FEDERAL ELECTION COMMISSION 

WASHINGTON, D.C. 20463 

November 29,2011 

MEMORANDUM 

To: TheCommission 

Through: Alec Palmer 

StaffDirector 

From: Patricia Carmona 

Chief Compliance Officer 

Thomas Hintermistef^^^ 

Assistant Staff Director 

Audit Division 

Alex Boniewicz \yC 

Audit Manager 

By: Kendrick Smi 

Lead Auditor 

Subject: Audit Division Reconunendation Memorandum on Chris Dodd for 

President, Inc. (CDFP) 

Discussed below are revisions to the attached Draft Final Audit Report (DFAR) as well as 

the Audit Division's recommendations. The revisions and recommendations are based on 

CDFP's response to the DFAR and the audit hearing. The Office of General Counsel 

reviewed this memorandum, concurs with the recommendations and provided the attached 

comments. . 

CDFP submitted its response to the DFAR and requested an audit hearing on July 26, 

2011. On August 31,2011, CDFP presented certain matters at an audit hearing before the 

Commission. 

Finding 1. Net Outstanding Campaign Obligations 

CDFP did not mention this matter in its response to the DFAR or during the audit hearing. 

The Audit staff recommends that the Commission find that the Candidate did not receive 

matching fund payments in excess of his entitlement. 
Finding 2. Receipt of Prohibited Contribution and Contributions that Exceed Limits 

A. Receipt of Prohibited Contribution 

In its response to the DFAR and during the audit hearing, CDFP stated there was no 

sound basis for a finding that it received a prohibited contribution from the 

hitemational Association of Firefighters (lAFF). CDFP stated the following factors 

for the Commission's consideration. 

First, CDFP believes the amount in question should be $12,088, not $15,423, since 

this was the amount billed to CDFP. Second, CDFP contends the billing was actually 

not from the union itself, but rather the union's separate segregated fund, FIREPAC. 

Although it is uncertain, CDFP suggested that the invoice may have been printed on 

the lAFF's letterhead and presented as an agreement between the union and CDFP 

because the union handled the administrative functions of its separate segregated fimd. 

Third, CDFP noted that it eventually overpaid FIREPAC out of an abundance of 

caution and that FIREPAC appropriately reported a debt owed by CDFP and 

subsequently deposited CDFP's payment into its account. Finally, CDFP took 

exception to language in die DFAR that CDFP "did not consider the resolution of the 

contribution a high priority obligation." 

The Audit staff offers the following conceming CDFP's response to the DFAR and 

comments presented at the audit hearing. The Audit staff maintains that the amount of 

the prohibited contribution is $15,423. At the time the RV rental costs were incurred, 

the lAFF paid for the RV rental cost on behalf of CDFP, thereby giving something of 

value to CDFP, namely, the RV rental cost that CDFP should have paid. CDFP 

eventually repaid the lAFF for the RV rental cost, more than a year and a half from the 

invoice date. Therefore, the value of the prohibited contribution should be the 

ordinary market cost of renting the RV and not the pro-rata amount of $12,088. 

With respect to the question of whether the union or FIREPAC billed CDFP, the Audit 

staff provides the following information. First, the lAFF billed CDFP for use of the 

RV. The invoice was printed on the lAFF's letterhead and includes language that 

indicates an agreement between the lAFF and CDFP for the RV's usage. The only 

mention of FIREPAC is regarding payment. As such, in subsection "1. Facts" of 

section "A. Receipt of Prohibited Contribution" (page 10); more detail regarding the 

invoice from the lAFF will be included in the audit report. Specifically, the Proposed 

Final Audit Report (PFAR) will state that the invoice was printed on the lAFF's 

letterhead and include CDFP's explanation presented at the audit hearing that the 

invoice was printed on the lAFF's letterhead since it handled the administrative 

functions of FIREPAC. 

Conceming CDFP's payment to FIREPAC for use of the RV, the Audit staff notes 

that the DFAR clearly acknowledges that CDFP eventually overpaid $32,233 to 

FIREPAC for the rental and wrapping associated with the RV and further details 

FIREPAC's reporting of the debt, as well as the timing of CDFP's payment (DFAR, p. 

11). It is the Audit staffs opinion that CDFP accepted a contribution from a labor 

organization and repaid the amount more than a year and a half after the invoice date. 
Finally, in regard to the language that CDFP "did not consider the resolution of the 

contribution a high priority obligation," (DFAR, p. 12), the Audit staff concurs with 

CDFP and the sentence in question will be removed from the PFAR. 

The Audit staff recommends that the Commission find that CDFP received a prohibited 

contribution of $15,423 from the lAFF. 

B. Apparent Excessive Contributions from Other Political Committees 

CDFP did not offer any comments in its response to the DFAR or at the audit hearing 

regarding this portion of the finding. 

The Audit staff recommends that the Commission find that CDFP received excessive 

contributions from other political committees totaling $44,300. 

C. Receipt of Excessive General Election Contributions 

In its response to the DFAR and during the audit hearing, CDFP mamtained that the 

audit report should make clear that, for the bulk of the excessive contributions, CDFP 

timely obtained redesignations and issued refunds. CDFP continued to assert that this 

finding arose from an audit error and this resulted in language being removed from the 

DFAR, which previously had been included in the Preliminary Audit Report. 

CDIFP stated that it transferred all its general election contributions to the Candidate's 

Senate campaign. Friends of Chris Dodd (FOCD). hi addition, CDFP stated that the 

DFAR incorrectly stated (1) that it had not provided the required redesignation letters 

necessary to transfer the excessive contributions, (2) that it resolved excessive 

contributions of $160,050 in an untimely manner and (3) that contributions of 

$173,210 have not been transferred to FOCD. 

The Audit staff agrees that the disposition of the excessive contributions could have 

been presented in a more precise manner in the DFAR. As such, in the PFAR, the 

Audit staff will modify the summary on page 4 (Part III - Summaries) and page 9 (Part 

IV - Findings and Recommendations) to provide a more precise presentation of 

excessive contributions that have been resolved by CDFP and of excessive 

..contributioos that stilt require resolution. Specifically, the Audit staff will clarify that 

of the $51,000 in excessive contributions from other political committees, $4,800 

remains unresolved and of the $244,050 in excessive general election contributions 

received by CDFP, only $7,100 remains unresolved. Also, the Audit staff will remove 

footnote 10 (DFAR, p.13) in the PFAR. 

