104.3(b)(3) and (4), and receive questions from filers regarding acceptable descriptions.
Therefore, in order to provide further guidance to filers and to encourage consistency
between filers, the Commission is publishing lists of additional generally acceptable and
generally unacceptable descriptions.

The Commission does not intend to request that a committee provide additional
information about a purpose of disbursement entry if the committee uses those
descriptions listed below as providing sufficient detail. However, ifa committee uses a
description that is listed as lacking sufficient detail, a RAD analyst may review the report
more closely but the Commission would not automatically take any particular action. In
most instances, the Commission will merely contact the reporting committee and the
committee may then amend its report. In the rare circumstances in which the
Commission deems it necessary to pursue the matter further, the Commission will
conduct a separate review of the sufficiency of the description of purpose to determine
whether it meets the requirements of 11 CFR 104.3(b).

Any future revisions to these lists will be posted on the Commission’s website at

http://www.fec.gov/law/policy.shtml#guidance. Committees with questions can contact

either their assigned RAD analyst (phone: (800) 424-9530 (press 5)) or the FEC
Information Division (phone: (800) 424-9530 (press 6); e-mail: info@fec.gov).
Descriptions of purpose that provide sufficient detail:
> “Salary” for a disbursement to a staff member.
> “Media” for a disbursement to a television or radio communication company.

> “Polling” for a disbursement to a research/communications company.


Voter Contact

Voter Drive

Voter Identification or Voter ID
Voter Registration

Worker

This Federal Register notice represents a general statement of policy announcing
the general course of action that the Commission intends to follow. This policy statement
does not constitute an agency regulation requiring notice of proposed rulemaking,
opportunities for public participation, prior publication, and delay in effective date under
5 U.S.C. 553 of the Administrative Procedure Act (‘‘APA’’). As such, it does not bind
the Commission or any member of the general public. The provisions of the Regulatory
Flexibility Act, which apply when notice and comment are required by the APA or

another statute, are not applicable.

Michael E. Toner
Chairman
Federal Election Commission

DATED
BILLING CODE:


Campaign Material
Charges

Collateral

Collateral Materials
Commission
Compensation (other than committee staff)
Consultant
Consultant-Political
Consulting
Consulting Non-FEA
Consulting Service
Contract

Contract Labor
Contractual Services
Convention Expenses
Convention Services
Costs

Delegate

Delegate Expenses
Design

Discount Fees
Election Day Expense

Entertainment


> “Travel,” “Travel Expenses,” or “Travel Expense Reimbursement” for a
disbursement to a staff member.

> “Printing” for a disbursement to a printing company.

> “Phone Banks” for a disbursement to a vendor providing phone bank services.

> “Dinner Expense” for a disbursement to a restaurant.

> “Catering Cost” for a disbursement to a hotel or restaurant where a fundraiser
was held.

> “Party Fees” or “Party Annual Dues” for a disbursement to a National Party
Committee for their annual dues.

> “Exit Polling,” “Door-to-Door Get-Out-the-Vote,” “Get-Out-the- Vote Phone
Calls,” or “Driving Voters to the Polls” to individuals or vendors contracted
for get-out-the-vote or voter registration activity.

> “Supplies” for a disbursement to an office supply vendor.

> “Consultant-Media,” “Consultant-Fundraising,” “Consultant-Get-Out-The-
Vote,” “Consultant-Legal,” or “Consultant-Polling” for a disbursement to a
consultant or consulting company.

Descriptions of purposes that generally lack sufficient detail:

Administrative Expenses

Admin.

Advance

Bonus

Bounty

Campaign Expense


Meeting Expenses (if to an individual)
Meeting Supplies (if to an individual)
Miscellaneous or Misc.
Miscellaneous Expense

Office Expense (if to an individual)
Office Services

Outside Services

Operating Expenses

Other Expenses

Production

Professional Fees

Professional Fees — Consulting
Professional Services

Promotional Material

Publication

Push Card

Reimbursement

Rendered Service

Services

Services Rendered

State Convention

Supplies (if to an individual)

Voter Bounty


AGENDA DOCUMENT NO. 06-83 L-

> 2:13
FEDERAL ELECTION COMMISSION 10th BEC 13

WASHINGTON, D.C. 20463

December 13, 2006

MEMORANDUM
TO: The Commission
TT
FROM: Chairman Michael Michael E. Toner Jw
Vice Chairma; . Lenhard
RE: “Purpose of Disbursement” Entries for Reports Filed with the Commission

Attached is a draft of a policy statement concerning “purpose of disbursement”
entries for reports filed with the Commission. We request that this document be placed on
the agenda for December 14, 2006.

