges

allocated to New Hampshire by the Audit staff:

(a) Southwestern Bell, $379.95

For the reasons provided earlier under Iowa

for this vendor, the $379.95 allocated to New Hampshire has not

been adjusted.
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-42-

(b) Manchester Union Leader, $85.80

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The Committee states that this charge was for

a subscription for the national office. The Audit staff concurs

and has deleted this item.

(c) State of New Hampshire, $1,000

The Committee states that they thought filing

fees were exempt. The Audit staff contends that the $1,000 filing

fee is allocable to New Hampshire.

(d) Thomas Rath, $10,855.25 -

The Committee states that Mr. Rath was a

national consultant who lived in New Hampshire but worked for the

national committee. They add that his travel expenses will

reflect this and that "[j)ust because someone has his checks

mailed to his home in New Hampshire does not mean that New

~, Hampshire is all they knew about."

The Audit staff notes that they reviewed

invoices related to Mr. Rath's consulting firm, Rath & Young, and

allocated costs, such as telephone conferences, which involved

Committee staff known to be New Hampshire campaign personnel.

Also included are costs related to any intrastate New Hampshire

travel. Overall expenses and adjustment credits noted on each

invoice were prorated by the auditors based on the percentage of

time determined to be New Hampshire related.

The auditors note that costs not related to

New Hampshire were not allocated to New Hampshire, as suggested by

the Committee. The total costs allocated to New Hampshire was 41\

of the total amount billed.

(e) William Landau, $3,000

The Committee states that this charge was for

a van wreck in Massachusetts and that even though New Hampshire

was written on the supporting documentation, it occurred in

Massachussetts. Since the documentation supports this

explanation, this charge has been deleted from New Hampshire

allocation.

11. Polling Expenses

Section 106.2(b)(2)(vi) of Title 11 of the Code of

Federal Regulations states that expenditures incurred for the

taking of a public opinion poll covering only one state shall be

allocated to that state.

The Interim Audit Report explained that the

Committee made payments totaling $621,435.28 to the Wirthlin Group

for polling services. It was further explained that the Audit
.....,

--,

-43-

staff reviewed the available documentation related to these

payments, but that it was not possible to determine if the

Committee's allocation of the expenses to spending limitations was

correct because the documentation did not detail the coverage of

the polls. The only exceptions were three payments related to

Iowa and New Hampshire Focus Groups. These payments total

$16,200.00 for Iowa and $14,697.52 for New Hampshire, and were

included in Finding II.E.10., Non-Travel and Salary Costs, of the

Interim Audit Report.

In the Interim Audit Report it was recommended that

the Committee provide documentation related to polls conducted by

the Wirthlin Group that would establish in which state the polls

were conducted. It was also noted that after the documentation

was reviewed additional recommendations may be forthcoming.

In response to the Interim Audit Report

recommendations the Committee states that "Iowa was the obvious

place to assess national media. The voters were more aware than

any other state other than New Hampshire. Calling something an

Iowa Focus Group does not mean that the expenditure was intended

to influence Iowa voters." The Committee's response also states

that one payment of $479.52 was for interstate travel and

therefore not allocabl~. No documentation related to any of the

polling expenses was included with the Committee's response.

Subsequent to the receipt of the Committee's

response to the Interim Audit Report, the Commission issued

subpoenas to both the Committee and the Wirthlin Group requiring

the production of the necessary records. The records provided

indicate that the Committee conducted two public opinion polls in

the State of Iowa and three in New Hampshire. The cost of these

polls requires allocation to the state spending limitations.

The records produced also showed that the Committee

commissioned one Focus Group in Iowa and two Focus Groups in New

Hampshire. The pollster's reports were provided for the Iowa

Focus Group and one of the two conducted in New Hampshire. These

reports make it clear that the commercials being evaluated were

produced specifically for use in Iowa or New Hampshire. They also

indicate that the participants in the Focus Groups were all

residents of the state involved. Finally, it is noted that both

Focus Group reports indicate that the participants were also asked

to view commercials being aired by one or more of Senator Dole's

opponents. At the time of the Interim Audit Report only one of

the two New Hampshire Focus Groups had been identified. The cost

of both were included in the allocable amount by the Audit staff.

It was also le~cned that the $479.52 payment, which the Committee

states is interstate travel, was travel related to one of the New

Hampshire Focus Groups, and as such is allocable.
...... Z;'-:'"

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-44-

A final item identified from the review of the

polling records is a $4,000.00 per month retainer paid for the

months of January through March of 1988. A prorata portion of

this retainer has been allocated to Iowa and New Hampshire by the

Audit staff.

The Commission has determined that the Focus Groups

and the pro rata share of the monthly retainer are not allocable.

The remaining allocable polling expenses are as follows:

Allocable Polling Expenses

Less:

Committee Allocations

Additional Allocations

Iowa

$ 57,486.25

(35,989.00)

$ 21.497.25

New Hampshire

$ 57,578.50

(25,942.00)

$ 31.636.50

....

"

12. "Testing the Waters" Expenditures Made by

Campaign America

Section 9034.4(a)(2) of Title 11 of the Code of

Federal Regulations states that even though incurred prior to the

date an individual becomes a candidate, payments made for the

purpose of determining whether an individual should become a

candidate, such as those incurred in conducting a poll, shall be

considered qualified campaign expenses if the individual

subsequently becomes a candidate and shall count against the

candidate's limits under 2 U.S.C. 441a(b).

Section 100.8(b)(1) of Title 11 of the Code of

Federal Regulations states, in part, that the term "expenditure"

does not include payments made solely for the purpose of

determining whether an individual should become a candidate. If

the individual subsequently becomes a candidate, the payments made

are subject to the reporting requirements of the Act. Such

expenditures must be reported with the first report filed by the

principal campaign committee of the candidate, regardless of the

date the payments were made.

Section 100.7(a) of Title 11 of the Code of Federal

Regulations states that a contribution includes a gift,

subscription, loan, advance or deposit of money or anything of

value by any person for the purpose of influencing any election

for Federal office. The term "anything of value" includes in-kind

contributions.

The Audit staff reviewed the disclosure reports

filed with the Federal Election Commission by Campaign America

(CA), a registered multicandidate committee associated with the

candidate. The review was intended to determine if any of the

activity disclosed by CA appeared to relate to the Presidential
'-r"'~'.·' -"~:..~--. -.;-- ..... ~.~~:l)-

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-45-

campaign. A group of transactions were identified from the CA

reports which were questioned as possible testing-the-water

expenses. A request for the records relating to these

transactions was made by the Audit staff and again by the

Commission. After both were refused, the requested records were

subpoenaed by the Commission.

Campaign America registered with the Commission in

March 1978. As background, Attachment 5 shows Receipts,

Disbursements and year end Cash On Hand for each year from 1978

through 1988. A significant increase in activity is noted in 1986

and the first quarter of 1987. According to a copy of a

newsletter provided by CA Senator Dole is the "Honorary Chairman"

of CA.

As noted above, certain records were obtained from

CA via subpoena. The records obtained were for the period August,

1986 through April 1987 and included cancelled checks and related

invoices for disbursements to vendors and persons shown on CA

reports as having an Iowa or New Hampshire address. The Interim

Audit Report presented an analysis of the documents obtained along

with related activity noted in CA reports. Based on that

analysis, the Interim Audit Report concluded that the records

indicate the possibility of a "testing-the-waters" campaign by CA

on behalf of the Committee. It was also noted that the

information obtained was limited to payees with an Iowa or New

Hampshire address and therefore omitted many possible

"testing-the-waters" disbursements made to payees with addresses

outside of those States.

The Interim Audit Report also stated that the

disbursements which were considered potential "testing-the-waters"

in Iowa total $210,049.41. Of that amount, $173,826.46 was

believed attributable to the Iowa spending limitation. In New

Hampshire the total was $24,775.11 with $23,329.73 attributed to

the spending limitation. It was also noted that for purposes of

the review the "5-day rule" as set forth in 11 C.F.R. §

106.2(b)(2)(iii) was not applied because the persons involved were

CA personnel not Presidential Committee workers. Though the

allocable amounts were stated in the report, they were not

included in the preliminary calculation of amounts in excess of

the Iowa and New Hampshire spending limitations pending the

Committee's response to the Interim Audit Report and the review of

additional records.

In the Interim Audit Report it was recommended that

the Committee provide all documents associated with disbursements

made by Campaign America and/or any state level account, division

or committee which relate in any way to Iowa or New Hampshire for

the period January 1, 1986 through March 31, 1987.
l\~~~~Z;:~~f~~r~0~:~f~~~~:;'1I~b'> ;".':"i:··t;,~,,2i·~'{"''''~'':' '.,' '." .

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-46-

In addition, the Committee was requested to provide

the following:

1. The script(s) used for the telemarketing program that was

conducted in Iowa in October and November, 1986;

2. The follow-up letter(s) used for the telemarketing

program that was conducted in Iowa in October and

November, 1986; and

3. All documents including, but not limited to invitations,

hand-outs, press releases, flyers, transcripts, and

speeches which relate to appearances made by Senator

Dole in Iowa and New Hampshire.

In a separate letter to CA's Treasurer, the

Commission requested that CA provide documents relating to

disbursements made by Campaign America in Iowa and New Hampshire

in connection with the presidential campaign of Senator Robert

Dole that were not previously provided and specifically:

"1. All documents relating to all disbursements made by

Campaign America Iowa Division and Campaign America New Hampshire

from January 1, 1986, to March 31, 1987. This request includes,

but is not limited to invoic~s, canceled checks. debit memoranda,

bank statements, signature cards, and accounting records.

"2. The following documents:

'. ~~~

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a. the script(s) used for the telemarketing

program that was conducted in Iowa in October and November, 1986;

b. the follow-up letter(s) used for the

telemarketing program that was conducted in Iowa in October and

November, 1986; and

c. All documents including, but not limited to

invitations, hand-outs, press releases, flyers, transcripts, and

speeches which relate to appearances made by Senator Dole in Iowa

and New Hampshire."

In its response to the Interim Audit Report the

Committee treasurer states that "DFP strongly, but respectfully,

objects to this recommendation. The two are separate committees.

DFP is not required to maintain CA's records nor has it maintained

such records. As such, DFP is unable to provide any requested

records." The Committee provided no further information.

However, Counsel for CA responded to the request

for records made of that committee. Though denying any CA

disbursements were in connection Senator Dole'S presidential

campaign, copies of documents, including bank statements invoices

and cancelled checks for expenditures relating to Iowa or New

Hampshire were provided. In addition, CA provided the script and
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-47-

related documents used for the telemarketing program in Iowai a

follow up letter associated with the telemarketing effort, and

several documents relating to CA speeches made by Senator Dole in

Iowa and New Hampshire.

The conclusions presented below are based on an

analysis of the documents provided by CA in response to the

request for records, material obtained via subpoena and discussed

in the interim audit report, CA and other committee disclosure

reports, and Committee records.

a. Iowa

The Audit staff concludes that CA engaged in

Presidential testing-the-water activity in 1986 and 1987 and that

portions of that ~ctivity are allocable to the Iowa spending

limitation. Specific programs and types of expenses are discussed

below:

i. Telemarketing

-,

The largest single program that CA conducted

in Iowa appears to be a telemarketing program which took place in

october and November of 1986. According to the telemarketing

contract, the phone calls were to begin on October 16, 1986 and be

completed by October 30, 1986. The election date was November 4,

1986. The contract stated that people who responded favorably to

the survey would be sent a follow-up letter. An additional series

of phone calls was added later and were to be completed by

November 2, 1986.

The Reports Analysis Division questioned CA

about the telemarketing program. In a letter from Judith Taggart,

CA Treasurer, dated June 24, 1987 it was explained that this

program was "to determine the best means for supporting 1986 state

and federal candidates" and "no Iowa candidates were named in this

effort, thus the expenditure was general party building." In

correspondence, this telemarketing effort is referred to as either

Iowa Phone program, Get Out the Vote Program, or survey.

In a letter from the telemarketing firm to the

treasurer of CA, the telemarketing firm noted that "Floyd Brown,

your field representative for this region has been extremely

helpful in making this survey most successful for Senator Dole."

(emphasis added)

The Audit staff reviewed the CA disclosure

reports to identify candidates and committees supported by CA

between October 16, and November 4, 1986. Only $7,750 was spent

by CA in direct support; $3,000 for Federal candidates, $2,500 for

State candidates and $2,250 for local party committees. In

addition, in-kind disbursements totaling $9,791.98 for the

follow-up mailing mentioned in the telemarketing contract were

reported to seven state candidates.
:.~~~;:;2f~~:~""'S.{(r:-/~;:';"'~~;0;~~"-::" "; ','" ~~-': ,··..··<t~~··· ";.""' '-.. "::.1'.0 --~'" -0- .. - .." .. ·1.. ·_~ ..~~ .~ J' <c._,.~., -"'0 '.{_. '" ~_~_

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-48-

In response to the Commission's request for

records associated with the interim audit report, CA submitted

additional documentation for the telemarketing program.

An early August 1986 CA internal memorandum

states that the purpose of the program would be "To assist

Governor Branstad and other state and local candidates in Iowa by

conducting a GOTV program featuring the Majority Leader" (emphasis

added). Under "outline" the memo states that Republican voters

would be called and asked their position on state and local

elections, whose endorsement would make them more likely to

support the GOP candidates, queried about their attitude on farm

policy, and finally, tested on their level of participation.

certain respondents then were to receive a follow-up letter. (See

Memorandum at Attachment 6)

Campaign America also submitted what appears

to be a proposal from the telemarketing firm. The proposal is

addressed to Mr. Tom Synhorst (see discussion of Mr. Synhorst's

activity below). Though the proposed program is more ambitious

than that carried out, the proposal lists three major objectives:

1. To contact 228,000 Iowans and determine

whether the endorsement of each of seven prominent individuals is

more or less likely to influence their supporting the Governor in

the November election.

2. To record each person's attitude to the

above mentioned questions and store this information for future

telemarketing based on their response. Those showing a favorable

response to a particular individual's endorsement were to be

re-contacted within the final weeks before election.

3. To cost effectively provide high quality

and accurate survey data that can be utilized throughout the

project at the client's discretion. (See Attachment 7).

Included with the telemarketing documents is a

copy of the script apparently used in the program. It contains

six questions. The first two ask if the respondent supports

Governor Branstad and his statewide ticket, and a named Republican

candidate for the legislature. The third and fourth questions are

the same, but request a first and second choice. The question is

which of the listed leaders' endorsement would most likely cause

the respondent to vote for a candidate in the 1986 general

elections. The list of leaders contains the names of eight

Republicans, including Senator Dole, who were, at that time,

considered presidential hopefuls. Question five asks for approval

or disapproval of the Reagan administration farm policy and

question six seeks to determine respondent participation in the

election process. Six participation choices are given; General

Elections, Republican primaries, Presidential Caucuses, County

Republican Convention, Contributions to Republican Candidates,

Volunteer for Candidates. By late October 1986, few of these
- -.-. ~., • - ......"0"'....

-49-

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\

choices would seem to be relevant to the 1986 election cycle.

(See Attachment 8).

Two documents showing survey results were

provided. The first is on the telemarketing firm's letterhead,

dated october 31, 1986, and addresses only questions 3 and 4. The

analysis provides "B.D. responders" for each question. (See

Attachment 9)

The second document is a computer printout and

appears to be a more thorough analysis of the results. The

results for questions 3 and 4 are entitled president, 1st and

president, 2nd.~/ (See Attachment 10)

It is the opinion of the Audlt staff that

given the questio~s asked during this survey and that Governor

Branstad appears to be a supporter of Senator Dole (see discussion

below of "Agricultural Summit" held in late November 1986 and

co-hosted by Senator Dole and Governor Branstad), the primary

purpose of this telemarketing effort was testing-the-waters and

the costs are allocable to Iowa. Campaign America paid the

telemarketing firm $70,859.65 for their services.

In addition to the expenses discussed above,

CA paid a Washington area firm $8,010.67 to purchase and edit the

Iowa Republican voter tape, print survey cards, print labels,

keypunch telephone canvass card data, update the master file with

survey data, and print selected "Dole favorable" labels. These

costs are also allocable to Iowa. Campaign America also made

three payments in early 1987 to this vendor for services described

as selecting and printing of Dole favorables; computer tapes of

Dole favorable (first choice), Dole favorable (second choice); and

selecting and printing labels for persons in selected Iowa

counties. These invoices suggest use of the survey data with

respect to CA events in Iowa during January and February 1987.

The three payments total $979.60 and are allocable to Iowa.

The Committee used the services of this same

vendor and made payments to the vendor in excess of $400,000.

Campaign America provided documentation for

the telemarketing follow-up letters. The cost of printing and

mailing 58,000 letters was $11,091.98. An apparent draft of the

letter was submitted. The letter encourages the addressees to

vote for Governor Branstad and points out Senator Dole's

leadership on agricultural issues. (See Attachment 11)

~/ On the copy of the telemarketing script provided by CA,

Senator Jesse Helms is Isited among the leaders for

questions 3 and 4. On the summary of survey results,

Senator Helms has been replaced by Alexander Haig.
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-50-

"

Campaign America reported these expenses as

in-kind contributions to seven Iowa candidates. The cost of ~his

letter is allocable to Iowa.

The Commission determined that only the ~elemarketing expenses CA paid to a Washington area firm in the

amounts of $8,010.67 and $979.60 are allocable. Attachment 12 is

a summary of the telemarketing expenses.

ii. Events

The CA records made available indicate that at

least 19 events, speeches, or meetings were held in Iowa between

March 31, 1986 and February 23, 1987. These records also indicate

that Senator Dole was present for 17 of the events. Though the

available records do not establish the nature of all of the events

the following items are noted:

0

$

" 0

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"0

0

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r.

,

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In mid April 1986, CA paid expenses for receptions

in Wapello, Iowa. Available records do not

establish the attendees or the purpose of the

event.

In early May 1986, Senator Dole and 8 other persons

were in Iowa for the Iowa Republican Congressional

District Conventions.

In June 1986, Senator Dole and three others were in

Iowa for the Iowa Republican Convention.

In late July 1986 Senator Dole is shown as the

"Special Guest" at a picnic in Atlantic, Iowa

sponsored by the Fifth District Republican Party.

In late August, 1986 Senator Dole and 6 others were

in Iowa for the Iowa State Fair. CA paid for a

backdrop and flags which were delivered to the

fairgrounds.

In mid September 1986, Senator Dole and three

others were in Iowa for "Senator Grassley Birthday

Events".

In mid October 1986, a "Steering Committee Meeting"

was held in Des Moines. At least four CA personnel

attended.

In late october 1986 Senator Dole visited at least

three cities in Iowa along with six other persons

whose expenses were paid by CA.
~<'~:j~t~~{V~~J.~}~~;:;':;~l:;;:'i;;;:~"';~\~;\~·,~,;,; "'"",...,.~". .'" . . " ," ~: .

-51-

o

o

o

o

o

In late November, 1986 Senator Dole and Iowa

Governor Terry Branstad hosted a "farm summit" in

Des Moines. CA paid travel expenses for Senator

Dole and 4 other persons.

In early December 1986, Senator Dole and three

others traveled to Iowa for an address by Senator

Dole before the Iowa Sheriff's and Deputies

Association.

In mid January 1987. Senator Dole traveled to Iowa

for an address before the Iowa Lumbermens

Association. Other documentation submitted

suggests that other groups may have been addressed

during this time.

In late January 1987, Senator Dole traveled to Iowa

to address the "AGC". The documentation indicates

the topics related to the construction industry.

Campaign America sponsored at least three "Town

Meetings" in Iowa. Documentation provided

indicates that the events occurred on 2/7/87 in

Orange City, Iowai 2/12/87 in Dubuque, Iowa and

2/22/87 in Des Moines. These events appear to be

similar to the events of the same name sponsored by

the Presidential Committee. The 2/22/87 Town

Meeting occurred after the beginning of the

Presidential Committee activity. (The Committee's

earliest reported expenditure is 2/10/87 and the

Committee's first bank account opened on 2/18/87).

