U.S. GOVERNMENT PUBLISHING OFFICE

WASHINGTON : 

1 

79–006 

" ! HOUSE OF REPRESENTATIVES 115TH CONGRESS

2d Session 

REPORT

2018

115–898 

House Calendar No. 179 

IN THE MATTER OF ALLEGATIONS 

RELATING TO 

REPRESENTATIVE MARKWAYNE MULLIN 

R E P O R T 

OF THE

COMMITTEE ON ETHICS 

AUGUST 10, 2018.—Referred to the House Calendar and ordered to be 

printed 


SSpencer on DSKBBXCHB2PROD with REPORTSE:\Seals\Congress.#13
(II) 

COMMITTEE ON ETHICS 

SUSAN W. BROOKS, Indiana 

Chairwoman 

KENNY MARCHANT, Texas 

LEONARD LANCE, New Jersey 

MIMI WALTERS, California 

JOHN RATCLIFFE, Texas 

THEODORE E. DEUTCH, Florida 

Ranking Member 

YVETTE D. CLARKE, New York 

JARED POLIS, Colorado 

ANTHONY BROWN, Maryland 

STEVE COHEN, Tennessee 

REPORT STAFF 

THOMAS A. RUST, Chief Counsel/Staff Director 

BRITTNEY PESCATORE, Director of Investigations 

MEGAN H. SAVAGE, Counsel to the Chairwoman 

DANIEL J. TAYLOR, Counsel to the Ranking Member 

MOLLY N. MCCARTY, Investigator 

MARK HAMILTON, Investigative Clerk 


SSpencer on DSKBBXCHB2PROD with REPORTS
(III)

LETTER OF TRANSMITTAL 

HOUSE OF REPRESENTATIVES, 

COMMITTEE ON ETHICS, 

Washington, DC, August 10, 2018. 

Hon. KAREN L. HAAS, 

Clerk, House of Representatives, 

Washington, DC. 

DEAR MS. HAAS: Pursuant to clauses 3(a)(2) and 3(b) of rule XI 

of the Rules of the House of Representatives, we herewith transmit 

the attached report, ‘‘In the Matter of Allegations Relating to Representative Markwayne Mullin.’’ 

Sincerely, 

SUSAN W. BROOKS, 

Chairwoman. 

THEODORE E. DEUTCH, 

Ranking Member. 


SSpencer on DSKBBXCHB2PROD with REPORTS

SSpencer on DSKBBXCHB2PROD with REPORTS
(V) 

C O N T E N T S 

Page 

I. INTRODUCTION .......................................................................................... 1 

II. PROCEDURAL HISTORY ............................................................................ 2 

III. HOUSE RULES, LAWS, REGULATIONS, AND OTHER STANDARDS 

OF CONDUCT ............................................................................................ 3 

IV. BACKGROUND ............................................................................................. 5 

V. FINDINGS ...................................................................................................... 8 

VI. CONCLUSION ............................................................................................... 15 

VII. STATEMENT UNDER RULE XIII, CLAUSE 3(c) OF THE RULES OF 

THE HOUSE OF REPRESENTATIVES .................................................. 16 

APPENDIX A: REPORT AND FINDINGS OF THE OFFICE OF CONGRESSIONAL ETHICS (Review No. 13–2392) 

APPENDIX B: REPRESENTATIVE MULLIN’S SUBMISSIONS TO THE 

COMMITTEE ON ETHICS 

APPENDIX C: EXHIBIT TO THE COMMITTEE REPORT 


SSpencer on DSKBBXCHB2PROD with REPORTS

SSpencer on DSKBBXCHB2PROD with REPORTS
House Calendar No. 179 

115TH CONGRESS REPORT " ! HOUSE OF REPRESENTATIVES 2d Session 115–898 

IN THE MATTER OF ALLEGATIONS RELATING TO 

REPRESENTATIVE MARKWAYNE MULLIN 

AUGUST 10, 2018.—Referred to the House Calendar and ordered to be printed 

Ms. BROOKS, from the Committee on Ethics, 

submitted the following 

R E P O R T 

In accordance with House Rule XI, clauses 3(a)(2) and 3(b), the 

Committee on Ethics (Committee) hereby submits the following Report to the House of Representatives. 

I. INTRODUCTION 

On December 23, 2013, the Office of Congressional Ethics (OCE) 

sent a referral (OCE’s Referral) to the Committee in which it recommended further review of allegations that Representative 

Markwayne Mullin, in 2013: (1) personally endorsed goods or services provided by companies he or his family owned; (2) received 

outside earned income, in excess of the applicable limits, from 

those companies; and, (3) served as a director and/or officer of the 

companies for compensation. 

The Committee did further review the allegations OCE referred. 