CDFP took exception to the Audit stafTs statement that certain documentation "was 

not previously available." Although the Audit staff made copies of the documentation 

provided during audit fieldwork, it is acknowledged that the language in the DFAR 

may not be a fair representation of CDFP's efforts to respond to the Preliminary Audit 

Report recommendations. Therefore, the Audit staff will remove the language in the 

PFAR. 

Regarding CDFP's assertion that the DFAR incorrectly presented excessive 

contributions' of $160,050 as resolved in an untimely manner, the Audit staff has 

modified the finding to more accurately reflect CDFP's resolution of some excessive 
contributions. Specifically, excessive contributions totaling $144,950 previously 

categorized as resolved in an untimely manner have been re-categorized as resolved in 

a timely manner. The Audit staff and OGC concur that CDFP's action with respect to 

these refunds was made in accordance with guidelines outlined in Advisory Opinion 

2008-04. 

CDFP also claims that the DFAR incorrectly states that contributions of $173,210 

have not been transferred to FOCD. CDFP has provided the necessary redesignation 

letters for these contributions and, as a result, the Audit staff will remove footnote 11 

(DFAR, p. 14) from the PFAR. ' 

The Audit staff recommends that the Commission find that CDFP received excessive 

general election contributions of $241,950 ($244,050 less a contribution of $2,100 that 

CDFP demonstrated was not excessive), of which all but $7,100 have been resolved. 

Finding 3. Misstatement of Financial Activity 

After consideration of CDFP's response to the DFAR and its comments during the audit 

hearing, the Audit staff will clarify in the PFAR that CDFP's net realized losses of 

$150,370 should be reported on Schedule A-P (Itemized Receipts), Line 21 (Other 

Receipts) as a negative receipt. 

The Audit staff recommends that the Commission find that CDFP misstated its financial 

activity for 2008. 

If this memorandum is approved, a Proposed Fmal Audit Report will be prepared within 

30 days of the Commission's vote. . 

Should an objection be received, Durective No. 70 states that the Audit Division 

Recommendation Memorandum will be placed on the next regularly scheduled open 

session agenda. 

Documents related to this audit report can be viewed in the Voting Ballot Matters folder. 

Should you have any questions, please contact Kendrick Smith or Alex Boniewicz at 694-

1200. 

Attachments: 

- Draft Final Audit Report on Chris Dodd for President, Inc. 

- Office of General Counsel Analysis (ADRM) Receiveid on November 18, 2011 

- Office of General Counsel Analysis (DFAR) Received on May 24,2011 

cc: Office of General Counsel 
Draft Final Audit Report of the 

Audit Division on 

Cliris Dodd for President, Inc. 

January 24, 2007 - September 30, 2008 

Why the Audit 

Was Done 

Federal law requires the 

Commission to audit every 

political committee 

established by a candidate 

who receives public funds for 

the primary campaign.' The 

audit determines whether the 

candidate was entitled to all 

of the matching funds 

received, whether the 

campaign used the matching 

funds in accordance with the 

law, whether the candidate isf • 

entitled to additional jt^r/ 

About the Committe<^. 2) 

Chris Dodd for President, Inc^^^^e* principal campaign committee of 

Christopher J. Dodd, a canditliEtte|for the Democratic Party's nomination for 

the office of President of^tneJ^iteaiStates. The Committee is 

headquartered in W^^amord, Connecticut. For more infonnation, see 

chart on the Campaiign'Organization, p>2S^'K 

^^^^ 

Financial Aj^ivity (p.3) 

matching funds, and wtiiel^er^ 

o 

o 

Receipts 

0/.i:4[:,Contributions fro^!b1|Mduals 

o^^lSdntributions from^lPoli^ical Committees 

o \TFahsfeiis>from Affiliated^Committees 

Loans Received 

Matehing lMijnds|Receive^ 

Offsets^Jto Operaiiiig^xpenditurek 

Other ReWpte> ""'' ^ 

HjfkalReceipi^P^^ 

the campaign otherwise | M 

complied with the Umitationsi^||^ j^^ ^ 

prohibitions,,^add'disii|lbju^ 

requirement^..6f^i£fe^ele^^^^^^ 

law. ^"Z€ ^-^^' 

Mi4i^s^ QperahneExL-

^^^^ T ^^^ ^ 

Loan Rqpaymf nts 

res 

Future Action 

The Commission riiayjinitiate 

an enforcement action^at^a 

later time, with respect tS^y^ 

of the matters discussed in^^^ 

this report. 

^^^ransferslo^'ther Authorized Committees^ 

!k o^^ntribution Refiinds 

Tota^Sisbursements 

m 

I^IIidings and Recommendations (p. 4) 

..... 

et Outstanding Campaign Obligations (Finding 1) 

Receipt of Prohibited Contribution and Contributions 

that Exceed Limits (Finding 2) 

Misstatement of Financial Activity (Finding 3) 

$ 9,848,996 

750,402 

4,632,357 

1,302,811 

1,961,742 

127,012 

47,506 

$ 18,670,826 

$ 14,978,850 

1,302,811 

507,910 

1,365,901 

$ 18,155,472 

• 26 U.S.C. §9038(a). 

^ This represents the transfer of general election contributions redesignated to the Candidate's Senate 

committee, Friends of Chris Dodd. 
Draft Final Audit Report of the 

Audit Division on 

Chris Dodd for President, Inc. 

January 24, 2007 - September 30, 2008 

^^^^ 
Table of Contents 

Part I. Background 

Authority for Audit 

Scope of Audit 

Inventory of Campaign Records 

Part II. Overview of Campaign 

Campaign Organization 

Overview of Financial Activity 

Part III. Summaries 

Findings and Recommendations j | 

Summary of Amounts Potentially OweS io the U.S. Treasury 

Part IV. Findings andy^comme^^^ipns 

Finding 1. Net Outstanding i^^^g n Obligatioi^ 

Finding 2. Receipt of Prohibi^^Bl^^^on and 

Contributions that Exteed I^^^; 

Finding 3. Misstat^^ientof Fman6m.ActiviM 

Page 

8 

15 
Part I 

Background 

Authority for Audit 

This report is based on an audit of Chris Dodd for President, Inc. (CDFP), undertaken by 

the Audit Division of the Federal Election Commission (the Commission) as mandated 

by Section 9038(a) of Title 26 ofthe United States Code. That section states "After each 

matching payment period, the Commission shall conduct a thorough examination and 

audit of the qualified campaign expenses of every candidat^^d his authorized 

committees who received [matching] payments under s^ecjtipn 9037." Also, Section 

9039(b) ofthe United States Code and Section 9035jJiai^.of the Commission's 

Regulations state that the Conunission may conduc^oiSei^xmmnat^ and audits from 

time to time as it deems necessary. 