The invitation postcards were printed by the same

Iowa firm who printed the later cards for the

Committee. The postcard for the February 22, 1987

town meeting appears to be the same size and format

as those used by the Committee, and uses the same

photograph of Senator Dole. No samples for the

others are available. The postcard for the

February 22, 1987 event begins with the message

"With the 1986 campaign behind us, Republican

voters and candidates clearly have major challenges

ahead in 1988. During this meeting I would like to

hear your views and concerns while sharing some of

my own with you regarding our shared Republican

future." A flyer associated with the same

printing bill is entitled "Bob Dole on the Issues"

and includes a quote from the Washington Times of

January 15, 1987 which begins "If Sen. Robert Dole

is running for the White House, he'S off on the

right foot."

In addition on February 7, 1987 Senator Dole

addressed the Iowa Bankers Association in Sioux
f~~~w,,;,'" ,;::<;>:.J.~~f;f*(iir<,,'i~:;'::"~'~·""-'" ",.

-52-

City. In the text of that speech Senator Dole

cpmments "Sioux City is one of my favorite places.

In fact, lately, any place in or near IOWa is one

of my favorite places." (See Attachment 13, p. 1)

In a memorandum dated February 18, 1987 titled

"Iowa talking points" under the sub heading

"General Objectives of Iowa Talking Points" the

following appears:

"Offer Iowans a Friend in the White House. If

candidates are confronted with questions: How

should your PAST commitments assure Iowans that if

you are elected Iowa will have a friend in the

White House ... " (emphasis in original). (See

Attachment 14, p. 4)

r i:~1~-

~,

,

o

and events

visited 18

with these

$76,403.80

Finally, on February 23, 1987 CA paid for a

breakfast for S3 people in Davenport, Iowa. The

talking points memorandum noted above begins with a

section titled Quad Cities Issues.~/

During the period covered by these meetings

Senator Dole appears to have made 17 trips to Iowa and

different cities some repeatedly. The costs associated

events which are not included elsewhere total

of which $30,268.81 is allocable to Iowa.

The Commission determined that of the events

discussed above, only the expenses associated with the three Iowa

Town Meetings (2/7/87, 2/12/87, 2/22/87) and the 2/23/87 Breakfast

Meeting in Davenport, Iowa are allocable. These expenses total

$14,684.35. Attachment 15 includes a listing of events and

associated expenses.

iii. Campaign America Iowa Staff

In addition to the Iowa activity discussed

above, CA records show a significant staff effort in Iowa during

1986 and early 1987.

Floyd Brown: Mr. Brown's mailing address is

in the Washington D.C. area. Available records indicate that he

was on the CA payroll effective mid March 1986 through late

February 1987. He was on the Committee payroll effective March

16, 1987 with the title of Regional Director for IL, IN, lA, NO,

SO, WI, MN, NE, and MO.

During his employment at CA, records reviewed

indicate that Mr. Brown made 29 trips to Iowa of 1 to 6 days in

duration. He was in Iowa before and/or during nearly all CA Iowa

~/ Quad Cities are comprised of the following: Davenport, IAi

Bettendorf, IA; Moline, IL; and Rock Island, IL.
'0

Mr. ~~nhorst is shown on the Committee's staff

list as a regional director for Iowa and Ransas.

-54-

Jane Voights: Ms. Voights was employed

between mid June and the end of August 1986. She had a telephone

in her name which CA raid for and which was referred to as CA's

Iowa telephone. Her expenses were for car rentals, meals,

mileage, supplies, lodging, stamps, etc. There was one shipping

bill which described the contents as "Campaign Literature." The

date and location to which the material was shipped corresponds to

a late July event in Atlantic, Iowa.

In addition to Messrs. Brown and Synhorst, CA

retained the services of seven individuals with Iowa addresses

during parts of 1986 and early 1987. Each is briefly discussed

below.

Mr. Synhorst' salary and expenses total

$20,955.78. The amount allocable to the Iowa spending limitation

is $17,688.78. As with Floyd Brown, the S-day rule is not

considered to be applicable. A schedule of Mr. Synhorst's

activity is at Attachment 17.

Mr. Synhorst is shown in Committee files as

the addressee for telephone and electric bills for the Committee's

Des Moines apartment beglnning on February 17, 1987 for the

electric service and February 13, 1987 for telephone service.

Both of these dates are during his employment with CA and before

the final CA Town Meeting. Two of his expense vouchers paid by CA

in February contain charges for the security deposit and the first

rent payment for the apartment. Mr. Synhorst notes that this is

where he and the "National Staff" will stay when in Iowa. Mr.

Synhorst also submitted an expense reimbursement request to the

Presidential Committee dated February 4, 1987 to cover a clipping

service. This request was made while he was employed by CA.

Available records indicate that Ms. voights

WdS associated with at least four meetings or events in Iowa. One

in late June at the time of the Iowa Republican Party convention,

a late July event where Senator Dole was to appear, an early

August meeting in Des Moines, and an October event in Council

Also the postage for the follow up letters

associated with the telemarketing program ($5,950.00) was

apparently paid by Mr. Synhorst in Des Moines during the later

part of October and reimbursed by CA. A memo from Mr. Synhorst

apparently faxed from Senator Grassley's offlce requests checks

for postage, printing and mailing. The postage check was made

payable to Mr. Synhorst. Accordlng to the documentation submitted,

the printing and mailing checks were dated October 27, 1986 and

~ere "Federal Expressed" to Mr. Synhorst at Senator Grassley's Des

Moines campaign office.

~~~~~~%a'"}7"""'"''"'''''''., -"~ ...."", ""~-O>"""',.~"~,,.,~.,.

: ~"

'I
-53-

events, trips by Senator Dole and for various meetings with CA

Iowa based staff. (See above.) During a number of these trips

Mr. Brown paid for his expenses as well as those of other staff

persons.

As noted in the discussion of the

telemarketing program, a letter from the telemarketing firm in Des

Moines refers to Floyd Brown as CA's field representative for that

region. In late October he attended a "Steering Committee

Meeting" in Des Moines. A note on records relating to a late

November, 1986 trip states that he will meet with one of the Iowa

CA staff concerning the "90 day plan." It is noted that this trip

occurred after the 1986 election and that 90 days from the date of

the trip would correspond to the beginning of Committee activity.

Mr. Brown's expenses for this trip were paid by CA.

Though Mr. Brown travelled to other states on

occasion, it is the opinion of the Audit staff that the records

reviewed to date indicate that Mr. Brown's primary focus was on

the state of Iowa and that when viewed in light of the other CA

activities discussed below, his salary and expenses should be

considered testing-the-waters expenditures. Attachment 16 shows

Mr. Brown's travel and salary. Payments to Mr. Brown totaled

$47,823.40, of which $38,052.40 is allocable to the Iowa spending

limitation. (See also Attachment 15 - Events)

AS noted above, given that during this time

Mr. Brown was not a Committee staff person, no attempt has been

made to apply the 5-day rule at 11 C.F.R. S 106.2(b)(2)(iii).

Tom Synhorst: Mr. Synhorst appears to be the

second CA staff person who has a Washington D.C. area address and

whose primary focus was in Iowa. Mr. Synhorst received consulting

payments of $1,000 per month which appear to cover the period

April through December of 1986 and salary for January/February

1987. The earliest expense request noted from Mr. Synhorst is for

a trip in January 1987. However, other documents reviewed

indicate that he was in Iowa earlier on several occasions

beginning in March of 1986. It was also noted that Mr. Synhorst

received consulting payments through November of 1986, as well as

expense reimbursements, from the 1986 re-election campaign of Iowa

Senator Grassley. Given his involvement in that campaign, it

seems likely that he visited Iowa earlier in the year 1986 while

receiving consulting payments from CA.

It was also noted that Mr. Synhorst held

meetings or job interviews with several persons in Iowa. With the

exception of one expense reimbur~pmpnt these persons were not paie

by CA, but in at least two cases, worked for the Committee.

The proposal from the telemarketing firm whicc

handled the telemarketing program dlscussed above was addressed tc

Mr. Synhorst and dated August 1986.
-55-

, " -

Bluffs. Consulting fees and expenses for Ms. Voights total

$5,049.89. The entire amount is allocable to the Iowa spending

limitation. Ms. Voights received no payments from the Committee.

John Rehmann: Mr. Rehmann was a paid

consultant from July 1986 to January 1987. His expense reports

indicate meals, telephone, and supplies. Like Ms. Voights he is

associated with the late July event where Senator Dole was to

appear.

He notes having attended a "strategy committee

meeting" on October 22, 1986. He also notes expenses involved

with the leasing of office space and gives an approximate location

in Des Moines. CA shows no payments for Iowa office space but the

Committee's Iowa office was located in the vicinity mentioned by

Mr. Rehmann. Mr. Rehmann's consulting and expenses total

$3,734.13, of which $3,729.43 is allocable to Iowa.

The Committee paid Mr. Rehmann consulting fees

and expenses from mid-December, 1987 to mid-March, 1988.

Cal Hultman: Mr. Hultman was paid a

consulting fee from September 1986 until March 1987 and travel

expenses. He notes having attended the October 22, 1986 "steering

committee meeting" in Des Moines.

He also is associated with the late October,

1986 event noted above under Jane Voights. Mr. Hultman's fees and

expenses total $12,022.61, of which $12,016.00 is allocable to

Iowa. The Committee made no disbursements to Mr. Hultman.

Penny Brown: Ms. Brown was paid a consulting

fee for December 1986, and January 1987. She also received

expense reimbursements. Available documentation indicates that

Ms. Brown was associated with a December 7, 1986 visit by Senator

Dole. (See Event listing at Attachment 15) Total payments to Ms.

Brown are $5,947.02, of which $4,892.42 is allocable to Iowa. The

Committee made no payments to Ms. Brown. Like Mr. Synhorst, Ms.

Brown was an employee of the Grassley Committee in 1986.

Jeff Nelson: Mr. Nelson was paid two

consulting payments, one in November, 1986, and one in January,

1987. These payments total $3,500.00 and are considered allocable

to Iowa. Mr. Nelson received no payments from the Committee.

Carol Lehmkuhl: Ms. Lehmkuhl was paid one

consulting payment of $1,200 on March 4, 1987. She received her

first Committee salary check on April 1, 1987 and was shown by the

Committee as the Des Moines Office Manager. Like Mr. Synhorst and

Ms. Brown, Ms. Lehmkuhl was an employee of tk~ ~,~ssley Committee

in 1986. The $1,200 payment is allocable to Iowa.
-56-

"-""';"~:.?~-"'-'~~'" _~""L- .• -r'"1"I.~;-

\

Wythe willey: Mr. willey received one $4,000

consulting fee to cover January and February 1987. He received no

payments from the Committee. This payment is considered to be

allocable to Iowa.

The Commission determined that only the CA

Iowa Staff expenses associated with the three Iowa Town Meetings

(2/7/87, 2/12/87, 2/22/87) and the 2/23/87 Breakfast Meeting in

Davenport, Iowa are allocable. These expenses total $5,155.31 for

F. Brown and T. Synhorst and $5,059.39 for other Iowa based staff.

Attachment 16 is a listing of the Iowa staff expenses.

iv. Miscellaneous Iowa Expenses

Finally, there are a number of other Iowa

expenses not included in the above categories. These include

miscellaneous travel to Iowa, postage for Iowa mailings, charter

costs for a trip to Cedar Rapids, and expenses for a December 1986

Washington, D.C. breakfast meeting concerning Iowa

telecommunications. These expenses total $3,746.93 of which

$3,097.93 is allocable to the Iowa spending limitation. Since

none of these expenses are associated with the three Town Meetings

or the Davenport Breakfast Meeting, the Commission determined that

they are not allocable. (See Attachment 19)

The expenses discussed above indicate that CA

engaged in activities in Iowa during 1986 and early 1967 which

appear to be for the purpose of advancing Senator Dole'S candidacy

for nomination for the Office of President. The expenses show a

significant staff presence in the State, a series of events and

meetings many of which were attended by Senator Dole as well as

addresses to various Iowa groups by the Senator. A substantial

telemarketing program was undertaken to determine Senator Dole'S

strength compared to likely Presidential opponents and to identify

potential supporters. In 1987, the CA Iowa staff also appear to

have been making preparations for the Committee's Iowa effort. It

is also noted that Senator Dole was seeking re-election to the

Senate from Kansas in 1986.
A summary of CA's Iowa expenses is shown

below:

Iowa NonAllocable

Category Amount

Telemarketing Program

Events

IA Staff Expenses:

F. Brown and T. Synhorst

Iowa Based Staff

Miscellaneous

Iowa Allocable

Amount

$ 8,990.27

14,684.35

5,155.31

5,059.39

-0-

$ -0-

6,522.50

1,476.00

-0-

-0-

TOTAL

b. New Hampshire

$33,889.32 $7,998.50

Similar to Iowa, CA was active in New Hampshire in

the later part of 1986 and early 1987. Though the program appears

to be smaller, the types of activity are similar and the

conclusion concerning testing-the-waters is the same.

i. Events

Like Iowa, CA held a number of New Hampshire , meetings, events or groups of events between March 1986 and

February 1987. Available records indicate nine such events and it , appears that Senator Dole was in attendance at seven of the nine.

Listed below is specific information about these events.

o

•

o

A meeting and luncheon for 18 people, including

Senator Dole, was held in New Hampshire in early

March 1986.

In mid June 1986, Senator Dole and at least 2 other

CA staff attended a "Rudman Event" in Manchester,

New Hampshire.

Donald Devine*/ and Paul Russo were in New

Hampshire between June 18 and 20, 1986.

• A series of events were held in New Hampshire between August 24 and 29, l~~~ Senator Dole was in New Hampshire

for the majority of this tilli. Available records make note of a

photo opportunity, a Dole banquet and a luncheon. One expense

~/ According to documents provided by CA, Donald J. Devine was

the "Consulting Director" for CA.
~~~~,'Fj:e'~~!~~;~f"i':::~;>" ., "'~r."" "-""~";'

~;.;

!

. -.---......'.

-58-

voucher refers to the "Liberty Weekend." In addition to some New

Hampshire residents who were reimbursed for expenses, at least 5

others were in attendance including Secretary Dole. A bill from a

photographer includes a charge for making a video tape of the

Liberty Weekend. A memorandum from Suzanne Niemela notes that

money was collected at the door of one event and paid directly to

the restaurant. This memorandum also notes that seven checks made

payable to the "Dole Committee" were collected and that Ms.

Niemela needed assistance in cashing them. She states that

"{t]hey should be deposited in the Campaign America PAC or 'Dole

Committee' and a new check should be cut for the Greenhouse

Restaurant."

• Campaign America paid for a hospitality suite on

October 5, 1986 for the "Republican Convention."

o On October 24, 1986, Suzanne Niemela rented a

backdrop, podium and public address system for a news conference.

o Between December 11 and 13, 1986, Senator Dole made

two trips to New Hampshire. On December 12, food was purchased

for a meeting. Also, a meeting room was rented and refreshments

for 40 guests were ordered. Records further indicate that Senator

Dole addressed the Portsmouth Rotary Club on December 11, 1986 and

the University nf New Hampshire commencement on December 13, 1986.

o Senator Dole visited two locations in New Hampshire

between January 24 and 26, 1987. On January 25, CA paid for

brunch for 67 people.

o Senator Dole was in New Hampshire on February 16,

1987 to address the Keene Rotary Club. Campaign America paid for

a hospitality suite and refreshments for 90 people and a breakfast

for 60 people.

Expenses for these events not considered

elsewhere total $25,148.10, of which $16,025.71 is allocable to

the New Hampshire spending limitation.

The Commission determined that none of

the expenses associated with the events discussed above are

allocable. Attachment 20 is a listing of these events.

ii. Voter Lists

The auditors reviewed documentation

related to 117 payments, totaling $3,136.26, to various New ~ampshire towns f~( the purchase of Voter Lists. The dates of

payments for these lists were between October 16, 1986 and January

29, 1987, althou~:l it appears that the initial request was made by

letter, signed bv Ms. Niemela, on October 3, 1986.
!t~~i~~;l!71t.~:~~~~"~~'''''·P!tl..;:''';::;,",,':~''''e-~'S!'''' .:"~~,"':'::£'';fi·''i~it::;t.:'"''~.r''','~~···~ ..:."C·t,,''' ," '- - .,......."' ....t.;"...... -."..·.·'_H... • ..,

1..(ll~\~

:.

-59-

iii. Telephone Expenses

Campaign America paid for a business

telephone in New Hampshire. No record of payments for any office

facility is noted in the available records and the documentation

provided does not show an address. The telephone bills indicate

that the service was maintained by CA between October 1, 1986 and

February 24, 1981 at a cost of $2,223.16. Of this amount,

$1,381.03 is allocable to the New Hampshire spending limitation.

It was also learned that the Committee paid the telephone bill for

the same telephone number covering the period February 2S to March

24,1987.

iv. New Hampshire Staff

Campaign America employed three persons

who appear to have worked on the New Hampshire programs.

Paul Russo: Mr. Russo was a Washington

area consultant. Campaign America'S reports indicate that Mr.

Russo received his first consulting payment on April 1, 1986.

This payment was likely to cover the month of March, 1986. His

first expense reimbursement is reported as a March 12, 1986

transaction. No documentation was submitted by CA for payments

made to Mr. Russo before June 1, 1986. In addition, no

documentation was submitted for a June 30, 1986 expense

reimbursement. Available documentation indicates that between the

beginning of June 1986 and the end of August, 1986, all of Mr.

Russo's travel was to New Hampshire. No travel reimbursements are

reported after the August, 1986 trip. Mr. Russo received his last

consulting payment on October 3, 1986.

A copy of a memorandum from Mr. Russo

indicates that he had hired Suzanne Niemela (see below) "to work

the New England Region for Campaign America, establishing a 'desk'

in Concord, New Hampshire." As noted below, Ms. Niemela worked

only in New Hampshire. It is also noted that Mr. Russo made a

trip to Iowa during the first week of May, 1986.

Mr. RUsso's consulting payments for June

through August, 1986 are considered to be New Hampshire expenses.

These payments total $13,461.12 of which $12,341.63 is allocable

to the New Hampshire spending limitation.

The Committee made no payments to Mr.

Russo. Attachment 21 is a schedule of the CA payments to Mr.

Russo considered to be allocable to New Hampshire.

Suzanne Niemela: Ms. Niemela was hired

effective July 1, 1986. On or about August 1, 1986, Ms. Niemela

moved from Massachusetts to Concord, New Hampshire. Her moving

expenses were paid by CA. Available documentation indicates that

with the exception of one trip to the Washington D.C. area, Ms.

Niemela worked exclusively in New Hampshire. She received
-60-

.~~·~{.~l~l~~f''!.''·'''~-;'''';''''';.~''''~·'s-')......'1!>-O~~~'.-_~ .... ""_.... ••• .... - .. ......-~ ... .;: ....~"."-.. "'.'" • -~ .,.~,,,"l._:/~ .. i·....;Jo,T< ,-,,,,,,,,;;,_, r...... r.~··' ...· ~-~ •..l '-'.

~:~~/I"

;'.\

J;

consulting fees during the period July 1986 to February 1987 and

expense reimbursements covering activity from September 1986 to

February 1987. Expenses include phone, travel, supplies, copiers,

typewriter rental, etc. Beginning in March 1987, Ms. Niemela

received a salary from the Committee and is shown by the Committee

under New Hampshire staff - Regional Advance and Scheduling.

Attachment 22 shows CA payments to Ms.

Niemela. Payments related to New Hampshire total $17,959.91 with

$17,818.26 being allocable to the New Hampshire spending

limitation.

Finally, documentation was submitted for

a New Hampshire trip made by a Mr. Jim Murphy on February 26 and

27, 1987. The only other payment to Mr. Murphy by CA was a $1,250

consulting payment reported on March 12, 1987. Committee records

indicate that Mr. Murphy was to be the Northeast Regional

Director. A March 11, 1987 Letter of Agreement between the

Committee and Mr. Murphy also notes that he was to be paid $1,250

as a consulting fee for the period March 1, to March 15, 1987.

The amount was paid on March 13, 1987. Committee documentation

also indicates that Mr. Murphy was expected to live in the Boston

area for the duration of the Campaign. On March 11, 1987, Mr.

Murphy drove his car to Boston to "Begin Job." Mr. Murphy was

later named the head of the Political Field Division and moved to

the Washington area. He was on the Committee's payroll effective

March 16, 1987. Total payments for Mr. Murphy by CA are $1,590.60

of which $1,417.50 are allocable to New Hampshire.