After an extensive review, the Committee found the allegations 

raised several novel questions regarding the application of House 

rules and other standards of conduct to a Member’s efforts to maintain and promote a family business. These questions were further 

complicated by the procedural posture of the matter, which began 

when Representative Mullin consulted Committee staff after his 

election to the House, on November 6, 2012, in order to ensure he 

and his family businesses would operate consistent with the applicable rules. As Representative Mullin was working with Committee 

staff to bring his family businesses into compliance, OCE began its 

separate review, and eventually referred allegations to the Committee that related to issues which were part of the Committee’s 

advisory process. While these issues would typically be treated as 

advisory matters, and the Member would be given time to bring his 


SSpencer on DSKBBXCHB2PROD with REPORTS
2 

1The House has long recognized that Members may receive income from the royalties of book 

sales. This restriction does not change the Committee’s longstanding guidance permitting Members’ participation in the promotion of their own books, so long as the Member does so in their 

personal capacity and without using any official resources. 

businesses into compliance, OCE’s Referral compelled the Committee to treat the issues as an investigative matter. 

Ultimately, the Committee determined that Representative 

Mullin made a good faith effort to seek the Committee’s informal 

guidance on numerous issues with respect to his family business. 

Although the Committee acknowledges that its informal, staff-level 

advice is not a categorical shield from future adverse actions, such 

advice is nevertheless necessary to enable the House community to 

successfully navigate standards of conduct. Members and their 

staff are encouraged to diligently request the Committee’s advice 

and, upon doing so, may rely on the advice to engage in the vetted 

actions. In this case, Representative Mullin sought advice from the 

Committee staff about his family business, and appears to have 

substantially complied with most of that advice. To the extent that 

Representative Mullin substantially complied with the Committee’s 

advice, it would be inequitable to subject his conduct to additional 

review. 

The Committee did determine that an accounting error led Representative Mullin to inadvertently fail to fully follow part of the 

Committee’s advice. Committee staff advised Representative Mullin 

to transfer ownership of a company to his spouse. Representative 

Mullin transferred the ownership, but the company failed to terminate an automatic disbursement process. That mistake led Representative Mullin to personally receive $40,000 from the company 

in 2013, despite his lack of ownership. The money was paid into 

a joint account held by both Representative Mullin and his spouse, 

the rightful payee. However, the Committee found that, to bring 

Representative Mullin into full compliance with the Committee’s 

guidance, he must return $40,000 to that company. 

One of the issues on which Representative Mullin sought stafflevel guidance was his participation in advertisements for his family business. Representative Mullin complied with the advice he received on this issue. However, the Committee believes that, going 

forward, the House would be better served by different guidance 

with regard to Member participation in advertisements. Therefore, 

the Committee takes this opportunity to clarify its guidance with 

respect to Member participation in advertisements or other commercial endorsements of goods or services. Under no circumstances 

should a Member be actively involved in personally selling or endorsing goods or services in which the Member has a financial interest.1

Accordingly, the Committee unanimously voted to adopt this Report, and take no further action. Upon publication of this Report 

and repayment of $40,000 to Mullin Plumbing West Division, the 

Committee considers the matter closed. 

II. PROCEDURAL HISTORY 

The Committee received OCE’s Referral on December 23, 2013. 

Representative Mullin then submitted a response to the ComVerDate Sep 11 2014 01:49 Aug 22, 2018 Jkt 079006 PO 00000 Frm 00008 Fmt 6659 Sfmt 6602 E:\HR\OC\HR898.XXX HR898

SSpencer on DSKBBXCHB2PROD with REPORTS
3 

2Letter from J. Baran to Representative Conaway and Representative Sa ́nchez, Jan. 22, 2014 

(hereinafter January 22, 2014 Submission). 3 Code of Ethics for Government Service ¶5. 

4See, e.g., Code of Ethics for Government Service ¶8; House Rule XXV, cl. 2; 5 U.S.C. app. 

§ 50l(a). 5 House Ethics Manual (2008) (hereinafter Ethics Manual) at 188. 6The outside earned income limit for other relevant years has been: $26,955 (2014); $27,225 

(2015); $27,495 (2016); $27,765 (2017); $28,050 (2018). 

mittee, through counsel.2 On March 24, 2014, the Committee published OCE’s Referral and Representative Mullin’s response, and 

publicly announced that it would investigate the matter pursuant 

to Committee Rule 18(a). 

In the course of its investigation, the Committee issued multiple 

requests for information to Representative Mullin and to the accountants for the plumbing and home maintenance companies 

owned by Representative Mullin at the time of his election to Congress (collectively, the ‘‘Mullin Companies’’). In response to those 

requests, the Committee received and reviewed thousands of pages 

of materials. The Committee also interviewed the Chief Financial 

Officer (CFO) of the Mullin Companies, the companies’ accountants, and Representative Mullin, who appeared voluntarily before 

the Committee. 