Attachment AGENDA ITEM
For Meeting of /2-/4-20

SUBMITTED LATE


Event

Event Expense

Event Reimbursement

Event Supplies (if to an individual)
Expenses

Expense Reimbursement

Fees

Fundraising (if to an individual)
Fundraising Event

Fundraising Expense (if to an individual)
Fundraising Fees (if to an individual)
Fundraising Supplies (if to an individual)
General Advice

General Consulting

Generic Campaign Activity

Generic Consulting
Get-Out-The-Vote or GOTV

GOTV Expenses

GOTV Labor

Invoice

Labor

Literature

Meeting (if to an individual)


The Commission recognizes that the “purpose of disbursement” entries, when
linked to information provided about the recipient of the payment, may provide sufficient
disclosure. For example, a disbursement to an office supply vendor for the stated purpose
of “Supplies” provides adequate and acceptable disclosure, while a disbursement to a
committee staff member for the same purpose of “Supplies” would likely trigger a
request for a more complete description of the purpose of the disbursement. In the
former case, it is obvious to the reader what type of supplies were purchased, while in the
latter case, it is not.

As atule of thumb, filers should consider the following question: “Could a
person not associated with the committee easily discern why the disbursement was made
when reading the name of the recipient and the purpose?” For example, a person not
associated with the committee could not easily discern the purpose of a disbursement
made to a vendor for “Consulting” (unless the vendor’s name makes the purpose clear,
e.g., Smith Fundraising Consulting, Inc.). As discussed above, however, if the committee
were to provide additional detail with respect to the type of consulting the vendor
provided (e.g., “Fundraising Consulting”), an unassociated person would have no
difficultly discerning the purpose of the disbursement.

All information on campaign finance reports submitted to the FEC, including the
entries for “purpose of disbursement,” are reviewed by analysts in the Reports Analysis
Division (RAD). Some campaign finance reports, particularly those filed by presidential
campaign committees accepting public funding, are also reviewed by auditors in the
Audit Division. In practice, the RAD analysts and the auditors often encounter “purpose

of disbursement” entries that are not listed in the examples contained in 11 CFR


Branch, Reports Analysis Division, 999 E Street, NW,
Washington, DC 20463, (202) 694-1130 or (800) 424-9530.
SUPPLEMENTARY INFORMATION:

Political committees and other persons required to file campaign finance reports
with the FEC must itemize certain disbursements and, for each itemized disbursement,
must provide the full name and address of the recipient, the date the disbursement was
made, and a brief statement or description of why the disbursement was made. See
2 U.S.C. 434(b); 11 CFR 104.3(b)(3) and (4), 104.10(b)(4), 104.17(b)(3) and
300.36(b)(2)(iii). The “purpose of disbursement” entry, when considered along with the
identity of the disbursement recipient, must be sufficiently specific to make the purpose
of the disbursement clear. 11 CFR 104.3(b)(3)(i)(B) and (4)(i)(A). The Commission’s

regulation requiring a description of the purpose of each itemized disbursement includes

examples of descriptions that are acceptable (e.g., “dinner expenses, salary,” “travel

246,

expenses”) and examples that are unacceptable (e.g., “advance,” “miscellaneous”).
Neither list is exhaustive.

The Commission solicited comments on a draft of this policy statement on
November 2, 2006. Two comments were received. After reviewing the comments
received, the Commission has decided to publish the policy statement with one change.
As suggested by a commenter, the Commission has added “Consulting-Political” to the
examples of generally insufficient descriptions. In light of this change, the Commission
has also added examples of descriptions that would be generally sufficient such as

“Consulting-Media,” “Consulting-Fundraising,” “Consulting-Polling,” “Consulting-

Legal” and “Consulting-Get-Out-The-Vote.”


FEDERAL ELECTION COMMISSION
11 CFR Part 104

[NOTICE 2006- ]

STATEMENT OF POLICY: “PURPOSE OF DISBURSEMENT” ENTRIES FOR

AGENCY:
ACTION:

SUMMARY:

DATE:

FILINGS WITH THE COMMISSION

Federal Election Commission

Statement of policy

Political committees and other persons required to file campaign
finance reports with the FEC must itemize certain disbursements
and, for each itemized disbursement, must provide information
including a brief description of the purpose of the disbursement.
The “purpose of disbursement” entry, when considered along with
the identity of the disbursement recipient, must be sufficiently
specific to make the purpose of the disbursement clear. The
guidance below includes a non-exhaustive list of “purpose of
disbursement” entries that are generally acceptable, and a non-
exhaustive list of terms that are generally not acceptable.

Effective as of [INSERT DATE OF PUBLICATION}.

FOR FURTHER INFORMATION CONTACT: Richard T. Ewell, Attorney, 999 E

Street, N.W., Washington, DC 20463, (202) 694-1650 or (800)

424-9530, or Debbie Chacona, Branch Chief, Party/Non-Party