The Commission determined that none of

the expenses associated with the New Hampshire Staff expenses

discussed above are allocable. A summary of CA's New Hampshire

expenses is shown below:

Category

New Hampshire

Allocable Amount

New Hampshire

Non-Allocable Amount

Events

Voter Lists

Tele'phone

NH Staff Expenses:

Niemela/Russo

Jim Murphy

$ -0-

3,136.26

1,381.03

-0-

-0-

$ -0-

-0-

842.13

-0-

-0-

TOTAL $4.517.29 $ 842.13
The expenses discussed above in~teate

that CA engaged in activities in New Hampshire during 1986 and

early 1987 which appear to be for the purpose of advancing Senator

Dole's candidacy for nomination for the Office of President. The

expenses show a staff presence, a series of political events and

an effort to accumulate voter lists.

+_'« .1'< .::;~""'~"'~~"II\i<f'i!"'''''_,l';1''~''":'':~F.'O\Ji'''';1~*~~~~~~~1­

.~~~

':~

£~:) .....:.

l

~~

The Audit staff also learned that Campaign

America had committees registered at the state level in both Iowa

and New Hampshire. Though both the Interim Audit Report and the

request made to CA asked for information on these committees, no

information has been provided.

Presented below is an overall summary of the

CA activity which is considered testing the waters.

Non

State Allocable State Allocable

Iowa $33,889.32 $ 7,998.50

New Hampshire 4,517.29 842.13

Total $38,406.61 $ 8.840.63 0-

,

'0

o

Grand Total $ 47,247.24
13. Recap of Io~a and New Hampshire ~llocations

Presented below 1s a recap of allocable coat. to

Iowa and New Hampshire.

Amount Allocated by

the Committee

Audit Additions:

1. Twenty-Five Percent

rundraising Exemption

(Travel, Events)

Iowa

$ 793,230.82

28,450.36

New Hampshire

$ 462,462.20

13,997.06

2. rundraising ExemptionsDirect Kail Costs

3. Credit Card Phone Calls

(Intra-state)

4. Phone Banks

5. NE Regional Office

6. Compliance ExemptionsMedia Costs

7. Broadcast Media

8. Media Commissions

(Production)

9. Travel and Salary Costs

10. Non-Travel and Salary

Costs

11. Polling Expenses

51,935.78 43,618.56

23,280.46 1,696.44

-0- -0-

-0- 54,341.62

16,061. 46 13,961.15

2,595.98 37,295.89

2,664.64 2,988.08

73,161.62 66,349.25

35,179.99 31,085.16

21,497.25 31,636.50

12. "Testing-the-WatersExpenditures Made

by Campaign America

Total Allocable Amount

Less: Expenditure

Limitation

Amount in Excess of

of the Limitation

33,889.32

$1,081,947.68

(775,217.60)

$ 306.730.08

4,517.29

$ 763,949.20

(461,000.00)

$ 302.949.2.0.
~~.~!t~l:.r

....

-63-

As explained above, the Audit staff has determined

that the Committee has exceeded the expenditure limitation in Iowa

by $306,730.08 and in New Hampshire by $302,949.20 for a total of

$609,679.28. Shown below is the calculation of the amount

repayable to the U.S. Treasury as a result of these expenditures

in excess of the state limitations:

.~

;""

Amount in Excess of the State

Expenditure Limitations

Times the Repayment Ratio from

Finding III.A.

Repayment Amount

Recommendation IS"

$609,679.28

.278907

$170,043.82

The Audit staff recommends ~hat the Commission make an

initial determination that $170,043.82 is repayable to the United

States Treasury pursuant to 26 U.S.C. 9038(b)(2).

Repayment Amount: $170,043.82

D. Apparent Non-Qualified Campaign Expenses - Delegate

Committees

Section 9038.2(b)(3) of Title 11 of the Code of Federal

Regulations states that the Commission may determine that

amount(s) spent by the candidate, the candidate's authorized

committee(s), or agents were not documented in accordance with 11

C.F.R. 59033.11. The amount of any repayment sought under this

section shall be determined by using the formula set forth in 11

C.F.R. S9038.2(b)(2)(iii).

Section 9033.11 of Title 11 of the Code of Federal

Regulations states, in ~art, that each candidate shall have the

burden of proving that disbursements made by the candidate or his

authorized committee(s) are qualified campaign expenses. For

disbursements in excess of $200 to a payee the candidate shall

present one of the following:

A receipted bill from the payee that states the purpose

of the disbursement; a cancelled check negotiated by the payee and

a bill, voucher or invoice generated by the payee stating the

purpos~ of the disbursement, or a voucher or comtemporaneous

mem~-.'ndum from the candidate or committee that states the purpose

of th' disbursement. Where neither a receipted bill nor

s~p~')Lting documentation as described previously is available, a can~elled check negotiated by the payee that states the purpose of

t. P. Jisbursement is required. Where a cancelled check stating

pUC00Ge is not available the committee may present a check and

collateral evidence to document the qualified campaign expense.
r~~~~1'~?,7?.l:~Wt"." ..,'.. '~.' ,..'.. ":; '~1~~-

>~.

<~~.

-64-

Such collateral evidence may include, but is not limited to,

evidence demonstrating that the expenditure is part of an

identifiable progr8m or project which is otherwise sufficiently

documented or evidence that the disbursement is covered by a

pre-established written campaign committee policy.

For all other disbursements the candidate shall present

a cancelled check negotiated by the payee that states the

identification of the payee, and the amount, date and purpose of

the disbursement.

The Audit staff reviewed all available records and

delegate committee disclosure reports pertaining to eighteen

delegate committees apparently formed to support Senator Dole's

campaign. Fifteen of these committees were located in Illinois

and the remaining three were located in Maryland. Senator Dole

authorized th:rteen of these delegate committees on amendments to

his Statement of Candidacy. Four of the five non-authorized

delegate committees filed statements of organization with the FEC

and listed the Committee as an affiliate.

During the review of disbursements made by the delegate

committees, the Audit staff noted that $46,821.90 in disbursements

were not documented in accordance with 11 C.F.R. 59033.11.

At the exit conference the Committee Treasurer stated

that he was still attempting to obtain the missing documentation

from the delegate committees. A listing of the missing

documentation was provided to the Committee during the fieldwork

and again at the exit conference.

In the Interim Audit Report, the Audit staff recommended

that the Committee submit documentation which demonstrated that

the above expenditures are qualified campaign expenditures and

absent such a demonstration, the Audit staff would recommend that

the Commission make an initial determination that the Committee

make a pro rata repayment of $13,103.95 ($46,821.90 x .279868*/) to

the United states Treasury pursuant to 26 U.S.C. 59038(b)(2).-

In the Committee'S response to the Interim Audit Report,

the Treasurer states the following:

The problem is that the Illinois committees came at

the end of our candidacy. The individuals "running"

the committees went their various ways and with them

went their records. I realize that this is not an

excuse but I want to make it clear to the Commission

that these committees wer~ 'O~ l.1sed in anyway to

skirt the limits but rather were used for their

stated purpose of attempting to win delegates from

~/ It should be noted that the repayment ratio was revised to

.278907 subsequent to the Interim Audit Report.
!ft!fl(:7:~f~~~~~~~'[,~t"" ..'

,.. or.--" .---

"

-65-

various congressional districts. The expenditures

made by these committees were legitimate campaign

expenditures. However, I realize that they do not

become "qualified" campaign expenditures until there

is some record. I ask the Commission to show

leniency with regard to these committees and accept

as much as possible of the expenses for which any

kind of record exists.

The Committee's response includes the same incomplete

delegate committee records provided to the Audit staff during the

fieldwork. However, the auditors obtained most of the necessary

records as a result of requests sent to the delegate committees or

subpoenas sent to the banks where the delegate committees had

maintained their accounts.

These requests were sent to the thirteen delegate

committees authorized by the committee and one delegate committee

not authorized but which noted on a bank confirmation statement

that the Committee Treasurer was an authorized signatory on the

bank account. Subpoenas were sent to the banks where these

fourteen delegate committees had maintained their accounts.~/

Based on the Audit staff's review of the subpoenaed

records, we determined that $13,470.04 in disbursements made by

the fourteen delegate committees were still not documented in

accordance with 11 C.F.R. 59033.11.

Recommendation 19

The Audit staff recommends that the Commission make an

initial determination that $3,756.89 ($13,470.04 x .278907) is

repayable to the United States Treasury pursuant to 26 U.S.C.

9038{b) (2).

Stale-Dated Committee Checks ..... E.

Repayment Amount: $3,756.89

Section 9038.6 of Title 11 of the Code of Federal

Regulations states that if the Committee has checks outstanding to

creditors or contributors that have not been cashed, the Committee

shall notify the Commission of its efforts to locate the payees,

if such efforts are necessary, and to encourage them to cash the

outstanding checks. The Committee shall also submit a check for

the total amount of such outstanding checks, payable to the United

States Treasury.

The Audit staff reconciled the Committee's reported

activity to its bank activity through September 30, 1988 and

~/ Requests for records were not sent to the four

non-authorized delegate committees.
-,. '.. T ...... - ~,._ ~--• .:- ..... ,,~ • __ -.]V .,._ '-'.

-66-

determined that the total amount of outstanding checks was

$201,142.82. A review of the Committee's bank statements and

cancelled checks for the period 10/1/88-2/28/89 indicated that

$90,917.21 had been paid and $460.82 had been rejected for stale

dates by the bank leaving $109,764.79 in outstanding checks. This

outstanding check balance consisted of 214 checks.

Of these, 141 are contribution refund checks. The

remaining are to individuals and vendors in payment for various

obligations. It is recognized that some number of the non

contribution refund checks may represent checks that were voided

but for which no record of the voided checks was found.

In the Interim Audit Report, the Audit staff recommended that

the Committee present evidence that:

a) the checks were not outstanding (i.e., copies of

the front and back of the negotiated checks); or

b)

c)

the outstanding checks were voided (copies of the

voided checks with evidence that no committee

obligation exists, or copies of negotiated

replacement checks); and

the Committee attempted to locate the payees to

encourage them to cash the outstanding checks.

The Audit staff added that they would review any

information provided and would recommend that the Commission make

an initial determination that any amounts which remain outstanding

are payable to the United States Treasury.

In the Committee's response to the Interim Audit Report,

they stated that they have voided a number of the outstanding

checks and would like to review these with the Audit staff. The

Audit staff met with the Committee to review the actions taken by

the Committee regarding the stale-dated checks.

Based on this review, the Audit staff determined that

the Committee has 178 checks, totaling $71,733.23, which remain as

outstanding. Included in this total are 142 contribution

refunds*/ and 36 payments to individuals and vendors for various

obligatIons.

In summary, the Audit staff determined that as of

September 30, 1988, the revised total amount of stale dated

outstanding checks is $71,733.23.

~/ According to a Committee official, foue of these

contribution refunds, totaling $2,446, were voided by the

Committee because they were returneG 3S undeliverable.

These four items were reported as n~~atives on the

Committee'S disclosure reports.
Recommendation 110

The Audit staff recommends that the Commission .ake an

initial determination that $11,133.23 be paid to the United States

Treasury pursuant to 11 C.F.R. 59038.6.

Payment Amount: $71,733.23

F. Recap - Amounts Repayable to the United States Treasury

Presented below is a recap of the amounts recommended by the Audit staff as subject to the repayment provisions of 26

U.S.C. S9038(b)(2) and 11 C.F.R. 59038.6.

0-

""3'"

'0

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t 0 '.

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Expenditures in Excess

of the State Limitations

(See Finding III.C.)

Non-Oualified Campaign

Expenses - Delegate Committees (See Finding

111.0. )

Outstanding Checks (See

Finding IILE.)

Total Recommended Repayment

$170,043.82

3,756.89

11,733.23

5245,533.94
ii

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Cod._•• Nil M YT .. "

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2. "oar ...nt.-. • U 7'.",

3. Intel-Stat. '.15

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,. Equl..e.1t 45,"4.2' :1,21:1.14 .,

10. p08tage/Prlntlng 1,114.5' 1,'.4.'1

11. Hew.letter _.pen•• 1,101.10

"OrAL '150,50,.55 ,

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PRESIDENr PRESIDENr PRESIDENrPRESIDENr PRESIDENT PRESIDENr PRESIDENr PRESID "-.1

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PRf.SIDENT PRESIDENT PRESIDENT PRESIDENT PRESIDENT PRESIDENT PRESIDENT PRESI

:::>E.NT PRESIDENT PRESIDENT PRESIDENT PRtSIDENT PRESIDENT PRESIDE.NT PRESIDE..

DOll FOR PRESIDENT New E.ogW1d Region Newsletter November. 1987

New Campaign Video

Ready for Home Viewing

2,500 Cheer Dole Wildly

a.t Manchester Announcement

Interested In ftndln!

out aboUt &ob Dole.

The campalgn WID

prOVIde a complee

support paaage.

,ndudlJ'lg the VIdeo.

11 you are Intere:sed

In hosOng &!ob Dole

VIdeo party. contX:

your Dole Stare

Coord1l'W'OC' or the

,,~~gtand~

Headauarters In _.

MMc:nester. N H

.'?-.. D' '=to .. -:ze:u :-fti·y.;--::·'=t:'!" IiPE'1 ""--' I .... ..... :;

career. It sho'M why

he can provtde the

common sense

IUde"."'? thIS country

wllln~ In the

1990·s.

We need you to

hold a : .}"T\C video

pasty dunng me

rr..::nth of r-,,,.. ember.

To get Involved. all

you neec 1<; your lVI

VCR. rc··est\ments and

some mends wno are

.. ,,"

Sen. Dole greered by mousands as he ettre!S

hianchescer, N.H. IWIy. No~oer 9th.

The technology of

the 1980's Is be1ng

aoplled to the Dole for

President campaign In

the form of home

VIdeo parnes thatwUl

be held aaOSS the

country In the ccmlng

weeks.

The nanonaJ camPalgn hAS produced

an affea1ng 20 minute

film de5Cnbtng

Senator Dole s life and

capped &nO dlSdbled.

• Callea fer ment

p;ry for reacnet3.

• V~rc

cefe!"ld tile nghes of

me unbOm.

• Prom~tc

light fer [me rrem

verc for me Pre$ldent.

Sen. Warren B.

Rudman. RoN.H..

rec.etVed a loud round

of apl'lause when he

saJd. -I don t ttunk

there s anyone In

AJTIenca for .....nom

there s betTe! odds

that he 11 be tt1e 41 st

President of the

United States." 'i'

conrrnuect. insIde•.

srage A bleacher

Se-::Don held 7S

memoers of the 10m

Mour.taJn DivISion ana

their WIVes Some of

t~ formes soldIers

were amred In blue

blazers and Alpine

hats. Others wore

white Sl'IO\Y uruforms

and earned skiS and

white rllles. Dole was

Seriously 'M:lunc~ In

World War 11 while

seNtng as a Secono

Ueurenant Wlm the

division In Italy

Dunng a 2Q-mlnute

s~.marked

several times by

applause. Dole:

• PromISed he

would go alter the

reaer.Ubuagetde~~

without raJ.Slng

incorne r:a.re:s.

• Pledged CO

condnue Ills concern

for the poor. hand#-

A Regional Approac.h

to New England

"I felt the ground country. symboll%1ng

shake under my feet the SPIOt of the naoon

at mv first cxmraa more absolutely than

WI til'a New E..ngland any other reglon. Mer

Town Meeong.: - all at the begtnrung.

Thomas le!FersotI New E.rIgland was

Here In New ~g. AJTIenca.

land. woe like to thlnk Bob Dole knows

of ourselves as a

dlsnna region of the

"~ore man 2..500

s.::earrung suoporterS

~'eetec Sen.nor Bob

:.ole along WIth Mrs.

::>Ole and Robin Dole.

cUMg a roustng ant'IOunc.ernern rally held

....ovembet 9th In

'w\atlc.he:ster. N H. The

rally dubbed an •AlmOSt flawless

;)C)htlc:al event" by the

state 5 largest news-

~per surpassed me

eJtoeaat1ons of many

;)C)lIncaJ obServers In

"ew Ha.mcsture.

". feel It In the au I

'eel Vlerory In the au In

'''e state of New

~&moshlCe " Dole told

theaewd.

Dole was lI~ed on

one SIde by hundreds

of young people -

memt>erS of the Youth

for Dole org!.N%.ation

In New Etlg1&nd. On

the other side of the
Dole ••• Brock ••• WirthIln

..

::

'I:

...

,.

..

•:.

:t

-.&,.- ....

jolnlng the Dole rum

as Its pollsn!'.

"Sob Dole Is the

rtght man br our

tlmes. Amenans In

1988 want a rue..

c.lwge luder who

getS results ••• He Is

the most eleeuble

~publlanIn the

strong t1e1d of a.nd}-

dates.- Wlrthttn S&ld.

W\rthlin and his

assodates ha....e

conducted more than

2.000 polltlcaf SN1les.

He has selVed as ChIef

Pollster for ~lIan

presldem:ial

dares In ftve preo.1oUs

conte:m.

n

RJchard

Wlrthlln

President' Reagan s

10ng-<1me pollster.

RIchard W\rthUn.

announced In late oaober~h....-

SeNter Dole. at a

news conference

announdng the Brodt

mOYe. said. -AddIng

Bill SrocX to our team

Is & maJor poUtk:al

coup. BesJdes being &

dose personal friend

for many yeAIS. he is •

polltlcal veterar •,1

the sovt:h. one of the

SW'S of the Reagan

cabinet.-

Talking About Bob Dole • Senator Bob Dole unJaue!y qualllled U)

has tleen a strong ana ceal WIth the dVJerrecrr...e teglSl.uor lOt enges taang Amen27 years. He has led cans~.

the tisnts and cast'the • Senator Dole has.

tough \/Ores In sup- strong reaxd olean--

porr of ttle Rr.aga."I se.rvatism In ft5aJ 1'Nfeconomic reforms. the telS I.nd bre!gn a.!ala

Gtamm~dman co\Jl)led with • I1!CDr'd

defic:lt redua!on legtS-- of a:lmpa$SlCl'l for the

ladon. &Jd to ttle disabled and d'lCBe

Nlcaraguan Freedom less fol'tUl'\Ce.

Fighters. and ttle The Dole for Pres!-

President S Strateglc dent amP&lgn Is D~ lnitlattve.. orga.nb:.ed both In the

• The Senator s key earty stares as well

background hIS ablUty as nanonaJly. Polls are

to C7\16c:cme oersonaJ shawlng suoporr foe

adve1Stty and his the campaign'S srowm ~enc:e makes turn everywtlere.. 'i'

Sef1 Dole a(jdfes5.e:s 2 500 errt:husW:tk:

SU'Pporre.'S In .......an~.

