RON KIND 

MOVING FORWARD 

July 19 2016 

Re: Response to lAR, Kind for Congress Committee 

To Whom it May Concern: 

The Committee would like to thank the Federal Elections Commission staff throughout this 

exercise for their courteousness and professionalism. We strive to conduct ourselves with the 

utmost transparency, and we are pleased that the results of this audit underscore the importance 

that the Conunittee has long emphasized of ensuring complete transparency of donors. To that 

end, we already go far beyond existing regulations by maintaining a policy of fully disclosing 

ev^ contributor to our Committee, whether or not that contributor meets the $200 itemization 

threshold. 

This audit was a healthy and extensive exercise. We are pleased that this exercise has not 

resulted in any findings of missing funds, lack of disclosure, misappropriations, or any other 

indication of financial or reporting discrepancies, and the Committee recognizes that the only 

finding is that a portion of donations were not deposited to our local financial institution in La 

Crosse, WI in a timely manner. 

With respect to this lone finding, the Committee acknowledges the issue and has proactively 

taken a number of steps to address the finding, which have already fixed the issue. The 

Committee also respectfiilly submits that the statute and PEC rules are unclear with respect to the 

timeliness of deposits - they could easily be read to allow 20 days - but regardless, the 

Committee has now taken a number of actions to ensure deposits occur within 10 days.' 

The Committee would also like to note that many of the contributions that took longer than 10 

days to be deposited into our La Crosse, WI financial institution were not received in La Crosse, 

and therefore had to be mailed to the campaign in La Crosse, and then physically deposited. 

Unfortunately, as many Wisconsinites are aware, mail delivery to rural areas has gotten slower 

over the years due to a variety of factors. In fact, rural mail delivery can sometimes take weeks. 

The EEC's one-size-fits-all policy on timeliness of deposits does not take into account that mail 

delivery in rural areas is generally much slower than in big cities or on the coasts. 

* The law provides that '[e]very person who receives a contribution for an authorized political committee shall, 

no later than 10 days after receiving such contribution, forward to the treasurer such contribution." 52 U.S.C. § 

30102(b)(1). Thereafter, FEC rules provide that '[a]ll deposits shall be made within 10 days of the treasurer's 

receipt." 11 C.F.R. § 103.3. Thus, statute and role could be construed to Indicate that a committee has 20 

days to deposit, for any contribution that Is not sent directly to the treasurer. 

205 5th Ave S Room 428 • La Crosse, Wisconsin 54601 • Phone 608-782-3444 • Fax 608-782-4333 • www.ronkind.oig 

Authorized and Paid for by Kind for Congress, Brent Smith, Treasurer 
PON KIND 

MOVING FORWARD 

Despite the lack of clarity in the law and the additional challenge for rural communities, the 

Committee has already enacted a number of changes to ensure that all donations are now 

deposited in a more timely manner. The changes that we have proactively made include: 

• We have engaged a professional compliance firm to further ensure compliance with all 

applicable rules. 

• Wisconsin staff now make deposits of contributions on a weekly basis, to ensure timely 

deposits of all contributions received in the district. 

• We have a new campaign Treasurer, and campaign staff has received additional training 

regarding compliance rules. 

• When donations are received by campaign staff in Washington, DC, they are now 

deposited directly into a DC branch of our financial institution. This was a suggestion by 

EEC staff, and helps address the challenge of ensuring timely deposits despite the fact 

that rural mail delivery can often take many days or even weeks. 

• In addition to continuing our practice of keeping all records required by EEC rules, see 11 

C.E.R. § 102.9(a), we are keeping all additional records relevant to when contributions 

are received, including envelopes and additional paperwork. 

The Committee is confident that with these changes that have already been implemented, we will 

ensure the timely deposit of all contributions in the future. 

Again, we are pleased that that there were no findings of missing funds, lack of disclosure, 

misappropriations, or any other financial or reporting discrepancies, and we have proactively 

. addressed the single finding to ensure timely deposits. Thank you to the EEC staff for their hard 

work and professional demeanor throughout this extensive process. We look forward to 

continuing to work with the EEC as we go above and beyond the regulations to ensure an open, 

transparent and well-organized campaign committee. 

. Sincerely, . 

Brent. Smith 

Treasurer 

205 5th Ave S Room 428 • La Crosse, Wisconsin 54601 • Phone 608-782-3444 • Fax 608-782-4333 • www.ronkind.org 

Authorized and Paid for by Kind for Congress. Brent Smith, Treasurer