III. HOUSE RULES, LAWS, REGULATIONS, AND OTHER 

STANDARDS OF CONDUCT 

A. PERSONAL ENDORSEMENT OF COMMERCIAL GOODS AND SERVICES

House Rule XXIII, clause 3, provides that a House Member ‘‘may 

not receive compensation and may not permit compensation to accrue to his beneficial interest from any source, the receipt of which 

would occur by virtue of influence improperly exerted from his position in Congress.’’ In addition, the Code of Ethics for Government 

Service (Code of Ethics), which applies to House Members, states 

that a federal official should never accept ‘‘benefits under circumstances which might be construed by reasonable persons as influencing the performance of official duties.’’ 3 Other House rules 

and standards regarding outside employment and outside earned 

income may also implicate these standards of conduct.4 In discussing these standards of conduct, the Ethics Manual broadly 

states: ‘‘[A] Member should not undertake any outside employment 

that would involve the Member personally in the selling or endorsement of any goods or services.’’ 5

B. OUTSIDE EARNED INCOME

House Rule XXV, clause 4(d)(1), defines ‘‘outside earned income’’ 

to include ‘‘wages, salaries, fees, and other amounts received . . . 

as compensation for personal services.’’ Any such earned income is 

subject to limits established by the Ethics in Government Act 

(EIGA) and House Rule XXV, clause 1(a)(1), which provide that a 

Member may not have outside earned income attributable to a calendar year that exceeds 15 percent of the annual rate of basic pay 

for level II of the Executive Schedule under section 5313 of title 5, 

United States Code, as of January 1 of that calendar year. For calendar year 2013, the outside earned income limit for a Member 

was $26,955.6


SSpencer on DSKBBXCHB2PROD with REPORTS
4 

7 In 2013, Representative Mullin or his spouse owned each of the Mullin Companies, which 

thus qualify as family-owned businesses. Based on information from Representative Mullin, it 

also appears that two of those companies, Mullin Plumbing, Inc. and Mullin Plumbing West Division, generated significant revenue from the sales of plumbing parts, and thus they satisfied 

the requirement of House Rule XXV, clause 4(d)(1)(D) that ‘‘both personal services and capital 

are income-producing factors [of the business].’’ 8See House Select Comm. On Ethics, Advisory Opinion No. 13 (October 1978) (herein after 

Advisory Opinion No. 13), reprinted in Ethics Manual at 364; Ethics Manual at 231. 9 Ethics Manual at 231 (emphasis in original). 10 Id. 11See Advisory Op. No. 13. 12 Id. (see Ethics Manual at 368). 13 Id. 

The House Rules include a provision for the treatment of payments a Member receives from a family-owned business. House 

Rule XXV, clause 4(d)(1)(D) states: 

[I]n the case of a Member . . . engaged in a trade or 

business in which such individual or the family of such individual holds a controlling interest and in which both personal services and capital are income-producing factors, 

any amount received by the Member [is not included in the 

definition of outside earned income] . . . so long as the 

personal services actually rendered by such individual in 

the trade or business do not generate a significant amount 

of income.’’ 7

The Committee has stated that if a Member receives payments 

from a corporation that are ‘‘essentially a return on equity [invested in the company], then it would generally not be considered 

to be earned income.’’ 8 The Ethics Manual further states that ‘‘[i]n 

business corporations, only payment for services the Member performs is considered earned income. An increase in the value of the 

firm’s stock or distribution of profits is not considered earned income.’’ 9 However, in determining whether a payment from a corporation to a Member is a ‘‘distribution’’ (return on equity) or compensation for personal services, ‘‘the ‘real facts’ of a particular case 

would control as to whether moneys received would be deemed 

earned income.’’ 10 Thus, the ‘‘label or characterization placed on a 

. . . payment by the parties may be disregarded for purposes of the 

Rule,’’ and the payment will be considered earned income if it is 

‘‘in fact attributable to any significant extent to services rendered 

by the Member.’’ 11

In addition to this general guidance, the Committee has provided 

specific guidance with respect to S-Corporations, such as the 

Mullin Companies. If a Member owns an S-Corporation, the ‘‘determining factor’’ for whether payments from the corporation to the 

Member are deemed earned income ‘‘is whether the Member’s . . . 

personal services generate significant income for the business.’’ 12 If 

the Member performs services for the business that ‘‘actually generate any significant income for the business,’’ then some part of 

the payments the Member receives from the business may be 

deemed earned income. ‘‘However, if the Member . . . is engaged 

primarily in the general oversight and management or protection 

of his or her investment [in a business], such services would not 

be deemed to generate significant income.’’ 13


SSpencer on DSKBBXCHB2PROD with REPORTS
5 

14 Ethics Manual at 222. 15 Committee counsel made clear to Representative Mullin that any previously recorded advertisements that featured him could not make any reference to his status as a House Member. 

As far as the Committee is aware, Representative Mullin has complied with this requirement 

in all of his advertisements for the Mullin Companies. 