Attachment 4

Palle 2 of 4

~~~-~ _!!!II!I

. ~:

Labor Sea'ewy

\VIlllam Srock to be

NatiorW Chaltman of

the Dole ampalgn.

Brodt ls a former

Senator from Tennessee and O.alrman of

the RAe pubUan

National Committee.

Brodt Is & highlyrespeaed mat\ager.

HLs de~ from the

Department ofUbor

promoted 77le Washtngtoll Post to dub

ttle move a great gain

for ttle Dole campaign

and added. -Mr. Brode.

has se.:ved. not JUSt

the admlnlstratSon. but

ttle country welI.-

23c!e1e~

2I c!eJepta

17 c!eleg.uu°

52 deJepres

2JdeJ~

35deJepne:s

Ma. Dole dJd her

gr<!dua.-e 'NOnt In

5oston and SIded New'

Harnos:ure's \';'hlte

"'ount3.ll"lS dW1ng her

gra.au.U'e years. Sen.

Dole !\umanv New

Eng'.a.nd s:up~

who are ven:nns of

hl5 Army untt, ttle

1Oth ~untJJn

DMslon.

AsJd e from the 0~U5 In\pO~of

'leN ~ont7shlre on

February 16 New

E."l g'a."lC: COnralnS t\YO

"Super TUe:5l.Uy"

STa~-~

sens a.nd Rhode

~ane. When VenTlOnt

'lolds Its Ol'lmaJY on

.\I\1rc:n I. it "WI" stand

alone AS ttle only

pnmary eJea10n that

weeJt - an:r~g stgnl1kant NtIon&1

a.ttentSon.

• • •

Wllll;un Brock

The Dole campaign

grabbed a.t\Other one

of President Reagan's

cabinet members With

the enllsa'nertt of

Speaklng to a aowd

In Knoxvtlle. Tenn..

Dole spoke of her

husband's leadership

posttions In the Senate

and his battle to /;Nercome wounds he

r~lnWWo.

"A$ you an see. I

believe In him

strongly. and that's

why I gave up my fulltime posIt1on.- she

told ttle CI'O\fo1d..

up these £.x.eaJtlve

:>lrecrors Is a regional

supporr based In

'Aa.nd'\eser that

J'ldUdes & Press

Seaewy Youth

Coorc1lJUrof and

SchedUlerI Advance

Operatjot\S Coord.lnalot.

The SelW'O( and

,Vu's. Dole have not

b~ left Out of thl.s

regloT'.aJ WOfoach. For

obvlous reASOns ttley

are spe."lCU'lg a lot of

t.me In New Hampshire. But t...ey ve &lso

"'ade rea::'\t stoOS In

Surtlngt'On &no Cabot.

\, Port1a11C OgonC"Jrt aJ'ld Ca;:,e EJ!:.;t-

!:Jeth....\L WindSor

LocXs. Stamford and

",jew Haven cr. WarWldt. R.t. Boston.

PeabOdy. Worc:.esrer.

and Spnngfield. MA.

Febnwy 16

Tebnwy 28

MArth 1

MArth •

M..arth •

.\Wcb29

New K.1mpsh1re

MAine

Vermont

MIlSs.&chusltttl

R.hode IsWld

CoMecDaa

"l)eaUty contest

Elizabeth Dole

Elizabeth Dole g~

up her pOSItion as

Seaerary of Transportatlon on September

30th so she could

devote herself. fulltime to Senaror Dole's

"nPaJgn.

I\r$. Dole kJdted off

.:r campalgn for her

nusbaJ'ld WIth a SWIng

~hrough her nattve

;outh that begaJ'l on

:xtober 5th.

Three big names

have recenrty SIgned

on WIth the Dole ca:np,argn at the national

level

A Triple Play

about New Englanders. \\e share many

values "WIth Mldwes~ers- uprtght.

fi~Jc.e'y Inde:)endent.

hard-worldng That s

why tne Bob Dole

campalgn has taI<.en a

regloT'.al approach to

New Ellglanct

Our regional headquar.e~ IS Ioc..,ted at

852 E..on Street 111

1\.1anc.'lester. N H.

Allan W~l<er former

C'1Jef ot Staff to Sen.

INMTeII B Rudman R-

'I H IS regional field

c.:>orc;naror for New

:.:'lS'a,'lc1. Allan Is a

-.atrve "'ew E."lSlancer

ana Ms a ~reat deal of

::lOUnCAl ex:>enenc.e In

-:-us can of the

counrry

E.ach of the six

States haS an £.xeoJnve Dlfec:or aadung

A Regional Approach to New England, cont. •••
WIth other c:andlda:es

at 10% or less.

In Key £uty Stares .••

In the recent

Moines kgts:e'

poll. Dole beats BU5J'\

31% to 29% among

lIkely C3U01S attendees.

In New HampShlre..

a poll do:~ foe Sen.

Rudman among

Republ\ans who hzve

voted In recent

prlmar1e:s. putS 8ush at

31% and Dole It 22%

- WIth no one else III

double dlgltS. When

th~ polled ....-ere

Informed of Sen.

Rudman s support tor

Senator Dole. me gap

between 8ush and

Dole In New Hamoshire dosed to less

ttW\ 10%.

Hol!ancl.. amang

others. have been

woridng hard rcr

Senator Oo&e.

In Rhode I:s1&nd. A

30 me:mber Steenng

Committee thoU indudes House MJrt::r.:y

VY'hlp Atttrur M. ReJd

11 and former GOP

Chairwoman Le1Ia

fv\ahoney Is wonting

WIth Y1aory tn mlM

01'\ Ma1d\ 8th.

rattve5 a state senaror and t'M:) members ot

the R.eoubllC\j'\ State

Commrttee are key

playe..~ In a core

advtsory grOUl). State

Se.'\at'Cr Pete! Weber.

Asslstant House

M1nortty Le.a.de.r Kevin

Polner ReI:'. Pete!

ToOdIC.sen. ReI:'. Ins

Holland and State

Commmeeman Gil

5~attlrs Rudman and Dole greer Dole supporreJS u N.anctl~ t3JJy.

If you know young

peo"'e who wouki

enJOY wor1dng on the

caml:l&gn. thf!!'/ can

wnte or ca1l Ken 'i

Frc=__ •

c.'W.red by three longr.rne a~1S3 In

Conneccan R.eP\1bllcan poIttlc::s. Former

State Senate Mlnortty

Le.ader RJdWt1 C.

Bo=.:ro former \/leeCha!rman ot the Stare

R.epuClIcan Party.

Be~ Osborne: and

John e.e--Jn. former

Republican TOWT1

c.'-..al.JTr.an ot

Cre~ are lead.J.ng

:~e Do,e ettcl't..

'en staTe leq\Slators

are on the Doie team

In Conr.ee:neut. as well

as former Congres!-

man Abner W SibaL

In Vermont Senator

Robert Stafford and

form e.r Gcrwemcr

Rlchard Snelllng are

honorary a><h.aln'T1en.

House Mlnomy

Le.a.de.r M1chaeJ

BemI'1ardt. and State

RecreseruatlVe Sarah

are 'NOr1dng on

the Dole te.am.

In Massad1usett:s.

eleven stare tepre:se:n-

, 8efween Apr.'86

• and SePt.'87. the j GalJup Poll showed

-. the mar-SIn na1TC"oY\ng 't from 32 to 21 poIntS.

! 11M! ~gamle's poll

showed the gap dest tng from 49 points In

• , _... - May86 to 24 POints In

- .. {'~ ..l Aug.'S7.

-_..-.,!».:::".. ~;J; Jo=~~~ poll

"'""'I~~ ~~ 1l/;iil~-~ of Republican prtmary

c:. ......~;. ,_ • 'T Vot1'''5 sr .~~ a gap , _ I • . . :; -.1'-" of 33 p:..ntS In Aug.

~'::~~.l. • • - ., '86. 11le same poll. a ~- .-"-.... .e,~~,....... La. . ......-,.......... ~; .~_:,,: year ter. showed a • .. ••,.;:•...;.oU - • ,0<0.1 _ .,. -' ~gap ot on!' :%,

. " :'::.-~ .,.. • . t Natio!k1i ,Jlls conslsttntty ShoW a 2-way

race.. A June Huns Poll

showed Dolewn-h27%

and Bush WIth 31%. A

recent CBSIN~ York

,lines poll sh0w5 Bush

... -".". WIC III L.)"":Q.

of The NYTTrnes.

Many stUdentS supplied meJr energy &..

support at Senator

Dole's Le.a.desshll) annotIname.nt In Aug.

In the corrung months

c:am~gnlng for Dole.

Sever:&! former

Rudman sutf members haVe been

'NOr1dr'g for months on

the Dole c:ampa1gn tn

'l~ England..

"'ore t~ 250

~p\lt)lk:an ac:iVtst:S

.,. e parr of the Bob

Dole Ad\nSOrv.

E.xer:::utNe firiara and

Sreenns Comml~es

n ~~ HamCSNre.. In

addlrton to Sen..

warren B Rudman IR-

'I H.l as tiono~

CWtman. me Dole

effort In tl'lI! Grarute

State IS recped olf by

'I H. House S~r.

'h Douglas Scamman:

former Governor

Walter PetelSOn:

E.xer:::utNe Counolor

Peter Scauldlng- State

Treasurer Georg'le

Thomas. and former

Congressman Perlcins

Bass.

In Connea1cut. me

Dole c:a:T1p;ugn ts coYouth

on the Move

Whemer a football

game or a pOlitical

camPaign. nothing

matches me ernnu:g. asm of college &. HS

srueents Our Nt

Youth Coordinator.

Ken Fredme. (Manchester. N H 1. has been

organwng campuses.

large &. small. across

Sew England.

PrOlea5 have incuded a bhaing of

the DartmoutnlUnIV.

of NH foomaJl game.

rec.eNln~ ttle attention

Say\tlg "he has me

srren~h and exper1-

enc.e needed to lead

this nanon Inro me next deade " Senaror

Warre." B Rudman. Roo

'I H. rec.entty enCC~ Bob Dole for

p. e5lCem

At news centere"lCe5 Ll\ ;'.\a.l'letlester•

?o~ourn ~anon

a.~ Keene N H.,

,-c."'l"al' lI'lc.lc:ared he

::e"eved Oole 'M:lUld

:e me ·t"'o\J~ntful.

·~orousn ana

StTa.;S~t·raJliUngleader

:~IS country neeas as

Its next presIdent."

"I'm ttmlled to have

the aCNe SUOpol't of

someone as wellktlown and re:st)eCed

as Senaror Rudman is

In Nf!:'N Hamcsture " ::>ole said "H"IS VISible

C\S.S\Stanc.e In Nf!:'N

HamcS1'lre and aacss

t'le country WIll be a

-er1e"cous asset ro our c.amewgn: Dole

aoded.

1.udman said he

ex:::eceo to soend

mOSt ot hIS free ome

10th MtDtv AlumnJ

cheer Dole S oflicW

announcement.

Rudman Endorses Dole

leadership Announced

in N.H. and Other States

, J
t~i~rd.'l:~~"': •...:-:;::. .",', '"n .,

"

-.... ;0-.' ~",;, .-,.-- .,,~, "--,'.: Y ' ...,., ,......- - ••

Flncmce5-

look Good

The Dole campalsn

is maJdng great

progress In the aru ot

fundn.1s1ng. Dole

r<used money It "

~e: rate than any orner candIdate.

Democrat or RepubU.

'"\ during the

m21ly--slow summer quaner Dole

raJ.Sed almost S4

mIllion trom lui, to

Sept That brtngs the

tetal amount rats.ed to

aoproxlIT\ately S8

million. Funds are

'"OWIng In at I rate ot

$ 1.3 million a month

and SeNror Dole

expeasto ra.lse the

full S14 mUUon

2110wed by law.

Seyoncs this encouragtng news are Indianons that the 8ush

campalgn Is SPendJng

money taster than

Dole. A5 of e.ar1y Oa..

Bush had scent S2

million more than

Dole. Remember that

211 campalgns taJdng

mard\lng tund.s are

sublea to I MrJOna1

spencrng cap ot S27

mIllion. SDe.""IO.Ing

rate5 ill'e lIT\pornnt1 . -v

Your Action

AgendA

1. Set a gO&1 of

e.nIlst1ng 5 - 10 Dole

suppo~ e.adt weelL

2. Glve names L'

addresses to the IoaJ

HQor the Nt Reglonal

HQIn Mar'ld'\e:stet

(6031623-6680.

3 Hold "home

video patty lor Doie.

4. Wrtte • chedt to

Dole foT Pre$:iJenr

Commtt:ee. 1828 L

St. NW. WaY\... DC.

20036.

Bob Vld EJ/:.abertl

Dole ve councng on

your ac:::ve sucpo~

Paid for by the DOll rOR P1l!.SIDENT Committee

Where to find Us •••

Aaoss New £ngtmd-

·Cole woUld be the

Republlc.an Party's

strongest candldue.

He Is a good pUblic

speaker. an expen.

enc::ed debater and •

master of one-l\ners..•

Vhn. V S1wv'r::n

The 50smn Gc=e

-It looks as If the

race lbr the ~publlan

presldenna1 n0mination has alre&dy

narrowed to f'NO

candlca.~ - at Ius amongCalToU~

(N.H.) Republicans •..

Cole drew a W'ge

aowdof~

aaMsts duM! a

F'oUith ofJulY VISIt te

Wolfeboro.-

Q.rroll Cou.-rv lnd~eI'Ir (Nor..;

From the CUpping me ... Aaas.s me Wond- before the onslaught

-He l!ts the profile of pnmar1es on "Super

of the president whom Tuesday.· next March

many Amencans. 8. Cole 15 wide!)'

d1s1Jlusloned after I 1 VIewed &5 • compenyuss of t"NO s~ tor WIth the potential

sIve WashlngtOn to Win In six or more •

outSIders. new say of the states holding

they want: a compe- prtmarles or caucuses

tent Wide-awake from January 2.7

WashIngtOnian who through March 5.-

knows hIS way about The WashIngron Post

and WIll get things

done.•The £conomrsr.

London £ngland

Aaas.s me CounC}'-

-In the I I crttlal

testS of strengthS

00, b 32.1.1 DlMn.cr~

12031131·51"

Pe<w A. MlcheI.

~Dlr-=ar

~1s&.IM

5600 Post Ilc.cI

tuf IU 01!I1S

(l.OI155W71S

i"lII~

tx~Olreaor

M.I-.

PO. b 1119

A~Mt0&330

(2071 611·3899

NClm\II\ ISkJal Wlrts.

txecu::w DIllCDr'

Ca_ ".

'.'....u....:'--' • .DIn Sr-

• >,J' MA 01116

(617) 481·3all

!otl D.lwtoCI\.

txl!lCW\I'a DI-=r

Vena••

PO ~687

Wl'Jt'e Rlver ~on. 'IT

:lSOOI

,8023 457·1551

"orman ISkJol WIltS.

ecunvt Olm:ar

Ncw K&allMft - N.L

1.~aa1~

8S1 DmStrMf ~rv N.K.031ln

!603\ 613-6680 ,m C£m:II.

r..ucu::..... Ol-=r
,"0,; ~~{~~~~J;'~~~f?+~~\~~1~t?(~~tl~~~~~~~:t?;~~f~;~~1;;;\i~~~~~~t~?F~~fW'ff;~~'l')' '~":<'f;,:~;;r~t~~r~;~P?~~~~~~~': 0-"0; ~- '" ";~~( -

t'~

')0-

MJOOl119

-ATTACHMENT 5

CAMPAIGN AMERICA - REPORTED

RECEIPTS AND DISBURSEMENTS BY YEAR

CASH AS

REPORTED REPORTED CALCULATED FROM

RECEIPTS DISBURSEMENTS COLUPlNS 1 AND 2

1978 $ 205,096.00 $ 197,395.00 $ 7,701.00

1979 33,905.00 41,522.00 84.00

1980 13,500.00 13,188.00 396.00

0- 1981 -0- 173.00 223.00

1982 285,356.00 251,934.00 33,645.00

ex 1983 846,698.00 269,371.00 610,972.00

'Y 1984 426,219.00 585,767.00 451,424.00

'0

1985 417,971.00 390,423.00 478,972.00

8

1986 2,929,341.00 2,859,148.00 549,165.00

....... 1987 2,417,616.00 2,916,978.00~1 49,803.00

r· 1988 1,363,777.00 1,108,898.00 304,682.00

1'0 TOTAL $8,939,479.00 $8,634,797.00

'"

Of this amount, $2,088,536.00 was expended between January 1,

1987 and April 30, 1987.
;'.T'3IC11!-iE1ll' G

~~~ lof !"

KEMORANDUH FOR DOH DEVINE

FROM: BILL LACY

DATE: AUGUST 8, 1986

SUBJ: IOw"A' a 6 PROJECT

As you know, Iowa is a crucial s~a~e for the GOP.

1. Sena~or Grassley looka o.k., but Governor Branstad is in a

fight tor his li~e.

2. Because of tho agricultural sltuation, Io~a has national

signi!icance-- heavy GOP losses ~~ere woul~ ~ode ill for

realign:ant and would be a dec~sive se~ack for the

?resldent's farm policy.

3. Once a solid GOP state, Iowa is turninq Democratic. Stoppinq the slide there in '86 could give us some ideas to apply to

slippinq GOP midweatarn fortunes. To address ~~ese concern.,

! would like to propose this concept tor an Iowa '86 campaiqn assistance proqram:

E\1rposei To assist GOVernor Branstad and other state and

local candidates in Iowa by conduct1nq a GO TV program featurinq the Majority Leader.

Backgroynd: Midterm turnout is traditionally lower

especially whan the party in power faces serious econo~ic

problams. In 1982, econo~ic circumstances led to larqe

numbers ot Republicans voicing ~~eir protest by not votinq. Similar circucs~c8. exist in Iowa in 1986 because of the

far: economy; 60 it is critical to reach out to low-intensity

voter••

outline: Republican voters will be called, asked their

position on state and local elections, who.e endorsement would

:Aka tha.m more likely to support the GOP candidates, queried

about their attitude on fanD policyI and tinallyI tested on

their level ot participation.
',' ~~~~~¥!;::~f~~~~

..~Eietimant s %

~a~c 2 of 2

Lov part1e1pa~ion Republicans di••a~i.ti.d vi~~ ~arm policia. ~no .uppo~ ~~a .ta~a and local GOP tieke~ vill then ba

called. A me••aqe trom Senator Oole urqinq the. ~o ~urn out

will be delivered. The target qroup vill also reeeiva a

letter of endor.emen~.

In short, weill use our resources in a carefully tarqeted way

to elec~ :ore Republicans in Iowa.

Let =e knew ~hat you ~~ink.