Scope of Audit 

This audit examined: 

1. 

2. 

3. 

4. 

5. 

6. 

7. 

8. 

The receipt of excessive contributions and lB;^s^ 

The receipt of contributions c^oin, prohibited s6urcS|iv 

The receipt of transfers from^tejfiaujhonzed comm>ttees. 

The disclosure of contributionsl^o'dM^fers receive^^ 

The disclosure of disbursementsMeJbts atiii^^jgations^^ 

The recordkeepingp^cess and coMleteness';^^^^ 

The consisten^qy^oetweei^^ figures Md^^ 

The accuracMfiie Stat^i^t of NettmpSicling CaSptign Obligations. 

9. The campaign's^^lon^pliancefiwith spendii^g^imitations. 

The^^u4it staff routinel^pnduq^n inventory of campaign records before it begins the 

audit fi6id\^(ork. CDFP'S^cords '^^e.jmaterially complete and the fieldwork began 

immediate^ ^fl , 
Part II 

Overview of Campaign 

Campaign Organization 

Important Dates 

• Dateof Registration January U#Qj97 

• Eligibility Period Noveisi^pS; 2007 - January 3,2008' 

• Audit Coverage Janiii^^f:iPP7 - September 30, 2008* 

Headquarters j. ll^st Hartford,tt)1mecticut 

M 

Ban r k Information ^ 

• Bank Depositories 

• Bank Accounts di^h#^ig, two investmlSlI^ 

"^^^ ^ 

Treasurer ^^'"'^^fei? 

• Treasurer When Audit Was ConducW^^, ^ IfefluynDMIto 

• Treasurer During Perit^Idoyered by M^it K^®l,Pamltpl:i 

Management InformMpn "^Mc 

• Attended FEC Cani^likn Fina^l Seminar '% 

• Who Handled AccourTdnl^ani^^S^lw 

RecordkeeliyiifKi'Tasks ^^K^ "^^^J*. ^^^^^ ^ 

^ The period during which the candidate was eligible for matching funds began on the date of certification ofhis 

matching fimd eligibility and ended on the date the candidate announced his withdrawal from the campaign. See 

11 CFR §9033. 

* Limited reviews of receipts and expenditures were performed after September 30,2008, to determine whether the 

candidate was eligible to receive additional matching funds. 
Overview of Financial Activity 

(Audited Amounts) 

Cash-on-hand ® January 24,2007 $ 0 

o Contributions from Individuals $ 9,848,996' 

o Contributions from Political Committees 750.402 

o Transfers from Affiliated Committees 4.632.357 

o Loans Received 1.302.811 

o Matching Funds Received 1.961,742** 

o Offsets to Operating Expenditures .^^ ^ 127.012 

o Other Receipts 47,506 

Total Receipts ^ " W mi8,670,826 

o Operating Expenditures ^ » MS^978.850 

o Loan Repayments r wmsn 

o Transfers to Other Authorized Committee'^^l 

o Contribution Refunds ''^^ Ik. 1.365m. 

Total Disbursements ^ ^ $ 18,155,47m 

Cash-on-hand @ September 30,2t|^^T. $ 515,354 ^ 

Approximately 25,000 contributions from more than 19,200 individuals. 

As of September 30,2008, CDFP had made four matching fimd submissions totaling $ 1,999,514 of which 

$1,961,742 was certified by the Commission and paid to CDFP. This represents 9 percent of the maximum 

entitlement ($21,025,000) a 2008 Presidential candidate could receive. 

This represents the transfer of general election contributions redesignated to the Candidate's Senate committee. 

Friends of Chris Dodd. 
Part III 

Summaries 

Findings and Recommendations 

Finding 1. Net Outstanding Campaign Obligations 

As part of audit fieldwork, the Audit staff reviewed CDFP's^fmancial activity through 

December 31,2010. The review indicated that the Candidate.jdid not receive matching fimd 

payments in excess ofhis entitlement. In response to^€^i|reliminary Audit Report, Counsel 

for CDFP (Counsel) did not dispute this finding, but(^^9 tii¥$!m regard to the general 

election contributions maintained in an investmenf account, the'basis value ofthe investment 

account, not the fair market value, should have^«eif utilized in valiiainon. 

(For more detail, see p. 6) w^ct 

Finding 2. Receipt of Prohibitedlb^^ll^tion 

Contributions that Exc^dLLimits 

Dunng A-.j.. J -11 —^^..j.. . 

committees. The review identified a pfohimtHd^contributiofl^f $15,423 from the Intemational 

Association of Firefighters (lAFF), as ^V.^as $5=^^|^Jn exce^|iye contributions from other 

political committees.^The^j^i^hibited coniribution fr^^lbjeJAFl^^ from the rental of a 

bus/recreational vehicl^'TijRVy*^^^^ to^i;Hentifj^;^ibnafe campaign. 

The RV was proviSedSp CDFP fp^its use jus^rijsr to the lo'wa caucus. CDFP resolved this 

prohibited contribution,!:but in an^timely maii^.r. The excessive contributions from other 

political committees we^eijimresOiVfeS.^^ 

In additioiifa review-of^enersiMection c^tnMtiohs indicated that CDFP received 

contribiutions totaling $2^^;Q50 f6!|which it has not obtained the required redesignation letters 

necessafy^tb^liansfer these'limds to i^^^andidate's Senatorial Committee, Friends of Chris 

Dodd (FOCbpKCDFP did n|i%iake a^f^priate refimds, either. 

In its response ta-tbe^]Prelimin^|Audit Report, Counsel maintained that: 

• CDFP had ribt^iteceiy^d^f prohibited contribution from the lAFF; 

• regarding the SSfj^Op^ in excessive contributions from other political committees. 