C. COMPENSATION FOR SERVICE AS A CORPORATE DIRECTOR OR

OFFICER

House Rule XXV, clause 2(d) states that a Member ‘‘may not . . . 

serve for compensation as an officer or member of the board of an 

association, corporation, or other entity.’’ The Ethics Manual notes 

that ‘‘[a]s a general matter, Members and senior staff may serve 

in such capacities, but they may not be paid any directors’ fees or 

other compensation for that service.’’ 14

IV. BACKGROUND 

A. REPRESENTATIVE MULLIN’S BUSINESS INTERESTS AND ELECTION TO

THE HOUSE

Representative Mullin was elected to the House of Representatives on November 6, 2012. At that time, he owned the Mullin 

Companies, five S-Corporations (‘‘S-Corps’’) that were engaged in 

the plumbing and home maintenance industries. Representative 

Mullin long served as the primary spokesperson for the Mullin 

Companies and, as such, appeared in numerous advertisements 

promoting the business. These advertisements include video clips 

that appear on the companies’ website and in other places on the 

Internet. Additionally, Representative Mullin’s companies pay to 

air a weekly radio show in which someone from the companies, 

usually Representative Mullin, discusses topics related to home repair and suggests to listeners his companies can be a resource to 

them. 

Representative Mullin was sworn into office on January 3, 2013. 

During the period between his election and his assumption of office, then-Representative-elect Mullin sought guidance from Committee counsel regarding various issues related to his ownership of, 

and work for, the Mullin Companies. Among other things, Representative Mullin discussed with Committee counsel whether the 

Mullin Companies could continue to use advertisements featuring 

Representative Mullin that had been recorded before his election, 

and whether he could retain his ownership of one of the S-Corps, 

Mullin Plumbing West Division (‘‘Mullin West’’), that had a contract with the federal government. 

Committee counsel advised then-Representative-elect Mullin that 

the Mullin Companies could continue to use advertisements, featuring him, that were recorded before his election.15 Committee 

counsel was not asked, and did not discuss, whether Representative Mullin could record new advertisements, featuring him, after 

his election. However, Representative Mullin asserts that, when 

Committee staff met with him after his election to the House, Committee staff understood that he regularly participated in the weekly 

radio program, and that he would continue to participate in that 

program as a Member, provided that he was not compensated for 

such participation. Representative Mullin cites that understanding 


SSpencer on DSKBBXCHB2PROD with REPORTS
6 

16 Neither the Committee nor Representative Mullin have any contemporaneous records reflecting a discussion of the radio show. However, the Committee has no reason to believe that 

Representative Mullin’s recollection of the discussion of the radio show is incorrect. 17Mullin West held a contract with a federal agency, which could have implicated the statutory prohibition on a Member contracting with the federal government. See 18 U.S.C. § 431. Consistent with precedent, Committee staff advised Representative Mullin to transfer ownership of 

Mullin West to his spouse. 18 Representative Mullin’s father started the Mullin Companies, and eventually sold them to 

Representative Mullin pursuant to an agreement whereby the Mullin Companies make monthly 

payments to Representative Mullin’s father. The Committee understands that the amount of 

each payment is deducted from Representative Mullin’s ownership interest in the Mullin Companies. 19See January 22, 2014 Submission at 4. 

as proof Committee staff did not intend to restrict his ability to appear in other forms of advertising for the companies.16

Committee counsel also advised Representative Mullin to transfer ownership of Mullin West to his wife, to avoid any issue with 

a federal statute that prohibits a Member from entering into contracts with the federal government.17 Representative Mullin effected this transfer on December 31, 2012. Committee counsel also 

recommended several minor modifications to the business operations of the Mullin Companies to ensure compliance with House 

rules and federal law. Representative Mullin accepted these recommendations and the Mullin Companies made the appropriate 

changes. 

After joining Congress, Representative Mullin continued to host 

the weekly radio show. Representative Mullin also continued to appear in radio, television, and web advertisements for the Mullin 

Companies. Those advertisements generally recommend contacting 

the Mullin Companies for the audience’s plumbing and heating 

needs. 

B. PAYMENTS FROM THE MULLIN COMPANIES TO REPRESENTATIVE

MULLIN IN 2013

In 2013, Representative Mullin’s first year in the House of Representatives, the Mullin Companies made payments to him totaling 

$640,110.44. Of that amount, the Committee determined 

$545,110.44 was ‘‘passed through’’ Representative Mullin to other 

recipients, including his father (as payment for purchase of the 

businesses from him) 18 and state and federal governments (for 

payment of the Mullin Companies’ tax obligations). Representative 

Mullin, through counsel, described the ‘‘pass through’’ payments as: 

‘‘$387,425: tax payments to the IRS and to the Oklahoma Tax Commission; $69,983.44: payment to Rep. Mullin’s father for purchase 

of the business; $87,702: for purchase of rental properties.’’ 19 The 

Committee found these descriptions to be accurate. Such passthrough payments are standard for S-Corps, and do not necessarily 

represent payments ‘‘to’’ an S-Corp’s owner. In addition to these 

pass-through payments, in 2013, Representative Mullin did receive, 

and retain, $95,000 in payments from two of the Mullin Companies: $40,000 from Mullin West, and $55,000 from Mullin Plumbing, Inc. (‘‘Mullin Plumbing’’). 