MEMORAND~~ FOR OON OEVlh~

PAGE TWO

t;. '~'i'~~ .i..~~~~~~t~j.;;~:~ijfit1t0!f.0iff!.T;;1v~~·'F~~(;':~:. "

~~~>.;\~"'" ,

-T

~"

o
f\.ttud"lmmt 7

Page 1 of 2

PROPOSAL FOR

MR. TOM SYHHORST

August 19. 1986

3.." ccst eHectively provide I);gh Quality and accurate survey

data that can be utilized througnout the project at the client's discretion.

2. To record each person'S ~ttitude to the above mentioned

Questions and store this information for future telemarketing based on

their rep~"se. Those sho""ng a favorable response to a particular

individua. s endorse~ent "'ill be recontactec w1thin the final few weeks

before the election.

Object lVes

1. To contact approximately 228,000 Iowans and det!rm1ne whether

the endorsement of eaCh of seven promlnent 'ndividuals IS rrore or less

likely to influence their supporting the Governor in the November election.

'.~

4. A manual system of fi 1ing '1(111 be used as a back-up to the

client'S automated system.

S. The project wi 11 reQuire a tot a1 of n1 ne week s to cOITll' 1ete.

the final two weeks before the election will be utilized to contact the

people who responded favorably to a particular endorsement.

6. Lewis & Associates will have input and control over-4cdeSign~ .. j

layout of the telemarketing cards, as well as other variables affecting

efficiency and performance.

Assumotions

The following assumptions are based on several years of experience in similar types of projects. Each figure is conservative and

realistic: Lewis &Associates expects to exceed these figures through

improvement of performance variables can control. These assumptions

will provide an excellent measure of the maximum lime and cost involved

to complete this project.

1. Approximately 15 contacts will be completed per telemarketing

hour.

2. Approximately 17.51 of the ppt:lT)le surveyed will need to be

called back shortly before the !1ectior , cause they responded favorably

to I particular endorsement.

3. The survey data w111 be entered into the master file by the

client to enable those peoole who responded aparticular way to be

sorted~ counted and later re-printed on cards for follow-uo calls.

3/
The following estimates of the project's cost are based on the assu~tions mentioned before. This estlmate reflects the rnaXlmUlft eost

per contact the client can incur on this proJect. If lewls L Associates

completes the project in less than the estimated hours, the client will

only be charged for actual telemarketing hours rather than the estimated.

.'

Atta~t iI'a~ 2 of 2

Cost per telemarketing hour

Contacts per telemarketing hour

Cost per contlct

Original contacts

Follow-up contacts

Total estimatea contacts reQuireo

Contacts per hour Tel~~arketing hours

Cost per tel~~arketing hour

iotal estlmated cost

Original contacts

Favorabe response rate

Estimated follew-up contact reQuired

228,000

x 17.51

39,900

228.000

+39,900

257,900

+ is

17 •860

S 27.50

+ 15

S 1.83

Estimated Costs

.~> ·~~~~1~~~(:i~~~{~f0n~~:~?~~'~·'··~· . - "

Schedule

August 25-29

September 1

September 8

September IS

September 22

September 29

October 6

October 13

October 20

October 27

November 3

NovMblr 4

Hake final preparations for project

(Week '1) Begin project

(Week 'Z)

(Week '3) (Week '4)

(Week '5)

(Week 16)

(Week '1) (Week '8) Begln calling favorable resoonses

(Week 19) Complete callin9 favorable responses

(Week '10) Project completed

Election Oay

The calling hours of the project wUl be 9:00 I.Il. to 9:00 p.m. Monday

through Sunday.

- 2 -
~~CA, A POL:~!CAL ACTION CCMMIT:!!. CAN YOU H!AR ME ALRIGHT?

AtUldv:'ent £

Page 1 of 2

AND I AM CALLING FROM CAMPAIGN

YES

NO

tJNDEC:~EO

YES

NO

UNDEC::!lED

I '£OUR LOCAL RE?t:BLICAN ------- CANDIDATE FOR ~~ LEGISLATt\RE?

TERRY BRANSTAD, AND HIS STAT!-WICE ~:CKET?

1. WILL yOU BE Si.:PPORTING THE R:£PUBLIOI.N CANDIDA'!E FOR GOVERNOR,

HELLO. MY NAME :S

3. OF TH]: FOLLOWING LIST OF u:ADERS, WHO'S DlDORSEMENT WOULD

MAKE YOU MORE LIKELY TO VOTE FOR A CANDIDATE ON NOVEMBER 4TH?

o

HOWARD B.Ala:R

GEORGE BOSH

BOB OOLE

nSSE HEutS

JACX nHP

PAUL LAXALT

BOB PACKWOOD

PAT ROBERTSON
,.-

-.

_J

Attachr.ent C ~age 2 of 2

IOWA '86 PROGRAM 10 SCRIPT

PAGE TWO

• WHICH OF TH£SE LEADER' 5 ENDORSEMENT WOULD HAVE '::iE NEXT MOST

IMPACT ON YOl.JR DECISION TO VOTE NOVEMBER 4TH?

HOWARD BAKER

GEORGE BUSH

BOB DOLE:

JESSE HEUlS

JACK KEMP

PAUL LAXALT

BOB PACKWOOD

PAT ROBERTSON

eN AN IHPORT~'IT }ol..A~ AFFECTING IOWA, DO YOU :"PPROVE OR

DISAPPROVE OF THE JOB THE REAGAN ADMINISTRATION IS DOING ON

FARM POLICY?

APPROVE

DISAPPROVE

NO OPDaON

IS TP.AT STRONGLY OR SOMEWHAT (APPROVE) (DISAPPROVE)?

6. FINALLY, I WOULD ~KE '1'0 ASK YOO WinCH OF 'ni!SE: ACTIVITIES

YOU PARTICIPATE IN:

GENI:R.AL E:LICTIONS

REPUBLICAN PRIlWUES

PRESIDENTIAL CAOCUSES

YOUR COONTY'S UPOBLICAN CONVENTION

CONTRIBO'l'IONS TO REPUBLICAN CANDIDATES

VOIJ::iNTE'1:R FOR CANDIDATES

'!'HANK yOU FOR YOUR TIME.
_ .., ,.. - .... .. -.

:~;~~{~f.~~~~~~t;:f~-<-\\" " .

':~1

OotOber ~2, 1988

,-

Dear Fellow Republicans

I am vritin; you today on a ~a~~er o~ urqen~ i:po~ano. to

Iova.

Governor Terry ~ran.t&d needa your vote on Tul.day,

NOVe:bar 4.

It i' eeplcial~y i:portant ~at you and your tamily vota

this election day. Many cbooae not to vote in ~idtar: elections.

Thia muat not hap~8n th1. critical year.

Thi. :ake. your votaw-and ~a vota ot avary :Imbar ot your !a:ily--vlry critical.

!At ~e explain why. Goveme":' '!ar:y Bra.nsUd hal bean a

t=I:lndoua ally 0: :ine in the ~w~tle to :aXe America" f&r:.rs

cc:pltitivi aqain. HQII prcvidinq laadarabip to aolv. the

problea ot rural and l:a11 twn ~iC&.

Aa the Sanl.tor of a :ic!weatern aqr1cu1tural Itata, I knev

firlthand ot tha atruqql.. f~ly far-~ have faced in the 1aat

!ew year.. Not all politiciLna have unc!eratoOd.

But Tlrry !rar..auc! ha.. He'. led the charqa to l.:prove your aqricultura1 aituation L~ Iowa and in tha nation aa wall. Aa

Senata Majority Leader, I have con.ultad with hi: on !!-~ ~attara

on :ore than ona oeca_ion.

Tha Governor i. an etfective voica tor Iowa hare in Walhin~on, on aqr1cultura &nd other i.aua.. And t~.at la i:po~&nt.

But I've alao watched hia atticiant :anaqamant ot your .tata

qovern:ant--Iavinq you, the taxpayar, million. ot dollar.. An4

ha'i vorkc4 to'br1r.q mora joe. to Iava.

Uhd&r tha GQV.rnor'. leadership, I ••a a briqht tuture ah.ad

tor Iova. Plaa.e ma~a aura va don't 101. that opportunity. B.

lura to vote.

But donlt atop thare. Ba lura to vota tor tha GOP tic)(r:: (list atatavide candidat••]. And ~Q~lt ~orqct thl Rapublicaft candi~tca tor the stat. Sanat. an(1 HOUJICI. 'X'hay III 1:a a cruoial

part ot tha Govarnor'. ettort. to qat Iowa back on the riqht

tracJc.

"-
;'

.-

;-"tta~t II

!I~ge 2 of 2

!el1~e .., .a Kajcr1~y Leader of ~. Onita4 Stat•• 8ana~e,

I racce;t\iz. t.he n.N tor a ~ua. M.aka .u:e the Gov.rnor can

ccnt1nue hi••ftoru with ••t.ronq t .... b.ckinq him up.

Pl•••• vote tor ~erry Br.~~a4 on Nov.mber 4, an4 tor hi.

tea. It'. .0 very 111lpo~ant for :"v&.

8incerely,

P.s. Your vote can :a.ke the dif:erenca. !e aure to qat ou~

an4 vote tor Gov.rnor Erar..ta4 and hi. t~ck.t o~ .lection 4ay .
ATl'AatHEHI' ••

Page 1 of

DOLE FOR PRESIDmr

Review of Campaign ABerica Records - Telemarketing

., HLFOC

_.:;.._---------....._---

) 3 , / 0 I 6 4 ? B

Levis & Associates . Tel~4rketing Inc. 2945 10/14/86 $ 19,305.00 -0-

3265 11/03/86 42,120.00 -0-

3476 12102186 9,195.90 -Q3310 11/06/86 238.75 -0- - Total $ 70,859.65 -oEd Nichols Associates 3534 12109/86 2,635.73 2,635.73

3533 12/09/86 2,656.14 2,656.14

3797 01121187 2,718.80 2,718.80

3949 02113/87 238.75 238.75

4069 02126/87 147.00 147.00

4099 03/02187 593.85 593.85

Total $8,990.27 ~99O.27

Follow-Up Letter

Tom Synhorst (Postage) 3132 10128/86 5,950.00 -QU.S. Postmaster Des Moines 3086 10123/86 1,300.00 -0-

MacDonald Letter Service 3123 10127/86 2,683.52 -QABC Mail Service 3122 10127/86 1,015.00 -QABC Mail Service 4146 03/11/86 143.46 -0-

Follow-Up Letter Total $11,091.98 -QTelemarketing Program Total S90.941L90 S8.990.27

Payee Check • Check Date

lova

Allocable

AIIount

Commission Det'd

lava Allocable

MIount

;;,

:1,i

"1

'~~:2i -'~~

Ij'h

M~::£~~

:~11 ~~4~J

'~~~f

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Page 1 of 10

SENATOR BOB DOLE

ADDRESS TO THE IOWA BANKERS ASSOCIATION

FEBRUARY 7, 1987

I APPRECIATE THE OPPORTUNITY TO ADDRESS THE ANNUAL LUNCHEON

OF THE IOWA BANKERS ASSOCIATION.~IOUX CITY IS ONE OF MY

FAVORITE PLACES. IN FACT, LATELY, ANY PLACE IN OR NEAR IOWA IS

ONE OF MY FAVORITE PLACE0 ::>p •• ::....J D ••r'.Cr>.ETS ADDE:

AS MANY OF YOU KNOW, I HAVE SPOKEN TO MANY IOWANS DURING THE

PAST FEW MONTHS. IT'S VERY EVIDENT THAT IOWANS HAVE THE SAME

INTERESTS AND CONCERNS AS PEOPLE IN MY HOME STATE OF KANSAS --

THEY WANT TO KNOW HOW TO SURVIVE IN SOME TOUGH ECONOMIC TIMES.

THEY WANT A PROSPEROUS NATIONAL ECONOMY, BUT THEY'RE ALSO

CONCERNED ABOUT THE ECONOMIC WELL-BEING OF RURAL AMERICA.

SO I WILL BEGIN BY CONGRATULATING EACH OF YOU, BECAUSE AS THE

COMMERCIAL LENDERS TO THE FARMERS AND SMALL-TOWN BUSINESSMEN AND

WOMEN OF IOWA, YOU PLAY A CENTRAL ROLE IN KEEPING THE WHEELS OF

IOWA'S ECONOMY TURNING. IT'S NOT AN EASY JOB, BUT IT IS A

PARTNERSHIP THAT HAS ENDURED FOR MANY, MANY YEARS THROUGH THE BAD

TIMES AS WELL AS THE GOOD.

..

-1-

.. • co

. .. ... ... : .: ."
A GRASS ROOTS APPROACH

I AM FIRMLY CONVINCED THAT IF WE ARE GOING TO SOLVE THE

PROBLEMS FACING RURAL IOWA, RURAL NEBRASKA, RURAL KANSAS OR

ANYWHERE ELSE IN RURAL AMERICA, THE ANSWERS ARE GOING TO HAVE TO

COME FROM THE GRASS ROOTS AND NOT FROM POLITICIANS IN WASHINGTON

D.C.

IN NOVEMBER, GOVERNOR BRANSTAD AND I ORGANTZED THE

"REPUBLICAN TASK FORCE ON FARM AND RURAL AMERICA" WITH THE FIRST

I

l

....W"!'

. .:..

MEETING IN DES HOINES, IOWA, COMPOSED OF MIDWEST GOVERNORS,

SENATORS AND CONGRESSMEN. WITH SEVERAL NEWLY-ELECTED MIDWESTERN

GOVERNORS, WE F~t- THAT REPUBLICANS HAD AN OPPORTONITY AND A

RESPONSIBILITY TO or~ELOP A CLOSER STATE AND NATIONAL

RELATIONSHIP ON FOUR ISSOES IMPORTANT TO RURAL CITIZENS,

ESPECIALLY IN THE MIDWEST: FARM POLICY, RORAL DEVELOPMENT, FARM

CREDIT AND AGRICULTORAL TRADE AND EXPORTS.

IN ADDITION TO GOVERNOR BRANSTAO, SEVERAL MEMBERS OF THE IOWA

DELEGATION WERE PRESENT: RSPRESENTATIVES JAMES LEACH, JIM

LIGHT!'OOT, TOM '!'AO~! AND !'JlE1) GRANDY.

RURAL DEVELOPMENT

AFTER HOLDING MEETINGS IN DES MOINES AND CHICAGO, IT WAS TH!

TASK FORCE'S CONSENSO~ THAT, WHILE THE FARM PROGRAM IS

UNDOUBTEDLY A KEY FACTOR IN THE OVERALL RURAL ECONOMY, IT WILL

-2-

-"--. ....
I

t

ATtAClCC::r 13

Page 3 of 10

TA~E HORE THAW CHANGES IN BASIC FARM LEGISLATION TO TURN THINGS

AROUND. WE HAVE EXPERIENCED THE EMOTIONAL ROLLER-COASTER OF

HOPES AND DISAPPOINTMENTS WHEN WASHINGTON CONSIDERS NEW FARK

BILLS. WHILE SOME IMPROVEMENTS ARE MADE, THEY ARE OFTEN

TOOBROAD-BASED TO ADDRESS AND RESOLVE LOCAL PROBLEMS. MANY RURAL

COMMUNITIES AND BUSINESSES ARE IN CRITICAL DANGER OF COLLAPSE

NOW, AND WE NEED TO FOCUS ON WHAT CAN BE DONE THROUGH RURAL

DEVELOPMENT PROGRAMS TO SUPPLEMENT WHAT WE DO WITH FARM PROGRAMS.

IN PARTICULAR, WE NEED TO FINO WAYS TO DIVERSIFY THE

ECONOMIES OF FARM COMMUNITIES AND PROVIDE EDUCATION AND

VOCATIONAL TRAINING OPPORTUNITIES FOR FARMERS AND OTHER RURAL

CITIZENS. A NUMBER OF FARM STATES HAVE ALREADY DONE IMPORTANT

WORK IN THESE AREAS. WE NEED TO BEGIN TO COORDINATE EFFORTS AT

THE FEDERAL LEVEL WITH THE STATES AND PRIVATE ENTERPRISE AND MAKE

SURE OOR BASIC COMMODITY PROGRAMS DOVETAIL WITH THESE BROADER

INITIATIVES.

WE HAVE ALREADY STARTED IN THE SENATE ON SOME OF THESE

ISSUES. DORING CONSIDERATION OF THE FEDERAL HIGHWAY BILL ON

FEBRUARY 4, WE ADOPTED AN AMENDMENT BY SENATOR PRESSLER STATING

THE FEDERAL GOVERNMENT MUST DO MORE TO ADDRESS THE SERIOUS

PROBLEM OF DETERIORATING BUS SERVICE FOR RURAL AMERICA. WE MUST

KEEP BASIC SERVICES IN RORAL AMERICA TO ATTRACT NEW BUSINESSES

AND PROVIDE NEW JOBS AND GREATER ECONOMIC ACTIVITY.

-3- Ii

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RE-TRAINING FOR DISPLACED RURAL AMERICANS

I AM GOING TO MA~E A RECOMMENDATION REGARDING JOB RETRAINING

PROVISIONS IN ANY NEW TRADE LEGISLATION CONSIDERED BY THE lOOTH

CONGRESS. THE ADMINISTRATION'S TRADE BILL CONTAINS NEARLY Sl

BILLION IN RE-TRAINING ASSISTANCE FOR WOR~ERS WHO HAVE LOST THEIR

JOBS DOE TO INCREASED IMPORTS. CURRENTLY, 2S PERCENT OF ALL

AMERICANS LIVE IN RURAL CC~~UNITIES -- 28MMUNITIES THAT FACE

DIFFICOLT ECONOMIC TIMES DUE TO A NUMBER OF FACTORS, INCLUDING A

SIGNIFICANT DECLINE IN AGRICULTURAL EXPORTS AND A RISE IN

AGRICULTURAL IMPORTS.

I MAY OFFER AN AMENDMENT DURING THIS YEAR'S TRADE DEBATE

EARMAR~ING NOT LESS THAN 25 PERCENT OP ANY JOB RETRAINING FUNDS

FOR WORKERS IN RURAL COMMUNITIES ALL THE WAY FROM FARMERS TO

.-

HARDWARE STORE WORKERS THAT HAVE BEEN AFFECTED BY THE

AGRICULTURAL ECONOMY. ITS MY VIEW THAT IF 2S PERCENT OF ALL

AMERICANS LIVE IN RURAL AREAS THEY OUGHT TO GET AT LEAST 2S

PERCENT OF THE JOB RETRAINING ASSISTANCE.

FARM PROGRAMS

ANOTHER CONCERN OUR REPUBLICAN TASK FORCE ADDRESSED IS FARM

CREDIT. PERSONALLY, I THINK MOST BANKERS WOOLD SAY THEIR TWO

GREATEST FEARS WOULD BE (1) A SHARP REDU,'~iON IN COMMODITY

PROGRAM BENEPITS AND (2) THE COLLAPSE or THE FARK CREDIT SYSTEK.

THESE EVENTS COOLD RESULT IN LOWER FARMLAND VALUES AND EXACERBATE

THE fARM DEB~ PROBLBM• ..

.,

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I·

THE ADMINISTRATION HAS NOTIFIED CONGRESS THAT IT WANTS TO

CHANGE TH! 1985 FARM BILL. ONE PART OF THEIR LEGISLATIVE PAC~AGE

WOULD CUT TARGET PRICES BY TEN PERCENT PER YEAR FOR THREE YEARS.

THIS WOULD REDUCE SPENDING ON FARM PROGRAMS BY ABOUT S20 BILLION

DURING FISCAL YEARS 1988-1992.

MY VIEW IS THAT OUR EFFORTS TO ADDRESS THE FEDERAL BUDGET

DEFICITS MAY WELL REQUIRE SOME REDUCTIONS IN SPENDING FOR

AGRICULTURAL PROG~~S. WE ARE ALL FAMILIAR WITH THE FACT THAT

FARM PROGRAM COSTS HAVE RISEN FROM AN ASNUAL AVERAGE OF S3-$4

BILLION IN THE LATE 1970'S TO S25.8 BIL:ION LAST YEAR AND AN

ESTIMATED $25.2 BILLION IN FY-1987.

CONGRESS AND THE ADMINISTRATION SHOULD KEEP IN MIND, HOWEVER,

THAT, TA~ING INFLATION INTO ACCOUNT, THE FARM VALUE OF FOOD

ACTUALLY FELL DURISG THE PAST DECADE, AND THAT AMERICANS NOW USE

ABOUT ONE-THIRD LESS OF THEIR DISPOSABLE INCOME FOR FOOD

PURCHASES - SO FARMERS MAY BE RECEIVING MORE OF THEIR INCOME FROM

THE GOVERNMENT, BOT THE REAL BENEFICIARIES ARE PEOPLE WHO EAT.

SO, I DON'T BELIEVE CONGRESS WILL APPROVE THE

ADMINISTRATION'S TARGET PRICE CUTS -- OR ANY MAJOR FARM PROGRAM

CHANGES UNLESS AND UNTIL WE SEE MEANINGFUL AND EQUITABLE ACTION

ON BODGET DEFICITS.

-5-

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FARM CREDIT

WE ALSO WANT TO ENSURE THAT AN ADEQUATE SUPPLY or CREDIT AT

REASONABLE RATES IS AVAILABLE TO FARMERS AND RURAL ES7ERPRISES.

THIS MEANS MAINTAINING THE VIABILITY OF THE COOPERAT:~E FARM

CREDIT SYSTEM. BOT IT ALSO MEANS THAT OUR EFFORTS TO ASSIST

STRUGGLING FARMERS AND THE FARM CREDIT SYSTEM MUST Ncr DRIVE

COMMERCIAL LENDERS OUT OF THE FARM LOAN BUSINESS.

CHAPTER 12

I HAVE HEARD FROM A NUMBER OF FARM BANKERS IN MY STATE WHO

HAVE CONCERNS ABOUT THE NEW CHAPTER 12 LEGISLATION, SPONSORED BY

IOWA'S SENIOR SENATOR, CHUC~ GRASSLEY. THEY PARTICULARLY

QUESTION THE RADEQUATE PROTECTION- PROVISIONS, WHICH ALLOW A

DEBTOR TO STAY IN BUSINESS BY WRITING DOWN FARMLAND :£BT TO ITS

CURRENT VALUE.

TO DATE THERE HAS BEEN NO RUSH TO THE BANKRUPTCY COURTS SINCE

ENACTMENT OF CHAPTER 12. AS OF JANUARY 22, THERE WERE ONLY 357

FILINGS IN THE 8TH CIRCUIT, WHICH INCLUDES IOWA AND SIX OTHER KEY

FARM STATES. THE LIMITED USE OF THE NEW CHAPTER 12 APPEARS TO BE

THE NEW TAX REFORM BILL, WHICH ENCOURAGES FARMERS WITH SERIOUS

FINANCIAL PROBLEMS TO WRITE DOWN LOSSES INSTEAD OF FILING FOR

BAN~RUPTCt.

-6-

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Pa3e 7 ot 10 '1

I SUGGEST WE SHOULD GIVE SENATOR GRASSLEY'S LEGISLATION A

FAIR CHANCE TO WORK. CONGRESS WILL BE WATCHING CLOSELY TO SEE

WHAT THE REPERCUSSIONS ON FARM LENDING WILL BE. IF SIGNIFICANT

PROBLEMS ARISE AND CREDIT THREATENS TO DRY UP, WE ARE PREPARED TO

MAKE THE NECESSARY CORRECTIONS.

SECONDARY MARKET

I UNDERSTAND A TASK FORCE HAS BEEN MEETING ON THE SO-CALLED

·SECONDARY MARKET- CONCEPT COMPOSED OF THE FARM CREDIT SYSTEM,

THB INDEPENDENT BANKERS, THE AMERICAN BANKERS AND INSURANCE

COMPANY REPRESENTATIVES. SENATOR GRASSLEY HAS INTRODUCED

LEGISLATION TO CREATE A SECONDARY MARKET AS A HEANS OF INCREASING

THI AVAILABILITY OF FUNDS FOR FARK LENDING.

THE IDEA OF PACKAGING LONG-TERM FARM LOANS AND MARKETING THEM

THROUGH AN EN~ITY THAT HAS AGENCY STATUS AND ACCESS TO THE BOND

'. EITHER THROUGH THE FARK CREDIT SYSTEM OR THROUGH A

-FARMER MAC- OR AN -AGGIE MAE- -- IS AN INTRIQUING IDEA THAT

DESBRVES CLOSE EXAMINATION, ESPECIALLY IF IT COULD BRING MORE

CAPI~AL TO RURAL COMMUNITIES AND COULD OFFER FARMERS LOWER

INTEREST RATES ON REAL ESTATE LOANS.

I THIN~ THERE SHOULD BE A FULL DISCUSSION OF THIS CONCEPT AND

HOW IT MAY BE PART OF OUR OVERALL APPROACll 1'1) THE FARM CREDIT

SITUATION THIS YEAR. I ENCOURAGE COMMERCIAL LENDERS TO WOR~ WITH

THE FARM CREDIT SYSTEM AND OTHERS AND CONTINUE TO EXPLORE WHAT

MAt PROVE TO BI A VERt OSBFOL LENDING TOOL.

...... -'~. ' .. .. ..•,. .._....." .. ..
PROPOSED COMMITTEE HEARINGS

fJtf:!fj-:¥:~~~~~~~:~\}'.~"""'-'·< ,':,",,"Y'i- "'1'7<"';:';'n- .,-:~~,){{~.,-<.", .1"'" w" . ',-" ._- ...,"....,\" , .. ,--,- ,

I,

RECENTLY THERE HAVE BEEH QUITE A FEW PRESS REPORTS CONCERNING

THE FINANCIAL CONDITION OF THE FARM CREDIT SYSTEM. CONGRESS HAS.

COME TO THE AID OF THE SYSTEM TWICE WITHIN THE LAST 18 MONTHS,

PASSING LEGISLATION TO PROVIDE BASIC GUIDELINES FOR REFORMS AND

GIVING THE SYSTEM AND ITS BORROWERS MORE FLEXIBILITY IN DEALING

WITH THEIR PROBLEMS. THERE ARE MANY WHO SAY THE SYSTEM WILL NEED

SOME FEDERAL FINANCIAL ASSISTANCE SOMETIME THIS YEAR UNDER THE

1985 CREDIT ACT. THERE ARE MANY WHO FEEL THE SYSTEM COULD BE

MORE CANDID ABOUT THE EXTENT OF ITS DIFFICULTIES AND THE

TIMELINESS OF INITIATING A NEW DEBATE ON FURTHER REFORMS AND

'0

j

.... - .

"-

J'

RESTRUCTURING.

I HAVE WRITTEN SENATOR LEAHY AND SENATOR LUGAR ASKING THE

SENATE AGRICULTURE COMMITTEE TO CONDOCT A FOLL DAY OF HEARINGS TO

INVESTIGATE THE FINANCIAL STATUS OF THE FARM CREDIT SYSTEM AS

WELL AS OTHER AGRICULTORAL LENDERS. SOCH A HEARING WOULD PROVIDE

AN OPPORTONITY TO RECEIVE RECOMMENDATIONS FROM THE FARM CREDIT