Counsel demonstrated that contributions totaling $6,700 were not excessive, provided 

copies of negotiated refimds checks for excessive contributions totaling $39,500, and 

provided non-negotiated refimd checks for the remaining $4,800; and, 

• with respect to the $244,050 in general election excessive contributions, 

documentation that Counsel provided demonstrated excessive contributions totaling 

$234,850 had been resolved, a contribution of $2,100 was not excessive and excessive 

contributions totaling $7,100 remain unresolved. (For more detail, see p. 8) 
Finding 3. Misstatement of Financial Activity 

During audit fieldwork, a comparison of reported figures with bank records revealed that 

CDFP understated its receipts by $355,240 and overstated its disbursements by $190,935 in 

2008. In response to the Preliminary Audit Report, CDFP amended its reports, but excluded 

an adjustment relating to net realized investment losses. As a result, receipts for 2008 remain 

misstated. (For more detail, see p. 15) 

Summary of Amounts Potentially Owed to the 

U.S. Treasury 

Finding 2 Receipt of Contributions thatj^ceed 

Limits - Unresolved 

$ 11,900 
Part IV 

Findings and Recommendations 

I Finding 1. Net Outstanding Campaign Obligations 

Summary 

As part of audit fieldwork, the Audit staff reviewed CDFP's financial activity through 

December 31,2010. The review indicated that the Candidate^'d not receive matching fimd 

payments in excess ofhis entitlement. In response to the^^liiminary Audit Report, Counsel 

for CDFP (Counsel) did not dispute this finding, but ^gt^^L in regard to the general 

election contributions maintained in an investment aQC^u^, tMbasis value of the investment 

account, not the fair market value, should have be'^oitilized in vMuation. 

Legal Standard 

A. Net Outstanding Campaign Obligations^^^CO). ^f^i n 15 daysi^^fa^ the candidate's 

date of ineligibility, the candidate must subii^S^^tem^^of "net outs^^J^ing campaign 

obligations." This statement i^^|contain, amon|p>.i^^fhings: 

The total of all committee alsetsliheluding casmidmhand, amounts owed to the 

committee and capital assets liited^at^their fair mark^alue; 

The total of all outstanding oblig^ons^f(^^uaUfie ———ipaig d c n expenses; and 

An estimate of.^^^^a^ windin]^own co^^^^pF 

^•^^ 4. 

ents afti^^p<^of IneiiglBility. If, on the date of 

B. Entitlement ttiifMatching 

ineligibility, a cah^ate has niioutstandinj^ampaign obligations as defined under 11 

CFR §9034.5, that caii^i^^^^;^|^nue t^^^eive matching payments provided that he 

or shefi|tiiTlLi^^>net outs^^in^ampd]p]isdebts|on the day when the matching payments 

are^iiiadi:Tr#J:§9033^if • 

Facts'' ai^d Analysis 

A. Facts ""^^1 

The Candidate's^l^Steof ineligigHdty (DOI) was January 3,2008. As part of audit fieldwork, 

the Audit staff reviet^eJ|CDjp||^financial activity through December 31,2010, and prepared 

the Statement of Net OUtsts^ding Campaign Obligations that appears on the next page. 
Assets 

Chris Dodd for President, Inc. 

Statement of Net Outstanding Campaign Obligations 

As of January 3,2008 

Prepared through December 31,2010 

Primary Election Cash in Bank 

General Election Cash in Bank 

Accounts Receivable 

Capital Assets 

Total Assets 

$ 271,389 

1,706,575 

46,899 

8.407 

Liabilities 

Primary Election Accounts Payable 

General Election Accounts Payable 

Loans Payable 

Winding Down Costs: 

Actual 1/4/08-12/31/10 

Amounts Payable to U.S. Treasury for: 

Unresolved Excessive Contributions (See'^^din^!^^! if 

Total Liabilities 

Net Outstanding Campaign OblijpBons (Defieiji^fa^f Januar}^^2008 

Footn6tes^=t6^N©CO StafeBSiiati 

$2,033,270 

[a] ^d^msure that the n'l^ticuefimd^^firal election^ohtributions had no impact on matching liind 

einU^ment, the Audit sia-j^djusteo^m to match the general election cash in bank amount. 

Pri^^^I, CDFP rece^^generai^etion contributions of $1,749,670; however, at DOI, the fair 

market^arae of the investm^^ccountl^phich these contributions were maintained was $1,706,575, a 

lossof$43lfe. 

[b] Estimated windini|'j|c)wn co^^e not included above because this would only increase the deficit. It is 

likely that CDFP iltsltilUnpui|ing minimal salary and legal expenses. 

[c] This amount does not include $7.100 in unresolved excessive general election contributions. 
Shown below are adjustments for fimds received after January 3,2008, through July 17,2008 

(the date ofthe last matching fimd payment): 

Net Outstanding Campaign Obligations (Deficit) as of 1/3/08 ($2,824,891) 

Private Contributions and Other Receipts Received 1/4/08 

through 7/17/08 

503,712 

Matching Funds Received 1/4/08 through 7/17/08 1,961.741 

Remaining Net Outstanding Campaign Obligations 

(Deficit) as of 7/17/08 

($359,438) 

As presented above, CDFP has not received matching fimdjpa>ninents in excess of its 

entitlement. ^i^tS^V 

B. Preliminary Audit Report & Audit Division^Recommendinion 

The Audit staff presented the NOCO to CDFP^rf^p^sentatives at th^^exit conference. In 

response, CDFP did not address the NOCO.f 

^^^^^v , ^ ^^^^ ^ 

In the Preliminary Audit Report, the Audit staff r^Ciommendeakhat CDFP demonstrate 

whether an adjustment(s) was requifed^to any comp(^n|ppthe NOCO statement or provide 

any other comments it desired. ^^'^•^ >eMSat-^ 

C. Committee Response to FreliminWb^ Auoit^Report 

In response to the Prelipm^j\udit Re^k, Couii^|^^not dMv^^ NOCO but stated 

that incorrect amoun^^Y^6!^i^^pated for^|^p^j^pl^c^^l^asfi^in Bank" and "General 

Election Accounts^'ay^ble" beSp^ these fi|u^§^^re gen'eli^d using the fair market value 

instead of the basis value^pf the £il!^unt. Th^vMrther a 

affect the Committee's nelt^financiaj^pp^^^^ it^oignificant in Ught of Findings 2 and 3... 

added that "While this error does not 

In accofdanbew^ staff presented the general election 

investment account at^falr<markei^%lue as of ffii^Candidate's DOI. 

