Contract Labor

Contractual Services

Convention Expenses

Convention Services

Costs

Delegate

Delegate Expenses

Design

Discount Fees

Election Day Expense
Entertainment

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)
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


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:

VV VVVV VVVV

>

“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.
“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.

Purposes that generally lack sufficient detail:

Administrative Expenses
Admin.

Advance

Bonus

Bounty

Campaign Expense
Campaign Material
Charges

Collateral

Collateral Materials
Commission
Compensation (other than committee staff)
Consultant

Consulting

Consulting Non-FEA
Consulting Service
Contract


Professional Services
Promotional Material
Publication

Push Card

Reimbursement

Rendered Service

Services

Services Rendered

State Convention

Supplies (if to an individual)
Voter Bounty

Voter Contact

Voter Drive

Voter Identification or Voter ID
Voter Registration

Worker

HHE


AGENDA DOCUMENT NO. 06-72

SECRETARIAT

FEDERAL ELECTION COMMISSION — 7b OCT 27 A 10: 03
Washington, DC 20463

October 27, 2006

MEMORANDUM AGENDA ITEM
TO: The Commission Y for Meeting of_ll-oa-—o6

FROM: L HN ‘
Lares. onon jp/ SUBMITTED LATE

Rosemary C. Smith
Associate General Counsel

Amy L. Rothstein @&
Acting Assistant General Counsel

Richard T. Ewell ge by AR
Attorney

SUBJECT: Draft Request for Comment Regarding “Purpose of Disbursement”
Entries for Reports Filed with the Commission

Please find attached a draft Request for Comment regarding descriptions of the
purpose of committee disbursements. The Office of General Counsel has been asked to
transmit this document to the Commission Secretary in anticipation of the Open Session
on November 2, 2006.

The Request for Comment contains a list of descriptions of “purpose of
disbursement” that are generally acceptable for committees to use when filing reports
with the Commission, and a list of descriptions that are generally unacceptable. These
lists, which were developed by the Reports Analysis Division and the Audit Division, are
consistent with the lists set forth at 11 CFR 104.3(b)(3) and (4).

Attachment


FEDERAL ELECTION COMMISSION
Washington, DC 20463

November 2, 2006

Request for Comment: “Purpose of Disbursement” Entries for Filings with the
Commission

Summary:

The Commission requests comment on proposed guidance regarding descriptions
of disbursements for political committees and others filing reports with the Commission.
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.

Dates: Comments must be submitted by December 4, 2006.

Addresses: All comments must be in writing, must be addressed to Ms. Amy Rothstein,
Acting Assistant General Counsel, and must be submitted in either e-mail, facsimile, or
paper copy form. Commenters are strongly encouraged to submit comments by e-mail or
fax to ensure timely receipt and consideration. E-mail comments must be sent to
purposedisburse @fec.gov. If e-mail comments include an attachment, the attachment
must be in either Adobe Acrobat (.pdf) or Microsoft Word (.doc) format. Faxed
comments must be sent to (202) 219-3923, with paper copy followup. Paper comments
and paper copy follow-up of faxed comments must be sent to the Federal Election
Commission, 999 E Street, NW., Washington, DC 20463. All comments must include
the full name and postal service address of the commenter or they will not be considered.
The Commission will make every effort to post public comments on its web site within
ten business days of the close of the comment period.

Contacts: For further information, please contact Debbie Chacona, Branch Chief,
Party/Non-Party Branch, Reports Analysis Division, at (202) 694-1130.

Background and Guidance:

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

pare

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 arule 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.). If the committee were to provide additional
detail with respect to the type of consulting the vendor provided (e.g., “Fundraising
Consulting”), however, 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
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, if a 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