ADMINISTRATION, THE FARM CREDIT SYSTEM AND FROM COMMERCIAL

AGRICULTURAL LENDERS REGARDING MEASORES THAT MAY BE NECESSARY TO

ENSURE OUR FARMERS HAVE ACCESS TO AN ADEQOATE SUPPLY OF CREDIT AT

REASONABLE RATES.

I DON'T WANT TO BE CAUGHT WITH EVERYONE COMING TO CONGRESS

AND SAYING THAT TH! SYSTEM NEEDS ASSISTANCE WITHIN A WEEK. THIS

IS AN ISSOE THAT DOES NOT NEED TO SURPRISE ANY or OS, SO WHY NOT

START NOW TO THINK ABOOT THE VIRTOES AND DRAWBACKS OF ANY

ALTERNATIVES TO HELP THE SYSTEM THROUGH TOUGH TIMES. CONGRESS IS

.,. .- . ..-' -e- '. '..
-\

2'

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'Pase 9'oP-10 -)

GETTING TIRED OF PASSING LEGISLATION THAT EVERYONE SAYS WILL

wSAVE THE FARM CREDIT SYSTEMw -- ONLY TO FIND OUT THREE MONTHS

LATER THAT THE PROBLEM STILL EXISTS.

CONCLUSION

NOT LONG AGO, I SPOKE TO YOUR STATE SHERIFFS' ASSOCIATION

ABOOT SOME OF THE ISSUES I~PORTANT TO THEIR MEMBERS AND TO IOWA.

AGRICULTURE WAS· AT THE TOP OF THE LIST.

THERE PROBABLY WASN'T A SHERIFF IN THE ROOM WHO HAD NOT FELT

THE EFfECTS Of THE DEPRESSED FARM ECONOMY. AND THE EFFECTS ARE

VERY REAL, FOR IT IS THE SHERIFF OR A DEPUTY SHERIFF ~~O TA~ES

THAT LONG DRIVE UP A FARMER'S LANE TO DELIVER A FORECLOSURE OR

EVICTION NOTICE.

LI~E THOSE SHERIFFS, YOU ALSO KNOW THE PROBLEMS OUR RURAL

ECONOMY FACES. AND I DOUBT THERE IS A PERSON IN THIS ROOM WHO

HASN'T FELT THE PAIN OF TURNING DOWN A FARMER - PERHAPS A

NEIGHBOR OR A FRIEND YOU'VE KNOWN FOR YEARS - WHO WAS LOOKING FOR

A LITTLE BREATHING ROOM, A SECOND CHANCE, A NEW HOPE FOR THE

FUTURE.

-9-

:c.et~lU"'.~ . arM W'#,eJ ."'~_., -(~-,:- . ..,.,. -

,

.

.._.4
Yl~~'10.-;;1

BUT WHEN FARMERS ARE IN TROUBLE, YOUR BUSINESS - THE BOSINESS

OF BANKING - IS ALSO IN TROUBLE. 1986 SAW RECORD LOSSES FOR IOWA

BANKS, ATTRIBUTABLE IN LARGE PART TO THE STATE'S DEPENDENCY ON AN

AGRICULTURE-BASED ECONOMY. BUT THERE MAY BE SOME GOOD NEWS

AROUND THE CORNER.

I KNOW THAT YOUR STATE BANKING COMMISSIONER IS PREDICTING

fEWER BANK CLOSURES IN IOWA THIS YEAR. AND IN WASHINGTON, WE'RE

LOOKING FOR BETTER WAYS TO HELP BOTH THE FARMER AND THE BANKER.

NOW SOME WOULD SAY THAT WE IN WASHINGTON MUST PROVIDE ALL THE

SOLUTIONS. AND WE OFTEN TRt. BUT, AS I'VE SAID MANY TIMES

BEPORE, WE IN CONGRESS CANNOT GUARANTEE THAT EVERYONE IN OOR

SOCIETY SUCCEEDS. ALL WE CAN DO IS STRIVE TO PROVIDE THE RIGHT

KIND OF ENVIRONMENT WHERE PEOPLE HAVE THE OPPORTUNITY TO SUCCEED

- BOT WE CANNOT GUARANTEE SUCCESS.

BUT IF WE WORK TOGETHER, PERHAPS WE CAN HAKE 1987 A BEGIN~lNG

FOR MORE SUCCESSFUL TIMES IN AGRICULTURE. I LOOK FORWARD TO

WORKING WITH YOO.

-10-

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Page 1 of 4

BEVERLY HUBBLE TAUKE

400 "0" Street S.W. -203

WutUnKtOn D.C. 2002~

(202) 484-713~

o

f"ROM: 8H'T

• CAT!!:RP:;'~_~~_~~.: As confirillfl!<i V\ February 17 announcemO!ne, .i.~q

·')lIt 1,3:)0 J ,h" .i~seite plant's tr"ck t'''!cot'.\ "'i 1lI0:ie ?rf')1'lctl"~ r;AT pl...rtt 1.n [J!;llo:

i.n deus'! ,jl.1~ 00 r..:l;;.c; .1~ 1='1)~J';tt,;'l ·v.ltlCe!':.. '>\.\'1t ,.,\tl p~...se oue ciunnq late

1987, , 988.

(TIE TO I)OL£ 'rRAOE AGENO.\ m p~(n~r I~h~.\ "'~l) lJ. S. JOSS... ",s ?r';)ven by Dole

battl~1 "CJ"lnst l.1nfur Canad1.an perlt i"l~ru and unfai.r etlanol imports (l'Iloltly

Brazll.>, Bob Dole 1.S cO~1.tt~d to -.nforce U.S. trade laws, and de~and free but

TRADE.

ALSO USEPUL HERE: Other Dole initiatives re: stronq ~ollar, aqqressive purluit

of international markets, erOSlon of federal rp.d tape/barri-.rs to .tronq

trade. )

• MISSISSIPPI RIVER PROJBCT: Officials in ar'!a are pushinq number of proposed

proJ-'cts (but not l.n_~t ,,~~~~~~~) includinq:

• Possible use of ol.d Case buildinq outsid'! navftnport as " museUM or

tourist cent.er, ~n~o!nei.nq t'iv'!r "t''!a appeal to to.ni..ts.

• 'h. -!; ta te cOll\.'lI1s"l')f\ .lrqi.ng con!l tr~ction of new bridqe--old one vi-.wed ~s

s~v~rely lnad~qu~e~ line h~tw'!f!n Iow.-Illi~o~s.

• ~iv~r s~en a~ cent~rpiece of lonq-ranq~ (20-year) d~velopment plan

prolloted by local ~~ill to OJl'li t .. Ql14d Clti"!" ",ore al lIinqlft t':nl!Uluni ty: ''''''11<1

inclucie re~v.l of eommercial properties alonq riv4r.

• These proposals have not really ~oved past promotion staqe •

. :'1 ••..;.... ,.. _ .... ~':""'~~~"..; IL~. ~:-.~.~-~ ....fO'.~...... ? --..,.0: ~_~ _ • ,-..... -== ... _.t:: ~~- ~-. ••
IOWA T~~~ _~'!!!

SUPPORT POll IOWA PARM:!:RS -----------

" ~. -.:t ~~~(... ;.,:... ·.::-...':'i-;-)J:.:",q.::,~1~~~·;·.rr·::!:I'~·:·I}"-'<

A'ITA(2'\t~'T'~ It.·,· .•

Page of 4

P~Ut 2

• ~R CAMAD~ PORK IMPORrS: Dole/Crassley tnltlative led to PUNITIVE

OUTIES for C.,nadlans dumplng pt')t'lt unf4irly t')n fJ.S., \o'l.t~ ,,!'lOrIllOI1S staltes for

Iova.

• aKYAIR BT8AMOL I~: Dole battles v~. unfair ~t~nol i~ports, ~everely

j eo pard tU.ng -corngrowers -, corn-based ethanol intiustry, at qre4t C'l-t< to low".

;;uch b"ttl~" l\"v,,! .tY!'ted "!th-sn"t io~~,.t.. , "'~V\'I'J :J.":\. o\'J -1,,:.,"0,ly ..bout S900

~tllion tn la~85 - ~"rly 'S5 410ne, "ccortitng tv ~t~d~ol .ndustry.

• BILL 'l'O _~'!~~ _~~~~~_~~-r:~~. Dole-backed, would mean 72511 - 750 IIlUion

"!"rly tioll"rs to Iow~ f~r~ftr~.

• SOIL TtL~ C~, I~A STA~ UHI~I~ - Dole, supporting C.Crassley,

englneered restoritl.on-;f-S,-,-:1 -M:iLiicii-iO-ISU for research crucial in hatne

for U.s. agriculture to co=pete ~ii;;t1vely in global oarkets. Study of nev

grovth option., nev uses of U.S. food and fiber•••• to sustain the 7 out of '0

Iova job. nov dependent on agriculture.

• '985 BILL: Suggest keeping this tight with f~w ~ey points:

(,) No bill ~uld please ,,11 farll~r••

(2) Under REPUBLICAN-SHAPED progra=s of past FIVE YEARS (1982-1996), HORE

W1.S SilP.S't' 0 .. I\CRICULTURE ($104 BILLION ~"ti",o\1';I! ·1-1 "f' to\.. t ~!,r-ing) than va.

spent on a'lriCtl1 ture dur-inq pri.er 18 YEARS1 It cOlllllli tl:llI'lnt to M"rican f..r.llrs

lS IIIt!4surl!d by ·Iollars, th~ hct is th"t r:tl~ ;U:?;J"t.IC:~~ Se:~~TE d'!'livl!r:~ti f"t'

'JcolJ~tl!r "hlpport ti> cllJetcultl.lt''! tl\oIJn pr"!v\ously efferted 'lnder Ol!lIocratic control•

• (3) ~ugq~st ~mphasi~ on o\c~ievl!~en~ of fac~ proqra.. , light acknowledg~ent

of inev\ tah t.. \nclll~'I'l"r:i~~, \)01 t 'II) n~ to .n.. o!l(tP.n.i VI! r-'l'Ilarks to Jef~nri ""rota

n\ t to Sound. too defenU.ve.

• W"IJQfIlC BIPAJt'n.SA.1f SUPPOil:'t' P'RO'( 97 SBXA!'ORS, Republican-controlled Senate laet yur led v;yt;-;o.t-;:;;;p[n9-tii.-reio~Tn40 yun.

· -1'. sorry our party dl.c!~'-L~~.i.L~'!._C?.~~_!.~'!!..e!.~~~,- grous~

Democratic pr".idlllntial hn?'lf'll. e,.,.ry 'l4rt, -but '-t 'lot ""''''1 fro. us .nd

it'. theirs nov. - (w..~~}~~).

• No vander Deatocrae.. cril\gotd at RdpubUcan-led t'l'!fOrlU. \'h!'.)II'jh tlwt

hi.04:-..lt"l·~ .)....ul'taul, Republican.,

#' -_'OO -. _ .. " ...... - .' 1: _ .........

o ntalnated about 6 Jln:t.IlJII POOR. frola t.M taJt roU••.

.~ - . ;";" -...~-
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Page J of 4

o Reducet\ tho! t'Jt> ro\t~ .,f 27\ t""'otr tttan -tt .tny ti~'! .. \.nc~ 1931.

• IJICQM.E TU IMDDING, eng1.n~t!r~ hy R~puhlic:"n., ·n"ur~·\ ?~!I4"stY ~::'IF:F' 'l':)

-.«)I(~ ~~." (ConCl'!nt.ro\t...l C'~H~ F f'Jr t..,"'-\nco::le taxpayers "'ho move up

narro'" u·x -b;;ckees-fastl!r. )

TAX ~, Coat"d

• D~TS IQY WIll 'nm RH'n'ORIC _~~! - but. 1. t.' s REPUBLICANS WHO HAVE

DELIVr.REO TAX RELI~ th~ v~ry ·,",or~ers, ,",omen, ~lnorltlcs and poor- tor' IoIhe.

oe~ocr.ts too often clai~ l'!~clusive ccncern.

• HEW CHALL1!:IIGlrr TO BEAT BACK ISEVITABLE DE~tY.:'R;,":'·r.: ~T'1'~PTS TO S'rRIP "wAr

':'HOSE !{1I.R~-WON ·r.u: BR~..A~! ')~:nocrat-eon tro lled House has already re) ected

efforta to proto!ct tax relief fro:: early er0510n. DOLB RESOLO'TIOII seeks to put

Senators on record AGAIlIS"r M'( t"fC)ll(! TU IHCRE10SE THIS YPAA:--Aiencan

"'orll:ers IoIon 'i\1h:l tan ~c:ll rAe -,.";(....;;·,irl.\';r" .tll;-:-i:';;:i. -.i~~-:;i.- -';~i' !' "Il ".)'# '1\-\<\"'1 "'J.lC

~:;T. t~ :J ,P'C;!':~Vo\'t' [:)~ " ~.,!? l'ri.,ri. ty on the Republican -\g'!nda.

• m 1ft (~~L~q~~_~_~_~~.~,I've traveled to Michi,qan

, els~wherft to lobby legislators.... 32 .tates hc:lv~ adopted resolutions urqinq

con,t1tutional a~end=ent limitinq taxes And rftquiring a balanced federal

budget. I'M COHlUft!:D 'l'O A BA.I.AltC!D _~E'f ~.

• SBIIM"K BllDGE'f VO'rW III 1985 't'O KL.DUnn 13 PtlDBRAL PROGRAMS. , restric t

"£ll"ndlng In hundreds of other proqra;;-;;S;-ma);;-v\ctQryt;;ards budget

r~.tr&lDt•••• FI)ILED ONL~ WHEN HOUSE BA~~EOI

• G'1lAM'-R~ ha. been useful in aovinq u.s. tovllrds b,ltigt!t control aut &

.tatUtl! c",,, morlified, po.tpo,,~d, or "~4n1~d hy a ~\~pt~ a-ljori.t/••• ",~ieh is

vhy v.. neud th.. Con.tittl tl".,.t -t.,'!",l..",n t to fort:~ '':a''.Jro!.... to fi:lc41

r~..p')I\!tlhl\ t tt.

iIO(!IIl S ISSUES - .. -.........

• PElISICW -I:I"ORM, Oole-backP.l\ \'!<Ji:ll-l t\Ol\ 'J"v~ 'lOING WO"tDI the ri.'.I:'!; 1:,' 1""tt ~t

'!-lrUer for'-~-n-'-fon program., and CJU&ran~t!d OLOER WOMEN II shArlt l)f th"ir

.poUSft', r.. tlr~~..nt lnco,.... (8'!c~use hiqhest ~rcentaqe of loIO,.e" "'ork durinq

early twentl"8, exclusiol\ of thosd ~tkor. fro,. penSlOI\ accrual proved a qr.ater

ltability '--.le than .a1. vorkers).

..

.. - ,..,. :\.. '" -:- ......_.... , '-. ... ...,-\- - . .... .. -,.-:... ..- ,._.~~._..:;~_...~,_ ~.1.'Y:.:....-.-i.'t.~~~ ...

-~..,.~ . ..- ~- ., '~ "'""%.~

.

i

i

• 0IlLD SO'P~ IlJIPaCC&aAl. Dole-backed leqisl"'tion nov "llow••tate anc!

r"'e~&l qo"er,i,;'.,nt.a to WITKliOLD TAX RUUNOS from parenta ("os~ often fath.~.)

"'1nquent On r.h1ld support payaenU. Such chi l,'l~!upport Qnforcltl2ent crucial to

~r.,t""••nor.",,, econo.lc pre••ure of~n confrontinq "'Ollen "'ho head hou.ehold••

... -:~.:. <: ' .. ", -.". ... -. . --. :--".

._...--*' ~, ~';••:};, ~4 • .J . ..-:-~- -: -. ..... I '~ . :.. . .. -.

lS-.s.......-=.;o.;·~
• DISCRIMI~~Y LAWS: A Dole p~opo4~1 would nQt ~llow t~~~r.l ~u~i4 tor

.... f.)rt:>tra"nt o;-iiws-;ith qO!nd,H'-l>-t'N.l .n" t LIlr:tio"of.

~IT't ~IGlft"S -..--....

• RIGttfS N::"t: (Briefly explain stalt'!'1 f.),. b't-tr:lt "Qtl'lrs 1'\ :iOClle U.S.

t:o~unl tidS) ::: - -.)'';i'.. ted RepublicAn 'NPP')"" :.Ji:'l·n:it' "'liICIi 1lI11'\Ot"\':y \I.)t.. ,... i'l

~~ U.S. co~,unlt1~'1 ~ld ~ve LOST legal pt"ot~ctlon ess"ntlal quarantd"

their ho\'I1.c r:"l\4titut1onal C'i,qhta.

• MAJl:fiJI ~_~;~-':!<~~I~ID~!: Floor leader ~o naVlgate legulatlon throuqh

Senat~. ~es.aqe to black Al:lerlcan.: The Ol-trty of "brahall Lincoln REMAINS ho••

ot ~~ OF US deeply cOC=ltted to full freedom, rlqhts, of all A2erlcan••

(Note: :espite Iova's mlnuscule minorlty populatlon. Iovan. ~f all stripe.

are generally .upport~ve or at lea.t not antagon19tic to this type social

issue.)

e-

'Q

'-0 1IOl"B: GEnRAL OBJFl:'n~_~~_!~~~,,!!!

• ADDRESS VM.tR:S I~'1"0 IQIIlI'MIS: Initiatives Qn -5qric'lltunl 'l'!n'!rally,

porlt/corn ~P;cl7ic';i'iy;ti';-i.lo~--iova·s~lIt i'l~rl!sts fu ,",or'! ti.'lhtly th&n

~.o{ihl", ",i.th d'ly I)th"!r Republ1c4n ho~ful., ,t)Ossibly th.ln ,~"y O.~rtOr.r"t.

• OPPER I~AMS PRIBND 1M THE WHXTK MOUSe: It candidat~s ar~ co~fC'Qnt~J ~ith

'l'.W;tl.ln: -;i;;-<;·tio-uld-ioUi-?~'i·i-;;~,iiCz;';;i.';""'l11C''' 'h~",'l" thdt i.f ,/.')11 are

elected Iova vill have a friend ln the White ijQus~.... tt". li~e11 NO ONE could

ansver t~t chAll~ng~ ~9 ~tf~ct1vely as RFO. So ve should ~alte sure the

question is asked ••• and asked ••• a~ askftd. (j.inq past as baro~ter of future)

<Useful in other farm states as vell, for that matter••••)

(BRACKETS ADDED) • O!:YDfK BOB I)(){.E WI'fH IlOJROKIOLLr COI(SBRVA'rIV'K ~'f\) CCM(p~IOIlA'fS SU~AJIC3:

A too-rare coablMtion, but VERY APPP.iLiNG-tO-i';';~';i;--iti,;.;-the ------------ balanced-budqet, t&x control substance vithol1t w~arin9 out the ·conservativetara, But alllO atr4s. 111lportant nol" battle~ tor wO••", poor, "i,l\()rttt.....,

,"ndicap~ for- t!'\"J c')nlh!rv.. tl".~-",i.I".!l-.'-".:.'.-~..~'':':1:1'' " .• "'•• ,,~tj. IJ 'tl~~ I,~ ",_

• '~/'4~ RIGHTS included l'ap-r" prhlaci1y b"!C~USd thQlIot lUll... wert'!

rAisl!ci in i;ror-!ci';4 -tn-';" "'~tin'3.. ';OI!lIl1 $~tt1n'.1. ·ny not w"cl:'"nt t.ach

-...pha!iI!>I, h,at thot __ 'Jtt.l :').")~.;:; ~~..,~.) "h~'lt:\ 1~ .:i t:llcl 4:"'-1 i ....'l1'1l1 r·~ht)_';
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41.42

119.86

544.411

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1.300.14

91').20

415.111

1.646.n.

1,173.13

106.94

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512.64

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3.!i21.00

3.464.14

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1.326.6'

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IU"A

IIII1L-NOIf

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41.4:&

60.3'

2!i4.11

3:15.?4

1,8:12.41

1U1.10

2,181.22

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6.7.60

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303.1')

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640.41

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1.904.14

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ALLOCAIILe

A"'

3/31/16

4/04116

4/18/16

4/30/8&

6/::l0/8(,

112:1/8&

0/03/11(,

8/22/86

91191tl/,

10/.l1116

10/:1118(,

11/24/86

12/03/1U,

1/12/87

1121186

2/07111

2/12/17

2/22/11

2/23/17

CHECK • I

CHECK.DAn

~ESC.I~110H or EVENII

lIAtE or EVENIt

..AYII

------------------------------------------------------------------- ---------.--.--_ _-_ ..

2/23/81

1.IAKrASI "KITING, ,AIIIM,O.T

IlVI AIII"TlON 3990/2-1'

IL"CKHAUK HorEL rOI: 4~3"3-23

FLoro 1llI0llN

10" SYNHOISI

• "AnEll

" GL"SSN" lENA1011 DOLI

to" liYNHDRSI

IU.fOULS:

IUItOI"U:

I."MD 10IALI: '0.26•••1 46.1:14.99 33.397.;:4 14.024.30

----------------_._------------------------------_...------_....__ ....•.....••.•._.-... _....

oJ
:..-; ... ." .

At~.~": :5 'p.·~l(f·of :J

PlJ001122

DOLE FOR PRESIDENT

Definition of Columns:

.'

;';!.~

o

•

•

•

Iowa Allocable Amount - These CA expenses are allocable

to the Iowa spendin9 limitation. Since CA personnel are

not Committee employees, the "5 day rule" is not

applied.

Iowa Travel Non-Allocable - These expenses relate to CA

Iowa activity but are for interstate travel, interstate

telephone expenses, etc., and as such are not allocable

to the Iowa spendin9 limitation.

Other Expenses - These expenses do not relate to Iova

but were paid with a CA check which also paid expenses

related to Iova.

Plemo Entry Expenses - These expenses are included 1n

amounts discussed with respect to the payee. They are

shown here only to provide a aore complete picture of

the event and attendees.
I€Ml

Al.lot:able fbl-Allocable

'-mt lIM Mont Other 1IIImt salary

$ 545.26 $ -0- $ -0-

-0- 434.00 4-

600.11 469.00 4-

23.00 ...0- 4-

$1,185.92

254.~ ...0- 4-

..0- 290.00 -0-

370.56 468.00 33.02

-0- 285.00 ..0-

1,185.92

...0- 7~.00 ..0-

216.98 ..0- m.m

425.82 -0- 47.50

129.:1> ..0- ..0-

au RIl I'1ei1D'Nl'

.-rica £IqJemes -

Floyd 8r:tMl

--------_......

) 3 ,..., I rJ

Payee Illtes Oe:k. • Oleck Illte

Floyd 8nM1 0'JI1818fHXJ122186 1004 04107186

Inter. tet. Tours 03118186 Ins 04/01/86

Floyd 8nMa 00/23186-3126186 1m3 04/07/86

Federal F.lqRss 03125186 2001 W04/86

Floyd 8rtMJ 03116186-3131186 IIepoct 04/01/86

Floyd 8nM1 03I:n~101I86 11m 04/07186

Intel'. tet. 1\:lurs 03I:w86 Ins 04101186

Ployd Br1Ml 041O'lJ86-0411li186 11m 04/07/86

Intel'. tete TOUl'S 04102J86 UJJ4 04/21/86

Ployd 8nM1 04/01/86-0V15/86 Repol't 04/15/86

Intel'. tet. Tours 04/16186 1B84 04/21/86

Floyd 8r:tMl 04/16186-04/18186 1905 04/29/86

Floyd 8«Ml 04/19186-04125/86 lSU> 04/29/86

04I22f8(H)4/25186 2425 01105186

Floyd 8c«Mt 04/15/~/~186 Repx-t 04/29/86

FlO)'d Brown 04/29/96-a)104186 1984 00/14/86

Bl'• FT. IIilI 04/29~I04/86 ~2 (lj/2l1WJ

Floyd BrtMI 05/0lJ86..{)5/04/86 2425 01/05/86

FIO)'d BrtMI 00/01186-05115/86 Report 00/14186

Ifl'. fT. IBf 05/15/86-05117186 2078 06/<Y1I06

Floyd BrtMI ffi/15/86-(l;/17186 2149 06/16/86

Floyd 8nM1 05/16/86-05/31106 R(1)()rt ~/OI/fl()

6 ~O) .'t tJ

675.90

445.90

250.94

1.53.52

244.37

-0-

4-

4-

..0-

-0-

.mN1tfM'16

Page 1 of 5

1,185.92

510.39

4-

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1,185.92

...{}-

646.15

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Pi¥Je 2 of 5

Iowa '\~~f~~~~-'

Allocable tbl-Allocable "',!;~~~~

Payee Qltes <m::k • <beck Qlte Anmt Iowa Ammt Other '-u1t Salary ~J3.j(i

·.';~e

~~i~ :~~ Floyd Br1M\ 06109186-Q6111J86 2149 06/16/86 171.90 -0- -0- .~'.~~:~~

'~.~t~~ 06I09~11186 2425 (JI/ffi/86 142.ilO -0- -0- :/i~;1

Inter. Nit. Tours O6fOlJl86 2144 ~/16/86 ..0- 444.00 -0- P".~ I"

Hr. Fr. I&f 06109~11186 2151 ~/16/86 129.94 -0- -0-

Floyd BrrM1 06I01J86.06/15I86 Rep>rt 06/15/86 1,185.92 ,1~@ ~J'Ajll 0<

'~('~i

8r1Ml ~/18I8(H)6~ mJ 06/25/86 339.14 -0- 79.» u!~J ,:-!:,.\~,~

Int~. Nit. Toors 06/18186 2261 (11/('fJJ86 ..0- 464.00 -0- -·l':;"}~

;·ik--i.t:.;oo:

~/'t-r~l

Floyd 8nMI ~12618(H)6129186 2291 01100/86 201.43 ..0- ~.47 J Wl,:i

l.\;{l·j

06/26186 2425 (JI1(lj/86 8.~ ..0- ..0- !~~~& cJ:...

:£.~

Floyd 8nMI nvI6~:J>186 Repor:t 0»/25/86 1,185.92 #~3~

'}:'

~8nM1 (11/01186-01/15186 Report (11/15/86 1,185.92

Inter. Nit. Tours 07/16196-07/17/86 2370 07124/86 ..0- 290.00 ..0-

111'. Fr. lSI 01116186-01117186 2392 07128186 138.01 -0- 49.<x>

Floyd Bcow 01/16196-07/17186 2425 aII05/86 1J4.81 ..0- 4- :~,~~

Hr. Fr. [91 01121.J8&.q1124186 2397 07128186 120.05 -0- -0- ~$J;

FlD}'d 8rcMI (11/'1:J.IfY,..{J1 2425 aII05/86 1J8.04 -0- ..0- t;~~' ;';,ii,,J

Fed - fJqJ 07/23I8lJ 24~ 0IImI86 23.00 ..0- ..0- "lf~ "iti·; Inter. Nit. Tours 07/22186 24:J) 00105/86 ..0- 247.00 ..0- {~E -:~}~

llJrl.irwtm Ind. 07126/86 'JJn CTlI25/86 ..0- ~3.oo ..0- ,~ Floyd 8nM1 (11/~1/31186 Report 00/01186 1,l85.92 ~~;:~ .!::~.

,1'1":

Floyd BnNl 00/03/R6-00104186 2506 07103186 51.56 ..0- 14.00 ..:~ Ali,

!J.;~ Inter. Nat. Too..-s <W03I86 2~ <W12/86 ..0- 400.00 ..0-

ur. Fr. (Sf 00/04/06 2487 00/14/86 100.14 ..0- ..0- ~$i. J""~'I

Floyd Brown 00/01186-00/15186 Report 00/15/86 1,185.92 J&t ~l\IJ

·if.~ Inter. tel. Toors 00/18/86 2430 00/05/86 ..0- 370.00 4- '",'

.~-~:?~

Floyd RnMl 0011f)/fJ(...OO/11/f)6 1'i1V. mlCYJ/RI) 1S4.A'5 ·0- -O~ .~;~~

Iff. fT. [Hi 08/19/86-08/23/86 lIJlt. (J)/'..,/ll6 :1JJ4.9') ;",

0 0 f

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)

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Page 3 of 5 ~~:~ ,-Ai -,,1

-~~~ ; 1'. 'f

Iowa (~~

A1lDcable Nm-All.ocable '~~f

'."'~""

Payee IDtes tbeck I Oledt nUe Itnmt Iowa AIWult Other AIIlult Salary .~:~