Representative Mullin has characterized these payments as ‘‘distributions,’’ which he asserts were returns on capital he invested 

in the companies. Representative Mullin had capital invested in 

Mullin Plumbing in 2013. However, because he transferred ownership of Mullin West to his wife in 2012, Representative Mullin did 

not have capital invested in Mullin West in 2013. Some, but not 


SSpencer on DSKBBXCHB2PROD with REPORTS
7 

20See OCE Referral at 15. 21See OCE’s Memorandum of Interview with Representative Mullin at ¶¶4, 17, 24, 29, 33 (Ex. 

2 to OCE’s Referral). 22See 18(a) Interview of Representative Mullin. Representative Mullin told the Committee the 

Mullin Companies had a ‘‘Leadership Team,’’ rather than a formal Board of Directors. See id. 

It is possible Representative Mullin confused these concepts when speaking with OCE. 23See 18(a) Interview of Mullin Companies CFO. 

all, of the checks from Mullin West to Representative Mullin in 

2013 include ‘‘DIST’’ on the Memo line. 

Although the payments to Representative Mullin from Mullin 

West and Mullin Plumbing raise similar legal issues, the Committee’s investigation revealed one significant difference between 

them. Mullin Plumbing intended to and did pay $55,000 to Representative Mullin in 2013, while Mullin West paid him $40,000 

due to an apparent error in the company’s payment processes. 

Those payments were the result of an automatic disbursement 

process of $5,000 monthly payments to Representative Mullin. 

Those payments were not terminated when Representative Mullin 

transferred ownership of Mullin West to his spouse. This seems to 

have occurred, in part, because Representative Mullin did not inform the CFO of the Mullin Companies of the change in ownership 

when it took effect. The payments were ultimately stopped in September 2013, shortly after OCE initiated its preliminary review of 

Representative Mullin’s involvement with the Mullin Companies. 

Representative Mullin did not notice the continued payments because they were automatically deposited into a joint account held 

by Representative Mullin and his spouse, and Representative 

Mullin did not view the accounts because his spouse managed the 

family’s finances. Nonetheless, Representative Mullin did receive 

the payments, and has never returned them. 

C. REPRESENTATIVE MULLIN’S ALLEGED SERVICE AS THE PRESIDENT

AND DIRECTOR OF THE MULLIN COMPANIES

OCE found substantial reason to believe Representative Mullin, 

after he became a House Member, served as a member of the 

Boards of Directors of each of the Mullin Companies and also as 

the President of at least some of the companies. OCE suggested 

that some portion of the payments Representative Mullin received 

from the companies in 2013 ‘‘may have’’ been compensation for 

serving as a director and/or officer of the companies.20 However, 

OCE did not provide any basis for connecting the payments Representative Mullin received to any role he had as a Director or officer. Indeed, it is not clear that Representative Mullin even served 

in these roles after 2012. 

According to OCE’s summary of its interview with Representative Mullin, which was not recorded or transcribed, Representative 

Mullin stated that in 2013 he served on the Board of Directors of 

each of the five S-Corps that made up the Mullin Companies.21

However, in testimony to the Committee, Representative Mullin 

stated that none of the Mullin Companies had a Board of Directors 

in 2013, and that he was thus not a Director of any company.22

The CFO of the Mullin Companies confirmed that none of the companies has a Board of Directors.23

The record is less clear with respect to whether Representative 

Mullin served as an officer of the Mullin Companies after he became a House Member. Representative Mullin told OCE that he 


SSpencer on DSKBBXCHB2PROD with REPORTS
8 

24See OCE’s Memorandum of Interview with Representative Mullin at ¶4 (Ex. 2 to OCE’s Referral). 25See Letter from J. Baran to Representative Conaway and Representative Sa ́nchez, Mar. 24, 

2014, at 5–6. 26See 18(a) Interview of Representative Mullin. 27See id. 28See OCE’s Memorandum of Interview with Mullin Plumbing CFO at ¶¶7, 10 (Ex. 4 to OCE’s 

Referral). 29 In an email to Representative Mullin’s Chief of Staff, Tom Rust stated that the Committee’s 

guidance during staff’s meeting with Representative Mullin was not memorialized in writing, 

but that staff told Representative Mullin the Mullin Companies could re-use advertisements 

filmed before his House election if the companies were not fiduciary businesses and the advertisements made no reference to Representative Mullin’s position in Congress. See OCE’s Referral, Ex. 11. 

gave up his position as President of the Mullin Companies when 

he was elected to the House.24 However, a 2014 written submission 

to the Committee stated that he continued to serve as President.25

When asked in his Committee interview whether he was still the 

President, Representative Mullin initially said ‘‘I don’t think so. I 

don’t know exactly how that’s laid out.’’ 26 When shown his 2014 

written submission, Representative Mullin changed his answer and 

stated he was still the President of the various Mullin Companies.27 The Mullin Companies’ CFO also told OCE in 2013 that 