Finding 2; j?>Receipt^bf Prohibited Contribution and 

Contributiosisvthat EiEqeed Limits 

Summary ''^<Z^Zii^ 

During audit fieldwork, Atidit staff reviewed all contributions from other political 

conunittees. The review identified a prohibited contribution of $15,423 from the Intemational 

Association of Firefighters (LAFF), as well as $51,000 in excessive contributions from other 

political committees. The prohibited contribution from the lAFF resulted from the rental ofa 

bus/recreational vehicle (RV) decorated to identify Senator Dodd's Presidential campaign. 

The RV was provided to CDFP for its use just prior to the Iowa caucus. CDFP resolved this 

prohibited contribution, but in an untimely manner. The excessive contributions from other 

political committees were unresolved. 
In addition, a review of general election contributions indicated that CDFP received 

contributions totaling $244,050 for which it has not obtained the required redesignation letters 

necessary to transfer these fimds to the Candidate's Senatorial Committee, Friends of Chris 

Dodd (FOCD). CDFP did not make appropriate refimds, either. 

In its response to the Preliminary Audit Report, Counsel maintained that: 

• CDFP had not received a prohibited contribution from the lAFF; 

• Regarding the $51,000 in excessive contributions from other political committees. 

Counsel demonstrated that contributions totaling $6,700 were not excessive, provided 

copies of negotiated refimd checks for excessive con^^tions totaUng $39,500, and 

provided non-negotiated refimd checks for the remai^^ $4,800; and, 

• With respect to the $244,050 in general election^^^Sve contributions, 

documentation that Counsel provided demon^^^^^^ssive contributions totaling 

$234,850 had been resolved, a contributi^^^^lOo^mnot excessive and excessive 

contributions totaling $7,100 remain uijy^^lved. 

Legal Standard 

A. Authorized Committee Limits. An authoH^^ommitt^may not fe^^j;p more than a 

total of $2,300 per election from am^ne person o^^^^^^pf^lection from^a(^ulticandidate 

political committee. 2 U.S.C. §44r^^" ~ 

110.9. 

i)i[0(A), (2)(A)mff); 11 CFR §§110.1(1) and (b) and 

B. Handling Contributipns That Appear ExceMv^If a committee receives a contribution 

that appears to be excessi^^the. conmiit^^must eiuKI 

• Return the g[u13stionable%n.eck to the§^9^|;^or 

Deposit the c^^into its^^eral accoimpuid: 

o Keep mon^hi the acc^mt>.to cover all potential refimds; 

^^^^^^^ a wntt^^^idl^^^mng v^the contnbution may be illegal; 

^g;i^'^iM|dfe^giis ^^^tion (ffi^edu^ 

befori^^egali^^g^stablishelS 

if the contribution has to be itemized 

Seekaredfi gil^e excessive portion, following the instructions 

^^^provided inltiilComim^^ regulations (see below for explanation of 

^|fee|esignation^d ^ 

n^committ^&es not receive a proper redesignation within 60 days of 

re^^^g the ej^^sive contribution, refimd the excessive portion to the donor. 

11 CMI§ LQ^K)(3), (4) and (5). 

C. Redesignation of Exclusive Contributions. When an authorized candidate committee 

receives an excessive contribution (or a contribution that exceeds the conunittee's net debts 

outstanding), the committee may ask the contributor to redesignate the excess portion of the 

contribution for use in another election. The committee must inform the contributor that: 

1. The redesignation must be signed by the contributor; 

2. The redesignation must be received by the committee within 60 days of the 

committee's receipt of the original contribution; and 

3. The contributor may instead request a refimd of the excessive amoimt. 

11 CFR §110.1(b)(5). 
10 

Within 60 days of receiving the excessive contribution, the committee must either receive the 

proper redesignation or refimd the excessive portion to the donor. 11 CFR §§ 103.3(b)(3) and 

110.1(b)(5)(ii)(A). Further, a political committee must retain written records conceming the 

redesignation in order for it to be effective. 11 CFR § 110.1(1)(5). 

D. General Election Contributions. If a candidate is not a candidate in the general election, 

any contributions made for the general election shall be refimded to the contributors or 

redesignated in accordance with 11 CFR §§110.1(b)(5) or 110.2(b)(5), as appropriate. 

E. Unreimbursed Value of Transportation. The unreimbiu:si^d value of transportation 

provided to any campaign traveler is an in-kind contributio|iffrom the service provider to the 

candidate committee on whose behalf the campaign traveliPlveled. 11 CFR § 100.93(b)(2). 

F. Payment of Transportation. If a campaign trayeler-usesi smy^^^ means of 

transportation, with the exception of an airplane^^^campaign conooiiittee on whose behalf the 

travel is conducted, must pay the service pro^l^^'Within 30 calendair^^j^s of the date of 

receipt of the invoice for such travel, but not'l|[t^r than 60 calendar daystafter the date the 

travel began. 11 CFR § 100.93(d). '^^^ 

G. Receipt of Prohibited Contribution from Labo^p|ganizations. Politiciail campaigns 

may not accept contributions made%^i^ei.general tre&ury fimds of labor organizations. 2 

U.S.C. §441b. ^^'-^ ^''"^ 

Facts and Analsrsi^C 

A. Receipt of Prdliibited Contribution 

1. FaiCfe ^ 11 

DuringaM^ldworS,^the§^u^^^ CDFP was billed $12,088 on February 

12^^2008, by tBiiiMematiMal^As Fighters for a share ofthe rental cost of 

an|R.Y. The RV wa#^nted^l|vperiod off 8 days from November 18,2007 to January 

Qg^t was decoi^^to identi|/Senator Dodd's Presidential campaign. The invoice 

from'SiWp indicatedf^at CDFPl|sed the RV for 18 days in December 2007, through 

the dateW^ilri^ligibility. "fliBi^cost was prorated using a daily rate. The total cost of the 

rental for t^e-^B: days wasp|2,233, with $15,423 attributed to the cost ofthe vehicle and 

$16,810 to the c^t. of ",^^^ping" it to identify the campaign. The invoice requested that 

payment of $12,08i8i:^1^^'^lide within 60 days to the Intemational Association of 

Firefighters InterestelMn Registration and Education PAC (FIREPAC), a separate 

segregated fimd of the LAFF. 