~~~ 't}-ltr)

Inter. Mit. TOOl'S av27186-aJ/~/86 2586 09/02186 4- 819.00 4- .~r,~

Floyd 8nMI 00127/86-(81))/86 'BJ7 09/02/66 217.81 ..0- 48.00 ~"~rf~i·~ '\~JilJ

Floyd IktMt 00/29186 2766 09/24/06 118.56 ..0- 787.n 'i'f~~ f:~f!i( 8I'• IT. lBf 00/27186-OO1~186 2653 09/00/66 183.27 ..0- ..0- :~:)~~ ~:,;~~

Floyd IktMt 00/15/96-00131186 Report 00/29/66 1,185.92 ;~~ ·;~~1

Floyd Br<M1 09IOU66-00/15/86 F.eport 09/15196 1,185.92 ;i~

!tt~ :,".1 "'~ Floyd Bwm 09/17/66-00/'JJJ166 2769 09/23/1)6 266.22 ..0- ..0- J!,{t

Inter'. Mit. Twrs 00/17186 2833 10/0V06 ..0- 440.00 ..0- ,;;<~~

a~~~ Hr. Fl'. [Bi 00/17/66-00/19/86 3370 lU18/(J6 103.86 -0- ..0- ;'~1 .'1£t

~~.~

Floyd 8rowa 09116186-10/0V96 Report 10/0lJ06 1,185.92 ';i~~~'

'-1:.~

Hl'. F1'. lBf 10/00/86-10/10/96 3370 11/18106 91.18 -0- ..0- _?~

Floyd 8nM1 10l00l96-101WI86 'J!HJ 10/15/06 167.21 ..0- ..0-

Inter. ret. Tours 10/00/86 ~71 10/22/86 ..0- 400.00 ..0- ~i;,Jt'..t

~~~

Floyd Bwm 10/0V86-10/15186 Report 10/15/86 1,185.92 ";;q~I:

i~~~

Rl'. Fr. [Bi 10/15186-10/17/86 3370 11118/96 133.65 ..0- '~;,f~i)

..0- .;"~

Inter. Mit. Twrs 10/15186 .l>71 10122196 ..0- 620.00 ..0- -::~ #

;~

Hr. Fr. flit 10/20186-10/22186 3370 11/18/06 136.84 ..0- ..0- ~;t1. :-.)Qf

Floyd 8rcMl 10/19186-1012JJ106 'JJlJ7 rtJ.J(JlJ87 6.00 ..0- ..0- ·r;'7Z?:'

~~j~(

Black Imtc Ibtel 10127186-10128186 3272 11104/86 47.64 ..0- -0- ~!.{;

,~~ FlDjd Brown 10/16186-10/31186 Rep>rt 1110VB6 1,185.92 ";;~

Floyd Br<Ml 1l/0U86-11115186 ~rt 11115/96 1,185.92 ~i~j Floyd BrtMl 11124186-11/26/96 3407 12100/86 170.67 ..0- -0- ,'''.~'l '.~~1~ Inter. Mit. Tours lU24196 3515 12/26/86 ..0- 400.00 -0- • ;tii'1;l'

Fl<1jd Brolin 11/16/86-11/30/96 Report 11I2MJ6 1,185.92 ,';j~ ;{j!!;

'1

}f;j~~ I., -";:::'>;'_:";~
1,185.92

1,1JlJ.92

57.98 ..(}... 4-

1,288.92

5.25 ..0- ..0-

4- 37.8.00 ..(}...

7.00 -0- -0-

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IJct'd 11\

Salary Allocable

41.42

1,288.92

1,288.00 644.00

1,288.92 1,288.92

27,7CXJ.24 1,974.34

$77 ,7C(), 71, ) , cn11 _,111

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400.00

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$I),nl.m

..0-

8.00

41.42

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61.00

TfMl

Allocahle

Mo.rlt

8,591.71

125.94

451.15

107.95

119.42

527.:n

338.69

$10,267..16

12122186

WW87

12122186

O2IW87

12115186

01101187

WW87

01115/87

0Jeck Due

WCIlJ87

Woo/87

W02I87

W01l87

02/13/87

03/23/87

CYlI27187

10/01/86

10/10186

1l/~/66

01119/87

CYl/IO/07

03/18/87

;' I .-5

Illtes 01eck •

Inter. Ntt. Toors l2I0V86-12I07/86 3595

Floyd 8nMJ l2JW86 3867

Inter. Ntt. Tours 12/11/86-12112186 3595

Floyd 8nMJ 12I11J86..12I12186 3867

Floyd Brown 12101186-12115196 Report

Floyd Bl'lMl 1V15/86-12I31186 Report

Floyd Brown 01l12l87-01IlJ187 3867

Floyd Brown OUOl/OO7-01115187 Report

Floyd 8l'lMl 01117187 3867

Inter. Ntt. Toors 01121187 3871

Floyd Bl'lMl 01123/87 3867

Floyd Brown 0lI16187-Ol/31187 Report

F1.oyd Bl'lMl 02101187-02115187 Report

Black fmtt Ibte:.. W22J87-02123187 4236

Floyd Brown 02/16187-02I'lB/87 Report

Total Salary cnllhculmted

FroI Reports ()lly

mfA!.
I' I\. t-·~, ... : '" I

, ,A..

i

••

I

II
,t .'

)31/016(O~~

IlU AM I'IQlSdIM'

~"MKtca~­

T~ 9)mor:st

Payee OItes 01edl , 01II!dt IlIte

b 9;'rDJrst 0V01I86-Q5I31186 .....t 06123186

b SyrhJr.Jt O6IOlJ86..()6Il)I86 Report 07101186

n. SyrhJr.Jt 071'OlJ8&.07131186 Repor;t 07/31186

n. 9;'nhorst 0JI01I86...0II31186 P4!px't aJl29186

Tc. SyMont 0l)~131186 Repor't 1OIW86

Federal ~ess 10123186 J293 11/Clj186

Tc.~t 10lO1I86-10131186 .....t 11101186

Tc. Symorst 11101186-111])186 Report 12I02J86

Tc. SyrhJr.Jt ~12I31186 Repoct 01107187

Int. MIt. Tours 12/11186 3595 12122186

Tc. Symorst 01101181-01115187 Repoct 01115187

Tc. S}mor.Jt 0JJmI87-OVl.3I87 3792 OU21187

Avis P4!nt~ O1IOII81-oVl.3I87 3924 alJI0187

Int. MIt. Teus Ollal/81 :B)) 011'12187

Tc.~t 01I16187..())/31J87 Repor't 02101187

Int. MIt. TClII'S 01119181*/ :Bn 01122/87

~/ See Federal ElqlIess delivery to Ibtd FI' mt 1/22/87.

Iowa

Al10alble

....t

14.00

-6-

86.21

ffl.97

-6-

-0-

tm-Allocable

ICM AIIuIt

..0-

m.w

..0-

..0-

278.00

390.00

m'MHIJft' 17 ,. 1 of 3

Other

f)cp8llJt5 Salary

S 2,(0).00

1,<m.OO

1,(0).00

1,<ro.OO

1,<m.00

..0-

1,<m.OO

1,00>.00

1,<m.OO

-0-

1,~.S2

69.~

-0-

-0-

1,~7.52

...Q-

"~q..

., f

~!~~~

~l;.~!<1 ;-~~~;.

.{~l '§1

,#~ ;'\\J~'~

;'~J~

._~~~ /~~

jZ~

·JYJJf :;i?2i3 ,"'if'"

,H~ ,,·d'i,

}t~

"l~~!i't' .~~~~~~ .\'fP-i-

.:~

{ti

.:~

~.~ .,..:;

<'

...

/~)f~

_ I~l~

,'- t >~~i;'v"'to'";: ...... ~r.:;~;~~1~1
A1TMlIIM' 11

"20f3

6 5Q; [}.(;;

IXU MIt M&lIJIl'

... Ml!dQ £llpeIlgeS -

Tm. 9yimrst

):3·')/0

Iowa Camtission

Allocable tbMilloc:able Det'd IJ\ (heck • Owedl Date ItIImt Iowa ....t Other Mutt Salar.y Allocable

4235 03I2.l187 ~.n 4- 4-

J973 02118187 11.00 ...().. ...()..

t«J7 C'Il/26187 229.01 4- 4-

:JUt C'IlJ03I87 ...().. 215.00 ..0-

Aelut 02113187 1,~.S2 753.76

/1,)73 02126187 341.69 4- ..0-

:1191 C1lIOOI87 4- 518.00 ..0-

I'eport C'Il/22J87 1,455.52 1,455.52

IIJ44 C1lI25/87 3n.37 ..0- ..0- 372.37

W8 C1lI1DI87 -0- 696.00 ..0-

4164 03112187 557.~ ..0- ..0- 557.90

41f» ~187 ...().. m.m 4- :6~~

41.42 ..0- -0- 41.42 .:~~ J.~~ "'1;:"

41(» ~187 ..0- m.oo ..0- .j;·i~

;JfU~:

.....t 04/16187 262.29 j~{*~ <i~~~'

·t~\~

$2,710,-70 $3,267.00 S 69.90 $14,978.00 3,J80.9J ,~£i ~~\"ft.t:l

,it~~r~ ~"'%;~:

~fl~~~

:.{~1~

.~~

:~~ )d~

;~~

~~"

;~

Dates

01I27/ffl..l11lYJl87

0lI2BI87

01127/ffl.{JVJ9187

OV:JlI81

OlI01I87..Q2115181

0'l/16/ffl..Q2l17187

C1lII0187-02113181

<rlll0187

W18187-W24187

<rll18187

0'l/22I87-021131ff1

0J/03I87

Rotel Fr. IHI

Federal ~e§

Tm. Syrilont

Int. Nit. Tours

Payee

-

---------..-~.I!IIIII ...I111...................................................

'

1

TOI Symorst

TOI SyrDxst C1lJC1lJff1-f1l1C11187

Int. Nit. Tours fIlIC1JI87

(ru.t to 0!daI: Rapids)

TOI Symocst

TOI Symx'st

Int. Nit. Tours

TOI Symorst

Int. Mit. TGII"S

BladchiMt Hotel

Int. Nit. Tours

TOI 9yrhxst

GrarII Total
...

.,' "'"

I

,
'lUfAL Jane Voights $3,049.89

au RR ItCtSIlINl"

.. Mlrica Elanges -

Iewa Staff ""~E~,