Representative Mullin was still serving as President.28

V. FINDINGS 

A. REPRESENTATIVE MULLIN’S CONSULTATIONS WITH THE COMMITTEE

Representative Mullin initially approached the Committee voluntarily, after his election to the House, to discuss a range of issues 

related to his ownership of, and involvement with, the Mullin Companies. During those discussions, Committee staff advised Representative Mullin to transfer ownership of Mullin West to his wife, 

and recommended several minor modifications to the business operations of the Mullin Companies. Representative Mullin followed 

that guidance. Committee staff also informally advised Representative Mullin that the Mullin Companies could re-use advertisements, which featured him and were recorded before his House 

election, under certain conditions.29 Staff did not discuss whether 

Representative Mullin could film new advertisements for the 

Mullin Companies. However, the record indicates that Representative Mullin asked whether he could continue to participate in a 

weekly radio program the Mullin Companies paid for, in which he 

discussed common home maintenance issues, and that Committee 

staff said Representative Mullin could continue to participate in 

that program as a Member, provided that he was not compensated 

for such participation. 

The Committee has long encouraged House Members and staff to 

avail themselves of the guidance of the Committee’s nonpartisan, 

professional staff. The rules governing outside employment often 

require a fact-specific analysis, and Members are encouraged to 

conduct that analysis with the guidance of the Committee’s nonpartisan, professional staff. Although staff-level advice is not a categorical shield from future adverse actions by this Committee, such 

advice is nevertheless necessary to enable the House community to 

successfully navigate standards of conduct. Members and their 

staff are encouraged to diligently request the Committee’s advice 


SSpencer on DSKBBXCHB2PROD with REPORTS
9 

30See House Comm. on Ethics, In the Matter of Allegations Relating to Representative Tom 

Petri, H. Rep. 113–666, 113th Cong., 2d Sess. at 6–7 (2014). 31See id. at 7. 32 Ethics Manual at 188. 33 Id. 

and, upon doing so, Members and their staff may rely on the advice 

to engage in the vetted actions.30

OCE, when confronted with Representative Mullin’s evidence of 

consultation with the Committee staff, examined that consultation 

to determine whether it completely and accurately disclosed the 

facts of his proposed actions. As the Committee has stated in the 

past, this is a proper avenue of inquiry.31 Neither formal advice 

from the Committee nor informal staff-level guidance will suffice to 

protect a Member when that advice is based on inaccurate facts, 

or when that advice endorses a course of action fundamentally different from the course actually taken. However, where Representative Mullin substantially complied with those consultations, the 

Committee believes that it would be inequitable to determine 

whether Representative Mullin’s actions would constitute a violation. 

B. PERSONAL ENDORSEMENT OF GOODS AND SERVICES

The Committee has long advised that ‘‘a Member should not undertake any outside employment that would involve the Member 

personally in the selling or endorsement of any goods or services.’’ 32 While there is no specific law, rule, or other standard of 

conduct that expressly forbids such employment, the Committee 

has stated that this prohibition arises from the House Rules and 

the Code of Ethics for Government Service, which prohibit a Member from any use of their office or official position to obtain compensation or other benefits.33

There is no question that Representative Mullin personally endorsed the Mullin Companies’ goods and services, both before and 

after he became a Member of Congress, through a weekly radio 

program and advertisements for radio, television, and the web. 

However, Representative Mullin specifically asked the Committee’s 

staff whether the Mullin Companies could continue to use advertisements featuring Representative Mullin, which he had recorded 

before his election. Committee counsel advised Representative 

Mullin that this would be permissible, as long as they made no reference to his status as a Member. Representative Mullin also believes that he asked Committee staff whether he could continue to 

participate in a weekly radio program the Mullin Companies paid 

for, in which he discussed common home maintenance issues. Representative Mullin recalls that Committee staff told him that he 

could continue to participate in the radio show, as long as he was 

not compensated for that participation. 

Representative Mullin’s conduct conformed with this advice. 

However, going forward, the Committee believes that the House 

would be better served by different guidance with regard to Member participation in advertisements. Because this was informal, 

staff-level guidance, it is not subject to the same rule-based safe 

harbor for formal written guidance but Members and their staff are 

encouraged to diligently request the Committee’s advice and, upon 

doing so, may rely on the advice to engage in the vetted actions. 


SSpencer on DSKBBXCHB2PROD with REPORTS
10 

34The Committee notes that the more comprehensive and consistent one’s consultation with 

the Committee or its staff, the more protection the Committee can offer in response to actions 

related to that consultation. 35 Code of Ethics for Government Service ¶5. 36The House has long recognized that Members may receive income from the royalties of book 

sales. This restriction does not change the Committee’s longstanding guidance permitting Members’ participate in the promotion of their own books, so long as the Member does so in their 

personal capacity and without using any official resources. 37There are some restrictions on the use of a Member’s name for certain businesses (e.g., businesses that engage in fiduciary professions). And a Member of Congress choosing to add his or 

her name to a commercial enterprise after election to the House might be the kind of active 

endorsement of a commercial enterprise that would be improper. However, where no other restriction applies, the simple retention of a Member’s name on a business does not violate these 

rules. 