In its December 2007 monthly report, FIREPAC disclosed making an independent 

expenditure* on November 28,2007, in support of Dodd for "RV Art & Wrapping" in the 

amount of $16,810. When questioned, CDFP representatives stated that the LAFF 

initially paid for the RV to use as transportation to events involving commimications with 

the lAFF's restricted class. They stated that FIREPAC paid to wrap the RV because it 

FIREPAC reported independent expenditures of approximately $374,000 in support of CDFP. 
11 

was a communication expressly advocating Senator Dodd's presidential candidacy, 

which had not been coordinated with CDFP. CDFP later sought to determine whedier it 

could obtain the use of the wrapped RV from the lAFF for its own purposes. The lAFF 

made the RV available and CDFP used it just prior to the Iowa caucus. As mentioned 

above, the invoice was for a portion of the cost ($12,088); however, CDFP paid the entire 

RV rental and wrapping cost of $32,233. It should also be noted that CDFP's payment 

occurred more than one-and-a-half years after the invoice date. After reporting the 

independent expenditure, FIREPAC disclosed a debt owed by CDFP in its March 2008 

monthly report for the fiill cost of the RV ($32,233) and continued to report this debt 

until it reported the reimbursement in its December 2009^onthly report^. 

2. Preliminary Audit Report & Audit Division^^STiifmendation 

In response to a discussion of this issue at the ex^^mf^i^e, CDFP representatives 

provided a copy ofa reimbursement check, da^^^ob^^^j2009, to lAFF FIREPAC 

for $32,233. CDFP representatives stated j^^DFP paid Ix^for the use ofthe bus and 

the cost of the wrap to avoid receiving ai^iMkind contribution ^i|i|rcspons ^ e to other 

inquiries from the Audit staff, CDFP re^^^tatives stated that iF>^Jtieir understanding 

that the lAFF paid the rental cost ofthe busi^at the same bus wrappl|:g>was utilized by 

both the lAFF and CDFP; and, that they are iKawacdplany other ex^^ses that were 

paid by FIREPAC relating to^^iise or wrap or^ ^ after CDFP acquirla its use. 

The Audit staff acknowledges tfinhe'^^3^i^nt of $3Z'^^by CDFP was an attempt to 

rectify this matter. However, the^ntal pOTl^^f the R\^j^st ($15,423), apparently paid 

by the LAFF, appears^^Mbe^a prohibi 

-^^^^- ^ politicJ^na^ra^^ntiJSutio^ was resolved in an 

uui^r a^a result oi^^^lmbursenifem made to FIREPAC, noted 

above. 

contnbutiibnKLaboi^gamzations are prohibited 

from making cQp|nbution^^olitical^a||ig^ 

untimely mannMlHy CDFP^^a result oi^^pilmbursenK 

In the^Pceliniiin 

documentatioh 

.LBport, thli^udit sta^recommended that CDFP provide 

j^i^onstrati^^diat it d^^^;eceive a prohibited contribution of $15,423 

from^the lAFF, incIMlng docimientation to Verify that the lAFF did not pay for the rental 

portidj^pftheRV. 

3. Comni^^ Responsi^^ Preliminary Audit Report 

CDFP's resp^e did notjl^lude any additional documentation. However, Counsel 

maintained that^dbFP csffl^t be found to have received a prohibited contribution when it 

was directed (on thi^^p^'s invoice) to pay FIREPAC and it simply complied. In 

addition. Counsel sta^that even if CDFP should have paid the lAFF, the 60-day 

timetable in 11 CFR §100.93 should not apply because it applies only to non-commercial 

forms of transportation. Counsel maintained that "the primary purpose of the wrapped 

bus was not to transport people from place to place, but rather to serve as an unusual 

form of campaign visibility, like the C-SPAN bus or the Ron Paul blimp." Analyzed in 

this manner. Counsel believed the proper question was whether the campaign paid for the 

use of the bus within a commercially reasonable time (Counsel cited 11 CFR §114.9(d) -

' A reimbursement from CDFP was inadvertently deposited into its non-federal account. The subsequent 

transfer was reflected on the year-end report. 
12 

Use or rental of corporate or labor organization faciUties by other persons). Counsel 

further added that the circumstances that led to the delay in payment were not adequately 

considered. The response stated that while the payment remained outstanding, CDFP 

was in a deficit position with many competing obligations that it sought to manage as 

best it could. Counsel maintained that CDFP chose to pay the fiill cost of the bus rental 

and wrap, in an abundance of caution, even though there was a strong argument that it 

could have paid less. 

Regardless of whether the payment for the use of the RV is considered under 11 CFR 

§100.93 - use of non-conunercial forms of transportationpr 11 CFR §114.9(d) - use of 

corporate or labor organization facilities, reimbursemenj|w;^ not made within a 

commercially reasonable time. 

CDFP's possible financial difficulty after the canipaign do^s^not excuse its acceptance of 

the contribution or explain why CDFP did n^Cponsider res6lution of the contribution a 

high-priority obligation. 

Finally, CDFP's decision to pay the entiri^^tal cost of^the RV does^qtnegate the fact 

that CDFP received a contribution from a lab6r|}rganizMion that it failed^tp^resolve 

timely. 

B. Apparent Excessive Contributions frl^Qther Poli^al Committees 

1. Facts 

During audit fieldwol^k, fh^Audit s ^i^^^''$5%:-^^ii apparent excessive 

contributions fc^m^ther pdl^al comiH^^l^hich remained unresolved. The 

contributions inclu%i4: 

• i&MJotalm^llsJfM^^lh^bee^pid^ refimded by CDFP; however, the 

A* lelmdiChecks n%^^cleared account. As such, these remained 

unresolvei^^xcessi^^^tribution^^ 

"^•?:-5^0ne for $4,0i!6^or wl^^^DFP presented a timely, completed redesignation 

*v%letter. Howe^&^^DFP i*^ ^ transferred the contribution to FOCD, nor 

^rj^lgded it. It was^oted ^^b-ansferring the fimds to FOCD would have 

resolved this issue,t«f ^t because the candidate was no longer seeking re-election to 

the Sibffate. the traiMer may not be plausible. The Audit staff considered this an 

unresolv^dliexcessiyjs contribution. 

• Thirteen ex&:^^si|e contributions totaling $39,000 for which CDFP had failed to 

provide any evidence of a refund or redesignation. 

2. Preliminary Audit Report & Audit Division Recommendation 

At the exit conference, the Audit staff provided a listing of these excessive contributions. 

Counsel did not address these contributions in its response. 