~~~~'I:

~:~I

1f~· ;~'t';'

'4:~~ 9~I)lt

':/.r:~

),."'~~. '~;,i ;" ~<. . \,~,;~!~.;;

~J~~ "'J;o J£.,1;j/A

'1:1'2

..'J~:t't;~:r Jt~ .' ;lf~'2. .. v~frltf

00>.00

Sillary

)l~~~: ""~~~~ <:_':.t .{

/Yf~~ ";~~

~i~

,~¥1 ·ff,:j

.J.\~0i. ;.I••y' ~'":,~ . ~~:'1~ ..".p.~;

;151

l~~j"l

i'r'

~~~..\:~

;it~

...~~~:~ ,\~\

\~,;5~

'"

'_~""" ,,', ,.,~v."IiJ .1

$2,00>.00

$ tm.OO

00>.00

m.AOtIM 18

,. 1 of 5

-0-

Other

-0-

tbl-Allocable

Iowa ....t

00.00

118.57

49.90

641.45

72.'}!)

55.14

93.06

207.68

$28J.54

176.0)

103.36

339.26

319.20

525.00

Iewa

AUaJle

....t

6€().~

.W£ WDIMIS

07107/PA,

07/11186

07103186

10109186

10100186

01111186

00/11/86

07/~

00/11/86

09/25186

00107186

101111186

0Iedt Bite

00/29186

00114186

10109186

11/18186

10129186

/ 0

24S5

2392

2290

2343 22n

29QS

29QS

2454

2456

2792

2429

3165

) j

Repott

0Jedt •

2485

2905

]]78

3212

Dltes

O6I15J86.WllI86

WIOI86-()6/18I86

06I20f86...0iIW

06126186-()6/29186

06115186-07115186

07/01186-07/31186

0711~/19186

07/161Pf>..07/17186

C11113186-07I~

07124186

071261Pb-07/'1J186

~t - SeptEllD!r:

00/01186-$31186

(8I0411J6..Ol1{M16

OO~

1OI25~lonB186

10/25186

Jane Voights

Jane Voights

B1' PI' I&t

Jane Voights

Jane Voights

Jane Voights

Jane Voights

HI' PI' 1St

Jane Voights

Ill' PI' 1St

Ill' Fl' 1St

Jane Voights

Jane Voights

Bl' Fl' 1St

Jane Voights

Jane Voights

Int. Mit. Teus

Payee
"

m.MBIIft' 18

"2ofS

:, ..., ....,~. ''1 ~\- .. ,:;..... -,.... 1',-- -------:;'j' ~:-"''jj...',.

, <. .it, ~A<ff

) 3 J I a I 6 Ij t> 3

¥ .. ':

au Q RGiL&d' "'" .... ~t....tCll ....... -

ICMI Staff

- ICMI

AThable tbhUlorable 0theII'a}w OIt•• (Juk' 0Ieck Dlle ""t ro. .....t J)rp8- Silluy

..... la...

Jcm P.t!f-.. 0*nrM1 1917 06/l)I86 $ m.oo

JcmIW-. 2152 OWI6186 $ 1m.22 225.00

Jcm rw_•• 07/25I8i.()lJ1OlI86 333S 11/11186 m.oo

Jcm 111_., a.se NIwot. 3315 11/11186 1(1).(1)

Jcm 114_" 0712S186-(J91Ol186 ms 11/11186 125.18

Jcm"••, ()I}~1OI01I86 3336 11/11186 3:11.00 4.10

........., 1Of01IIIf.-1Q131186 34f4O 11/25186 118.15 331.50

Jcm"••, IlJ01J86.01119187 ~1I1d 01/29187 II1d 215.18 l,m.oo

e9 aJ.I26I87 - 'ftmL .......... $9fi6.9J ..a- S 4./0 $2,762.50

~~ .i~

. ...

' ,.,n ,~~.f ~;:.I}Sl"''''''·'' ".' ,,;;,:-.'if.

I
.~f*' ,;;:;J ....\.j1'~l~

,:~~I ~":

f~

:';~I

r..!/i;~:;;

'ti~~ ";::f,f:

"1#"';

'1"J!i{~

~i";';!;.j;

.~~~

'-~

,li~ ;.~~

,,~~~.

t;

'i

~:i

,

~r ;~f{~':~~~' J ~~f'~~

q'i::irt~ ~!1~(t

·~~k~

~~fgi

camti.ssion i:::'{ Det'd'~.:iA'...?·' .....iI:

Salary Allocable

Oth!r

A'lTJOMNl' 18, ,.. 3 of 5

ICMl

Allocable tm-Al.lorable

AIIuIt !CMI AlnDmt

CALIIDMI

Uaedt • Oaedt Dlte

) 3 ) I Cl I 6 ~() tJ

lIU AR 'M' ~lllll ARrlca £llp:.~ - lwa Staff

~~~~----------_ ~:: ~::::~.:::::..iii~ ,

Payee Dltes

Call1J1t1m 00/0~1l5186 2Bl4 00126/EKJ S~.OO

CalIl11..... 00102J86.OlJ1UiI86 2782 00/24186 $ 259.76

Call1d..... 001071f'J6-{1)/12/87 2781 OO/2~/86 200.84

Call11lbm 00/16186-10131186 :m2 10/17/86 2,~.OO

CalIl1l..... OO/I6186-O}/19186 2818 OO/:J>186 1111.10

Call1dbBn 00/'l:J.IW,..(1)/261WJ 10115186 ~33.J6

Cal Il1ltEn OJ/])186 2951 10115106 11~.63

Cal IlJl.tEn lOImI86-101l5186 D79 11/18186 6.61

Call1d..... 10111186 3139 10/2&'86 85.22

Cal IlI1tEn 10122186 3138 10/2&'86 00.99

Call1dtEn 10/28186 :m4 IlJQSlEKJ /J).20

Cal IlJl.tJBn 111O~11/15I86 P4!port l1J01186 7~.OO

Call1dtEn 11/16186-11n>186 3374 11101186 7~.OO

Cal fllltlm 11118186 ~1 12/18/86 16.])

Cal IlI1tEn J2I01I86-12/15I86 Repor't 12/02186 7~.OO

Cal. IlJ1tim 12/16186-12/31186 3554 12/15/86 7~.OO

CalIlJ1..... 01101187-01115187 Repor't 01107/87 7~.OO

Cal. IlJ1UBl 01116187-01131181 3747 01115/87 7~.OO

Cal IlJ1tim 02J01J87-al115181 Repoct OO/(JJJfJ7 7~.OO 375.00

Cal Il1ltim CIl/I6181..(Jlf28/87 Repoct 00/00/87 ~.OO 750.00

Cal Il1ltJlIIIl 03/01187..(JJ131187 4413 ~/28/87 1,~.OO 1,500.00 -- -- -- 1UfAL Cal Il1ltJIIIn $1,516.00 $6.61 -0- $lO.~.m 2,625.00
........

Int. NIt. Taun lOtUI86 JJ71 tOI22I86

IWIIy IIaMI 1Of(J1186 '/947 IOIl5186

Int. NIt. Taun Il1mt86 :B71 12126186

!\my InJI.ft ltJn186-11121186 3564 12117186

IWIIy IIrcMI 1210118'-12131186 3540 12Im186

IIm1y IIl'CM'I ~12Im186 3645 01JC11181 92.U

IIm1y InJI.ft OlI01I87-01131187 3789 01121187

- 1UbL IIraIII $ 92.42

IIU RIl fIIISIIIM' ,....1... lalsica 1laI1!!I -

Ie. Staff

2,1tOO.00

Salary

$ 2,400.00

$ 4,0.00

'1 p 1.:-; ~~:'~':f£~~l;~Jt'ti'~7}~-

mMHM'18

"4of5

-0-

Other

~-

$ 491.00

83.13

JOO.oo

W.47

$1,(l)4.60

ICMI

Al1cable ttn-Alloalble

..,. 01_ dIedt I 0Illdt Dlte .....t lcMa ....t

·
CIro1 I.tfII1lIjd '*'-7 1987

Total ......t S 35,448.95

leD: tc. tm-AllacIble 1,061.21

0lJ0lI87-QZ12.B187

.... "t

... ... \4 J.

942~'86 ~<' , ;~

...',..

camdssim

Det'd .:IA'-'~ . Allocable "

1,491.53

5,059;)9'

5,05.9.39 4:' ~-"'\

5,059/19

s.1ay

4,em.CD

1,3».00

$1,150.00

1,150.00

-0- Sl.500.00

-0-

mM:1IM 18

...-SofS

-0-

Odw

EIlpa-

$ 4.10 S31.762.50

-0-

..()..

..()..

$1,061.21

I

-0-

-

-0-

-

-0-

ra.

A1l«.Ibla fbt...All.cable

AIIuIt JcM "'t

",625.24

..,....

11/11186

01/23187

am. ......

03lO\I87

.-mur

(DIl1l87

a.t~t.

lid ... J¥GDIIft'

~t. -.rica ...... - I.- Staff

.... "~'. ;r.-~~ '~~"'''-::::;~'''::'

D.14

ml

41m

4263

0Iedt •

) 3 'J I 0 1 6 ~O (;

$ 34,387.74

~- ...

Jeff II!ban

Jeff III!bcII

'!UrAl. Jeff rwvythe VllJey

r..StaffTo~

to. Al10cIble ....t
J ,.,. ,. ;OJ''' '< ~>,.- --'

- ~~l ~'~Pi?iJ41C;~~~i~{d2r~r

) 3 1 /'0 1 6 S () ~1 . f.~ 5'~"i}

. ,

«IVOIM'19

"lofl

IDI fat HGLiWI'

e..-t.. ABIc:a .... - I... Elcp!nsl!ll

I...

A110cIble rtn-Al.1oaIble

dIedt , 0Iedt OIte .....t lOIII ....t EIqleees

17m

1814 S 168.57

3~ 01121181 1,100.00 ;..

2153 06117186 1,170.00

Z359 07123J86 m.oo

2361 07123186 D.OO

D5 06f(MJ6 91.IS

4261 0lI31187 1M.56

3594 12122186 649.00 649.00

3711 0lI13I86 72.83

4162 (0112/86 72.82

nmvn 6WI)

,.,. OIt.

"""""''''''''''_IIIIII__I1111 ''''''''''"•••••••••••••••••••iliii....iiiliiiiiliii.i~'":r.I"~

, '(~~

t-~I ....'"

...' '.' .... _••:~~-:'." ,X.....hi;.1.'11

b_tel' MIA

iliA

III'

"

GI-.Jey'86

a-ltt. iliA

....... 1Irnt

ar. Pr. IBf

f« S. SlID «&11~

Elaine 9Idtil l1VlJI87

0Jqt. 12123186

Ultepte Tell.. 12116186

12/16186

'IUfALS

Total lOIII Mult $3,7/'/'.9'J

....~la t

Iowa A1loc:Ible t p.W.»

No --

.,

..

...

..0

z .. In:

......

III'

n ..n

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~~rff?71'}~~tfif~$$~~'~t-'~f~W':?~:~:";~P::;'ti1,:;:,~~11Ift,';,i'\;?-r?;:''o ·"'"-::{;'-:::';:·r;;:!,$;$.:~(~r~~~r#¥:;§~:J1-''''~J~ 1'f~~:Ftt~}'~;i1~t~: ·~.:r<r:1fi~"~'~'t:~~~:\i;'~;'\t~i'1J;';l;~r~:»;.F.r~.:f;~~;;F'~~lj:
------------------------------------------------------------------------------------------------------------------------------.-

----------------------------------------------------------------------------------------------.--------------------------------

AT'l'ACliHENT 20

Page 3 of 5

"TTENDEES

.,

'VENT

"TTe..DIU:S:

SUr."....C .UMEL"

SEN"TOI DOLE

"TTE.OE£5:

SEII"TOI DOLI

SUZA."E .C."EL"

"TTENDEES:

JErr "A..rULO

sua....' "I."ILA

IENATOI DOLC

IUA. BE••'

~' {

140.10

140.10

500.69

121. 10

'22.U

la.u

IU.U

"£"0

ENTMI

EXPEIISts

c /

902.00

tol.OO

OTHE.

ItIlI'£NSCS

'01.00

'01.00

HI.OO

NH

TIVL-II0"

ALLOCAILC

1,150.00

1,461 .00

lO2.1S

101.15

195.00

9l1.U

b E 0 9

Nil

ALLOCABLE

A"OUNT

2,019.46

12l.H

100.00

IU.GO

511.11

l,011.50

),00).00

CIIECIt

,

CliECIt DATE

lSOO/ll-05

1650/1-01

UOln-l0

nU/l-10

1111/1-19

U16/l-11

UU/l-0)

UOI/I-l)

U11/1-0)

, ,

1914/l-10

)664/1-01

)511/11-11

)606/11-l)

INC 16U/l-01

I ..C )615/1-01

)651/1-01

CO.T.NU ••G EDUCAT.ON

DESCI.'T.ON 0' IVENT/

DAn or EVUT/

'AICI:

SUIA....I IIU"ELA

SUITOTALS:

10/24/16

'ICSS CON'EIC"CI • CONCOID ""

11/11/.'-11/11/.'

SII.TOI DOLI "ODIISSES THC '0IT5"OUTH 101'''1' CLUB 11/11

SIIATOI DOLI ADOalSSCS THC U..IVEaSIT' or IIH AT CO""ENC'"ENT OUIKA", NK 11/1)

-------------------------------------------------------------------------------------------------------------------------------

HOLIDAY... KA.CN'STEI

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1'.1001122

DOLE FOR PRESIDENT

New Hampshire Allocable Amount - These CA expenses ar.

allocable to the New Hampshire spending limitation.

Since CA personnel are not Committee employees, the "S

day ruleR is not applied.

New Hampshire Travel Non-Allocable - These expenses

relate to CA New Hampshire activity but are for

interstate travel, interstate telephone expenses, etc.,

and as such are not allocable to the New Hampshire

spending limitation.

Other Expenses - These expenses do not relate to New

Hampshire but were paid with a CA check which also paid

expenses related to New Hampshire.

Itemo Entry Expenses - These expenses are included in

amounts discussed with respect to the payee. They are

shown here only to provide a aore complete picture of

the event and attendees.
~::.,

~rk ;,J~~ A'ITK1KNr 21 ~J~

!~' Paae 1 of 1

~: OOLE RI{ mESIIINl'

\},' CaJp;Ugn ItIerlca - y.:t Paul Russo t£

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~i~ Payee Iates Oledt • Chedc.late Mault m....t &penSleS Salaty ,~

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r· Paul~ WOOI86 '1147 06/»/86 $ 55.59 $ 11.00 ..0-

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PaulIWsso Wl3I~/15I86 '114B ~/30/86 4n.56 17.j) ..0- j

". Inter. tet. Toors 06/1.3186 2144 ~/16/86 ..0- 115.00 ..0- q

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,; Paul &JSSO 06I19/86-aJJ2OI86 '1149 ~/»/86 87.51 9.00 4-

" Paul FLlsso 06/01l86-aJ/»/86 Report 07101186 S 2,~.00 :I~).

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,. PaulIWsso 07/lfJ/fXrfJ7/17/86 2570 00/21J/86 278.97 16.00 ..0- ~. J. Inter. tilt. Toors 07116/86 2370 07124/86 4- 196.00 ..0- ,

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'\'" Paul Russo 07l1ll86-fJ7124/B6 2430 00/07/86 282.69 8.00 ..0- r.:; '; Inter. Nat. Toors 07/23186 2468 00112186 4- 161.00 ..0- ~4.

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'tt PaulIWsso 00I11J86-00/1.3I86 2521 00I'll186 ~.16 16.j) ..0-

il· Inter. Nat. Twrs OOIllI86 2547 00/26/86 -0- 197.49 -0-

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if Paul Russo OOIlB1B6-OO124/86 2845 10/07/86 1,279.87 9.!'i) -0- ~.

>', Paul~ 08/24/86-06129/86 2704 00/17/86 1,469.71 -0- -0- "

[l Inter. Nat. Twrs OOIlB/86 2547 00/26/86 4- 196.00 -0-

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" Paul £W.sso 00101186-(6/31186 Heport 00/05/86 2,~.OO t;"

P.}.' 1UfAL S4.841.63 Sl.119,lt9 S___4 S7,m.CO f(;.....

~r.~ fW fl<JqSure Allocable $12,341.63 .~~~ ,i:; ... lLlq1sfure tbl-A1lDcable 1,119.49

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Payee lates Cleek • Oleck late '-'mt Nt AlDnt Expenses Salary

~NitWe1a 07/0lJ8(H)7/31186 2481 00/14/86 $ 1,!ro.OO

Abt Assoc.i.ates 7/86-aI86 3200 10129/86 4- 141.65 4-

~Nieuela 00/24I86-0OI29/86 2849 1OIQ.V86 767.10 4- 46.~

~Nieuela 00101186-00/31186 2643 00/00/86 1,~.OO

~Niouela 00/01186-00/»'86 2B70 1OI(»/86 1,~.00

~Nieuela 00/17186-00/27/86 2946 10115186 217.41 4- 173.25

~Nierela 00/28186-10104/86 3115 10127/86 87.10 4- 4-

fAJZame Ni8lela 101<l>/86-10/10186 3167 10128186 137.93 4- 4-

Suzame NiBJela 10114/86-10111/86 3166 10128186 1~.51 4- 4-

Suzame Ni8lela 101:hJ/86-10/25/86 :r:.oo 12I<l>/86 255.n 4- 4-

Calcord~

Service 10101186-10131186 3294 111(l)f86 ~.OO 4- 04-

Suzame Nieuela 11101l86-111~/86 Report 12102186 1,!ro.OO

Cow Ccaft 10130186 3295 111<l>/86 39.00 ..{}.. 04- .

Suzame Ni8lela 11102.186-11100186 ? ? 60.23 ..{}.. ..{}..

Suzanne Niaailil 11100/86-11115186 ? ? 42.71 ..{}.. 04-

SuzalII1e Niemela 11/23186-11129/86 3653 01107/87 58.68 ..{}.. ..{}..

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Report OU:W81

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Payee

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SeIvia! 12101186-12131186

H.E. Calter foc

Cootimiqf &b:. 12I1JI86

Hieae.la 12107186-12113186

Nieae.la 12I0U86-12I3U86

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SeIVice OUOU87..{)U3U81

Nieae.la 8186

fAJzame Niaaela OUIU81..{)U25I81

9.rzame Nione1a OUOU81..{)U3U81

ful.ame Nione1a WOU87-4JJJ'JBI81

ful.ame Nieae.la W13I81

9.rzame NiBDela WOO187-4JJJ14181

ful.ame Niaaela 02I15/81-4JJJ2U81

Suzame NiaEla 03I0U87-OO13U87

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