Thus, the Committee believes it would be inequitable to punish 

him when he relied on that advice.34

Further, Representative Mullin was not an employee of the 

Mullin Companies. He was the owner of Mullin Plumbing and his 

wife was the owner of Mullin West. The Committee has not previously addressed whether the prohibition on the selling or endorsing of goods or services extends beyond employment to other situations in which the Member has a financial interest. Some of the 

laws, rules, and other standards of conduct pertaining to outside 

employment make distinctions between employment and other financial interests. However, the relevant rules and other standards 

of conduct pertaining to commercial endorsements are not so limited. Instead, House Rule XXIII, clause 3 applies to the receipt or 

accrual of compensation to the Member’s ‘‘beneficial interest from 

any source.’’ And the Code of Ethics for Government Service applies to the acceptance by the Member or the Member’s family of 

‘‘favors or benefits.’’ 35 Thus, there is no reason to believe that the 

prohibition on the selling or endorsing of goods or services is limited only to employment situations. 

Members of the House of Representatives are widely recognizable 

public servants. Even when they make no explicit mention of their 

official position, when Members actively engage in commercial 

sales or endorsements, they may create the perception that they 

are making use of their official position for commercial gain. Members must at all times avoid even the appearance that they are 

monetizing their public role for personal gain. 

Therefore, the Committee takes this opportunity to clarify for the 

whole House community that a Member should not be actively involved in personally selling or endorsing goods or services in which 

the Member has a financial interest.36 As such, Representative 

Mullin should now understand that, going forward, he cannot participate in the weekly radio program or the advertisements for 

radio, television, and the web. This restriction only applies to the 

active participation in selling or endorsing goods or services. Thus, 

it does not require Representative Mullin to remove his name from 

the Mullin Companies,37 nor does it require the Mullin Companies 

to scour the Internet to take down old videos of advertisements featuring Representative Mullin. Instead, the Mullin Companies can 

no longer take active steps to promote Representative Mullin’s endorsement of the companies. Thus, the Mullin Companies cannot 

film any new advertisements featuring Representative Mullin, and 

old advertisements featuring Representative Mullin should be removed from the Mullin Companies’ website. 


SSpencer on DSKBBXCHB2PROD with REPORTS
11 

38 5 U.S.C. app. § 501(a)(1). 39See Memorandum from the Committee on Ethics to All Members, Officers and Employees 

re: Change to Financial Disclosure Reporting Obligations and Reminder Regarding Periodic 

Transaction Reporting Requirement (Jan. 24, 2013). 40See OCE’s Memorandum of Interview with Mullin Plumbing CFO at ¶ 13; see also 18(a) 

Interview of Mullin Companies CFO. 41See 18(a) Interview of Representative Mullin; see also 18(a) Interview of Mullin Companies 

CFO. The CFO of the Mullin Companies confirmed Representative Mullin did significantly less 

work for the companies once he became a Member of Congress. See id. (‘‘He used to come to 

work every day at 7 o’clock, and that obviously changed. He would hire and fire before, and 

now he doesn’t. He would be involved in insurance renewals, banking decisions, policy decisions, 

and now he does not, he’s not involved in those things. He used to run service calls; doesn’t 

do that anymore. He used to oversee our shop; he doesn’t do that anymore. . . . Now we will 

involve him on more of a general basis, just as an informative. I mean, obviously they are still 

his companies, so we as a consideration just let him know what’s going on with them. If we 

change our uniforms, we might let him know that. If we—I mean, most of the time it’s just 

reactionary. It’s just an informative, this is what we’ve done. He might give his opinion, we 

might make changes based on that and then we might not.’’). 42See OCE Memorandum of Interview with Representative Mullin at ¶¶ 11–13, 18–21, 26, 34 

(Ex. 2 to OCE’s Referral); see also January 22, 2014 Submission at 1, 4–7. 43See Letter from Mullin Plumbing CFO to OCE, Sept. 23, 2013 (Ex. 8 to OCE’s Referral); 

see also 18(a) Interview of Mullin Companies CFO (Q. [T]he first sentence [of your letter to 

OCE] says, for the period of January 1, 2013, to current date, Markwayne Mullin has not received any income in the form of salary from any of the sources listed or any entities affiliated 

with these sources, and then there’s a listing of each of the Mullin companies. Is that accurate? 

A. Yes, it is. Q. The next paragraph is, sources of income not considered salary for Markwayne 

Mullin from January 1, 2013, to September 13, 2013, and it includes distributions. When you 

say, ‘sources of income not considered salary,’ what does that mean? A. It was not run through 

our payroll system. It was not considered a salary, it was considered a distribution.’’). 

