State Chairman 

Vice Chairman 

Treasurer 

Secretary 

National Committeeman 

Charles M. Webster 

Ruth Summers 

William P. Logan 

Charles L. Mahaleris 

Richard A. Bennett 

National Committeewoman )an M. Staples 

Executive Director Michael Quatrano 

WORKING PEOPLE 

»&feREFUBLICAN 

December 23,2011 

Via e-mail and U.S. Mail 

Tom Hintennister 

Assistant Staff Director, Audit Division 

Federal Election Commission 

Washington, D.C. 20463 

Re: Maine Republican Party - Response to Audit Report 

Dear Mr. Hintermister: 

Please accept the following as the response ofthe Maine Republican Party to the 

interim audit report. 

FINDING 1. MISSTATEMENT OF nNANCIAL ACTIVITY 

The MRP has amended its reports from 2007 and 2008 as requested. 

Additionally, the MRP is also amending its most recent filing as requested. 

FINDING 2. REPORTING OF DEBTS AND OBLIGATIONS 

The reports have been amended to accurately disclose the debts. 

FINDING 3. DISCLOSURE OF DISBURSEMENTS 

A. Non-Federal Account 

• Administrative Costs: MRP does not have documentation 

indicating that the identified transactions are solely non-federal 

expenses. The MRP has amended its reports as recommended by 

the audit report. 

Paid for and authorized by the Maine Republican Party, William P. Logan, Treasurer. Not authorized by any candidate or candidate 

committee. Maine Republican Party, 9 Higgins St., Augusta, ME 04330 (207) 622-6247 www.mainegop.com 
Thomas Hintennister 

December 23,2011 

Pagei of4 

Payroll and Associated Costs: The transactions identified in the 

audit report all occurred in die year 2007, during which there was 

no identified federal candidates on the ballot yet. The employees 

ofthe MRP did not spend any time on FEA activity during 2007 

and therefore, these expenses were properly paid as non-federal 

expenses. Based upon discussions with the audit department, it is 

our understanding that the FEC agrees with this. 

Voter Identification: The MRP has amended its reports to disclose 

this expenditure. 

Printed Materials: The MRP was unable to locate documentation 

to clarify that these expenditures were solely non-federal in nature. 

While the vendor has historically provided services related to state 

campaigns, there have been occasions where the vendor has 

provided services that were not solely non-federal. Accordingly, 

the MRP has amended its reports to disclose these expenditures on 

its federal reports. 

B. Federal Account 

GOTV/Public Communications: Some of these expenditures were 

not classified as FEA, but rather as an operating expenditure. I 

cannot determine whether the reason for the misclassification were 

data entry enors or other cause(s). The MRP's reports have been 

amended to accurately report these expenditures as FEA. 

Payroll Expenses: There are no documents showing the amount of 

time, if any, that these individuals spent on federal elections. None 

of these individuals works for the MRP anymore. Since there is a 

lack of documentation conceming the work performed by these 

individuals, we cannot definitively state that they did not perform 

any work on federal elections during the time of the expenditures. 

Accordingly, I have amended to reports to classify these expenses 

as FEA. 
Thomas Hintermister 

Decembqr 23,2011 

Page 3 of4 

Consulting Expenses: All of these expenditures were properly 

classified as FEA. The expenditures were for a consultant to the 

MRP's "Victory 2008" campaign. The Victory campaign efforts 

were primarily concemed with federal elections. 

Travel and Per Diem Expenses: All of these expenditures were 

properly classified as FEA. The expenditures were for the staff of 

the MRP's "Victory 2008" campaign. The Victory campaign 

efforts were primarily concemed with federal elections. 

Equipment and Miscellaneous Costs: A review ofthe Party's 

records does not reveal any documentation describing the use of 

the equipment and miscellaneous costs. I have had discussions 

with Party employees and officers from the time frame in question 

and have been told that the equipment costs were almost certainly 

for outfitting our satellite "Victory" offices. 

Printed Materials. Copies Not Available: The identified expenses 

appear to be FEA. Accordingly, the reports have been amended to 

reflect this. 

Telemarketing Expenses: The MRP has been unable to locate the 

scripts for the telemarketing expenses. Four ofthe transactions 

have a description that indicates that the expenditures should have 

been reported as FEA. The descriptions for five of the transactions 

provide no guidance as to the namre ofthe expenditure. Finally, 

the description of one of the expenditures appears to indicate that it 

was a state-related expense. However, as there is no 

documentation as to the script utilized in the telemarketing beyond 

the descriptions in tiie database, and given that the expenditures 

were made from the federal account, the MRP's reports have been 

amended to disclose these expenses as FEA. 

Coordinated Party Expenditures: The MRP has amended its 

reports to disclose these expeiiditures as coordinated party 

expenditures per the recommendation ofthe audit report. 

FINDING 4. FAILURE TO FILE NOTICES AND PROPERLY DISCLOSE 

INDEPENDENT EXPENDITURES 
Thomas Hintermister 

December 23,2011 

Page 4 of4 

The expenditure in question was an "Absentee Ballot Application Self Mailer" 

which included at least three federal and state candidates on the printed materials. The 

previous Treasurer apparently believed that the mailers qualified for the "slate card" 

exemption. After reviewing the materials in question and the audit report, I agree that 

the additional information contained on the documents removes them fiom the slate card 

exemption. Accordingly, I have amended the MRP's reports to disclose an expenditure 

of $14,150.26 of the expense as independent expenditures supporting Susan Collins and 

$14,150.26 ofthe expense as independent expenditures supporting Charlie Summers. 

The same amount of the expenditure is attributable to John McCain (President) and Sarah 

Palin (Vice-President). However, my reporting software has been unable to pull the 

required information into the correct fields to permit disclosure of those expenditures. 

The software support staff is working on the problem and as soon as it is fixed, I will 

amend the report to disclose those independent expenditures as well. The remaining 

amount ofthe expense is disclosed as FEA. 

In the future, the Treasurer ofthe MRP will provide education and guidance to the 

staff and employees of the MRP as to the mles and regulations sunounding independent 

expenditures. Additionally, a multi-tiered review process for all election-related 

expenditures will be implemented to ensure that more than one set of eyes will review 

any media ads, mailers, or other election-related expenditures before they are made so 

that any future independent expenditure will be recognized and reported in the 

appropriate fashion. Such review will include, but not necessarily be limited to, review 

by the Treasurer and the Executive Director of the MRP. 

The MRP is appreciative ofthe hard work ofthe Commission's audit staff as well 

as the advice and assistance ofthe audit staff throughout this process. If there are any 

questions or any additional information required, please feel free to contact me directly. 

Thank you. 

Sincerely, 

/s/ William P. Logan 

William P. Logan 

Treasurer, Maine Republican Party