In the Preliminary Audit Report, the Audit staff recommended that CDFP provide 

documentation demonstrating that it did not receive excessive contributions. Such 

documentation was to include evidence ofa transfer to FOCD for the contribution that 

had been redesignated but not transferred, copies of refund checks negotiated in a timely 
13 

manner, or redesignation letters signed and dated in a timely manner. Absent such 

documentation, the Audit staff recommended that CDFP make appropriate refimds to 

contributors and provide evidence of such actions (copies ofthe front and back of 

negotiated refund checks) or make a payment of $51,000 to the U.S. Treasury. 

3. Committee Response to Preliminary Audit Report 

In response to the Preliminary Audit Report, Counsel provided documentation 

demonstrating that three contributions totaling $6,700 were not excessive. For the 

remaining 14 contributions totaling $44,300, refund checks dated November 30,2010, 

were submitted. 

Afier consideration of CDFP's response, the Auditg^nioted that three contributions 

totaling $6,700 did not exceed the limits, 12 tots^^p^^^O were refunded in an 

untimely manner, and two totaling $4,800 reinai^piresokejijmtil evidence is provided 

that the refimd checks have been negotiat^^piCDFP is una^^ provide such 

evidence, the Audit staff recommends tha]|^y unresolved exd^s^^ contributions be 

disgorged to the U.S. Treasury. 

C. Receipt of Excessive General Election ContFtbuli«ii^ 

^' . • K 

During audit fieldwork, the Audit^^idtV i.^^fied con^ti^^ons designated for the 

General election totaling $244,05'S'^^r wMl^^FP did^^ provide the required 

redesignation letteFsJ|^,|,ssary to trs^^r the ^^|<to FOCI^Mn accordance with 

Advisory Opink^^^S^l^^O), CD^^£^^M^^sm Ofreceipt ofthe AO (dated 

September 2, to obtai^predesignatii^l^^make refiilhs. Even if CDFP had 

obtained the reqiii^dj^edesi^tion letteil&^acked the fimds to complete the transfer or 

refimd at the time. 1£%Au^^ta£^conside^e^\these imresolved excessive contributions 

ih'fffireUminaiy^^it R^^^!& Audit Division Recommendation 

At thejexit conference^^e Audit^^taff provided CDFP representatives with a schedule 

outlining'these excessiv^^ontributi^s. In its response. Counsel maintained that CDFP 

had propii^i^^refunded alljiili general election contributions. In the Preliminary Audit 

Report, the^A^it staff recffimended that CDFP provide documentation demonstrating 

that these contri^utionsj^i^ not excessive. Such documentation was to include copies 

of timely negotiatl^^^^^checks or timely signed and dated redesignation letters. 

Absent this documehli|ti^, the Audit staff directed CDFP to make appropriate refunds to 

contributors and provide evidence of such actions (copies of the front and back of 

negotiated refimd checks) or make a payment of $244,050 to the U.S. Treasury. 

3. Committee Response to Preliminary Audit Report 

In its response to the Preliminary Audit Report, Counsel maintained that, upon receipt of 

the Preliminary Audit Report, of the $244,050 in asserted unredesignated and unrefimded 

*° The Audit staff also noted that CDFP transferred general contributions ($67,800) to FOCD for which 

redesignation letters were not provided and has redesignation letters for $98,410 in contributions to be 

transferred, but insufficient fimds to do so. 
b. 

c. 

14 

contributions, only $14,900 awaited refund or disgorgement. The documentation 

provided by Counsel included: 

a. Copies of 30 redesignation letters, for contributions totaling $74,800, which were 

all completed and signed by the contributors. All the letters requested 

redesignation to the FOCD 2010 primary or general election and were dated prior 

to May 2008. 

A copy of an email confirmation from its receipts processing vendor 

demonstrating that it had processed a refimd of a $2,300 contribution on 

September 13,2007. 

A copy of a negotiated disgorgement check for aj^tribution of $5,000 and a 

letter sent to the Bureau of Public Debt on Nov^^r 25,2008. Otiier 

documentation stated that the political actioj^^^Littee, which made the original 

contribution, no longer existed. 

A copy of a negotiated disgorgement ch^^^ th^^^. Treasury for $144,950 and 

dated November 30,2010. Counsel^^d that this^^ck was for 82 stale-dated 

refund checks. Counsel provided^i|ck stubs for all ^t^^d checks. From the 

itten on August 

||tiiat the staledated refund checks must be disgorgSdf^n^^^^pbt provide ai^^^opriate basis 

for a finding of excessi^'eontributions^^t^^ey were lawfuUylreceived and 

timely refimded." 

Web page verification fro^tF^^^p,ts processiig^endor demonstrating that a 

$2,100 contribution was retumed ibj^^a|;sufficienj|j^ 

Copies oj^^^^ted refiuS^eck foi 

$7,100^^nf|^^d disg(^W^geglc€mj^800 to die U.S. Treasury for 

contribu^ns that ^^sel state3||l)j!P lacked evilience of refund or timely 

redesignatioii^^All relmd checks dated November 26,2010, and the 

^isgprgemen^icck No\%bcr 30,2010. 

e. 

f. ), foui^ffimd checks totaling 

^^pesult of the|teumcnta^i present^^^ Counsel in response to the Preliminary 

AMit Report, wmcKas n^^^iously available, the $244,050 of general election 

conmutions discuss! m the Pffiminary Audit Report are categorized in the following 

mann^ 

Exce^^contribulicns totaling $160,050 were resolved in an untimely manner; 

Excessiv^^nti'^^Ens totaling $74,800 " were resolved in a timely manner; 

A contribution of $2,100 was not excessive, as it had been retumed for nonsufficient fimds; and. 

Excessive contributions totaling $7,100 remain unresolved. Cancelled check 

copies (front and back) and/or other documentation demonstrating that these 

Based on its response to the Preliminary Audit Report, there are contributions of $173,210 ($74,800 + 

$98,410) for which CDFP provided redesignation letters, but has not transferred to FOCD. As of March 31, 

2011, CDFP's reported ending cash is $14,289. 
15 

remainmg refunds were negotiated should be provided or the amount should be 

disgorged to the U.S. Treasury. 

Finding 3. Misstatement of Financial Activity 

Summary 

During audit fieldwork, a comparison of reported figures with bank records revealed that 

CDFP understated its receipts by $355,240 and overstated its disbursements by $190,935 in 

2008. In response to the Preliminary Audit Report, CDFP an]^|nded its reports, but excluded 

an adjustment relating to net realized investment losses. 4^^^u^t, receipts for 2008 remain 

misstated. 

Legal Standard 

Contents of Reports. Each report must disclos^ 

• The amoimt of cash-on-hand at the beginnin^^d end of the repWihg period; 

• The total amount of receipts for the repo^^period and for the eleclti^cycle; 

• The total amount of disbursements for the repi^ng pe^^and for th^^^on cycle; and 

~ Certain transactions that requi^^emization on S^^^^PA (Itemized Re^^ts) or 

Schedule B (Itemized Disburse^n^ii^ U.S.C. '))(!), (2), (3), (4) and (5). 

Facts and Analsrsis 

A. Facts 

As a part of fieldw^^the Audi^pj^recom^ rcportedalslt^ty with bank records for 2008. 

The following char^Mine t s theMscrepanci^^^the beginning cash balances, receipts. 

disbursements, and the'^^mg ca^^d|^ces. 'i^^ucceeding paragraphs explain why the 

differences^^oiuSrred, if l^^i ^ 

2008xCommittee Jfti^ity 

^ih>i ^k^orted Bank Records Discrepancy 

Opening^^ash Balance 

January it'1^0j8 W. 

$2f4^,560 $ 2,456,875 $ 32,685 

Overstated 

Receipts """^^^jt^ 1 $1,910,177 $ 2,265,417 $ 355,240 

Understated 

Disbursements "^^^^^^ $ 4,397,873 $ 4,206,938 $ 190,935 

Overstated 

Ending Cash Balance @ 

September 30,2008 

$515,970'^ $ 515,354 $616 

Overstated 

The reported ending cash balance is incorrect because CDFP decreased its beginning cash-on-hand by 

$12,949 in its August 2008 Monthly Report and increased beginning cash-on-hand by $527,055 in its 

October 2008 Monthly Report. The unexplained changes in cash may have been an attempt to correct the 

cash discrepancies that resulted from the misstatements of receipts and disbursements. Absent these incorrect 

adjustments by CDFP, the reported ending cash balance at September 30,2008 would have been $1,864. 
16 

The overstatement of opening cash-on-hand ($32,685) resulted from discrepancies that 

occurred in the previous year, 2007. 

The understatement of receipts resulted from the following: 

• Matching fimd payment received 7/17/08, not reported $ 514,173 

• Net realized losses (investment accounts), not reported'^ (150,370) 

• Vendor refund, not reported 5,876 

• Offsets to operating expenditures, not reported 23,954 

• Political committee contributions, not reported 16,100 

• Unexplained difference ^^|^ (54.493^ 

Net understatement of receipts j^w ' $ 355.240 

The overstatement of disbursements resulted from the'^^wijg^ 

• Loan repayment, over-reported ^-1%^^ $(144,757) 

• Disbursements and investment fees, not^^p.6rted 239,950 

• Net errors in reporting payroll and fe6||p' 41,733 

• Transfer to the Candidate's Senate committee, over-j^^orted'^ x"J?>,(351,210) 

• Reported disbursements that actually clcMi&ban^j^B^ '07 s^/|^,(3,300) 

• Unexplained difference ^lir#p^ "^.649 

Net overstatement of disliursj^ents ^ttk $ (190.935^ 

The overstatement of ending cash-on-lismd ($&F6}>esulted Mm^the misstatements described 

B. Preliminary Audit Report'&^udit Diyisioif'Recommendation 

At the exit conferenc^^&e AuditiMff discussed^the misstatement and provided CDFP 

(totalinjgp51,2 i^^^ r^^entativSl^^d^tMCDFP had instmcted its broker to 

transif^Flhe funds to tii^SjCjlCD ai^unt, and tifi^'broker's delay in making the transfer caused 

the repoi|ing discrepancy ^p^e repdlting error could have been avoided if CDFP had not 

reported m^^sfer until t£^|inds w^^ctually transferred. Regarding the reporting of 

operating expdplitures, CDFl|^resen1^ves stated that many operating expenditures were 

not reported be(!l[^^they wer|^aware of the data processing requirements for entering 

debts and obligation|^^us,jh^y debt payments were not disclosed in CDFP's reports. 

CDFP representatives^did'^nlc^i-^ any other discrepancies (noted above). 

In the Preliminary Audit Report, the Audit staff recommended that CDFP amend its reports to 

correct the misstatements for 2008. 

It should be noted that this relates to realized gains and losses disclosed by the brokerage firm as such in its 

monthly statements, which were not reported by CDFP. These net realized losses resulted from the decline in 

the stock market. 

CDFP reported this transfer in September 2008, when it actually occurred in October of 2008. The Audit 

staffs bank reconciliation was done through September 2008. As such, it was reconunended that CDFP 

amend its reports to correctly disclose the transfer in October 2008. 
17 

C. Committee Response to Preliminary Audit Report 

In response to the Preliminary Audit Report, Counsel stated that, after the date of ineligibility, 

CDFP had some difficulty m preparing its reports. Counsel maintained this was due mainly 

to problems experienced in the use of the financial database. Counsel added that this is why, 

for example, CDFP failed to disclose a matching fimd payment received on July 17,2008, and 

over-reported a $144,757 loan repayment. Counsel concluded that CDFP is complying with 

the Preliminary Audit Report's recommendations by filing amendments to correct these 

misstatements. 

Counsel argued that the Preliminary Audit Report "appef 

account's fair market value, which do not need to be re; 

Counsel further added that the Preliminary Audit Report doesi^t correctly present the level 

of misstatement, mainly because of its incorrect treatment o^^FP's brokerage account. 

Ep,#'confuse fiuctuations in the 

^pp^^^ith the actual sale of the 

portfolio assets." Counsel contended that the Preliminjoy Audii Report's treatment of the 

$351,210 transfer of general election contributiq^slSid the $150^3^0 Jn net realized losses 

resulted from this incorrect treatment. 

'lias*. 

In response to the Preliminary Audit Report, CDF^Rfiled ame^ed repoits^jtcfT^calendar years 

2008 and for a portion of 2009. CDFP did not accepMhe/Audit staffs assessment of its 

investment accounts and, as such,4ifduded only a poWoJi^cif the adjustments relating to the 

investment accounts in its amended^^Sli^^Specificd^^se reports did not include net 

realized losses of $150,370 (see secti^«A.'ab^^|). HowevH^}^ not amending its reports for 

the adjustment arising from net realize(i^ses*,%i^p.ts remaii^fru^stated for 2008. CDFP 

materially corrected di^^^tants. 

\^-i\>.- \ 

.•••sev^