C. OUTSIDE EARNED INCOME LIMIT

The Ethics in Government Act (EIGA) states, ‘‘a Member . . . 

may not in any calendar year have outside earned income attributable to such calendar year which exceeds 15 percent of the annual rate of basic pay for level II of the Executive Schedule under 

section 5313 of title 5, United States Code, as of January 1 of such 

calendar year.’’ 38 House Rule XXVI, clause 2, provides that Title 

I of EIGA ‘‘shall be considered Rules of the House as they pertain 

to Members . . . of the House.’’ Accordingly, House Rule XXV, 

clause 1(a)(1), incorporates EIGA’s prohibition against Members 

earning outside earned income in excess of the annual outside 

earned income limit. For the 2013 calendar year, the limit was 

$26,955.39

Prior to 2013, Representative Mullin received payments from the 

various Mullin Companies which were explicitly designated as ‘‘salary.’’ 40 Once Representative Mullin joined the House, he stopped 

receiving ‘‘salary’’ payments, a change he, and the Mullin Companies’ CFO, attributed to spending significantly less time managing 

the companies, due to his full-time work as a congressman.41 However, Representative Mullin did receive payments totaling $95,000 

from two of the Mullin Companies in 2013: $55,000 from Mullin 

Plumbing and $40,000 from Mullin West. Representative Mullin 

has consistently characterized these payments as ‘‘distributions’’— 

meaning a return on equity for capital he invested in the companies—not salary or other compensation for services rendered to the 

companies.42 The CFO of the Mullin Companies has also characterized the payments as distributions, not salary or other compensation.43

OCE’s Referral suggested that, despite the ‘‘distribution’’ label 

applied to the payments, they were in fact compensation for Representative Mullin’s services to the Mullin Companies, namely the 

advertisements he continued to record for the companies after joining the House. OCE supported this finding in two ways. First, OCE 


SSpencer on DSKBBXCHB2PROD with REPORTS
12 

44See 18(a) Interview of CPA. 45See id. 46See id. 47See Advisory Op. No. 13. 48 Id. (see Ethics Manual at 368). 49 Id. 

cited an interview with an accountant for the Mullin Companies. 

OCE’s summary of the interview, which was not recorded or transcribed, states that the accountant explained the 2013 ‘‘distributions’’ to Representative Mullin were made ‘‘in lieu of salary,’’ 

which OCE interpreted as suggesting that the ‘‘distributions’’ were 

paid to make up for salary that Representative Mullin did not receive. Second, OCE found that the advertisements generated revenue for the Mullin Companies, and therefore should be characterized as outside earned income. 

With respect to OCE’s first point, Committee staff asked the 

Mullin Companies’ accountant about the statement OCE relied on. 

The accountant stated: ‘‘The comment here, in lieu of salary,’ I 

can’t imagine me saying that because it’s really not true.’’ 44 The 

accountant also told Committee staff: ‘‘I know in 2013 he drew no 

salary from the Mullin companies because he was at that time a 

Representative of the House, and he wasn’t working near as much 

in Tulsa for the company. He elected not to take a salary.’’ 45 When 

asked how he came to this understanding, the accountant said Representative Mullin told him he was not taking a salary in 2013.46

Based on all the available evidence, the Committee found that neither Representative Mullin nor the Mullin Companies or their accountant characterized the 2013 payments as salary or other compensation, or considered them as such. 

But this does not settle the matter. The Committee has previously stated that ‘‘the label or characterization placed on a transaction, arrangement or payment by the parties may be 

disgregarded for the purpose of [House Rule XXV]’’ and ‘‘the characterization of such amounts as partnership distributive share, 

dividends, rent, interest, payment for a capital asset, or the like, 

will not serve to prevent the application of [House] Rule 25 47 The 

Committee is, therefore, not bound to accept the characterization of 

money received by Representative Mullin from his business, but 

must look at the facts surrounding the receipts of that money to 

determine whether it qualifies as earned or unearned income. 

Further, the Mullin Companies are all S-Corps. The Committee’s 

longstanding guidance with respect to S-Corps is that the ‘‘determining factor’’ for whether payments from the business to the 

Member are deemed earned income ‘‘is whether the Member’s . . . 

personal services generate significant income for the business.’’ 48 If 

the Member performs services for the business that ‘‘actually generate any significant income for the business,’’ then some part of 

the payments the Member receives from the business may be 

deemed earned income. ‘‘However, if the Member . . . is engaged 

primarily in the general oversight and management or protection 

of his or her investment [in a business], such services would not 

be deemed to generate significant income.’’ 49

Because Representative Mullin was the owner of Mullin Plumbing but not of Mullin West, the Committee considered the payments from the two companies separately. 


SSpencer on DSKBBXCHB2PROD with REPORTS
13 

50 Notably, Representative Mullin has never denied that his advertising role benefited the 

businesses. Instead, Representative Mullin maintains that the ‘‘family business’’ provision of the 

outside earned income rule applies to that role. More specifically, Representative Mullin contends that, in the context of a family business, a Member must be allowed to sustain the 

business’s brand by appearing in advertisements for the business, without being subjected to 

the earned income limit. This is incorrect. Participation in advertising is not ‘‘general oversight 

and management,’’ and it is not ‘‘protection of his or her investment.’’ Advertising, by definition, 

is a driver of revenue for a company. And Representative Mullin’s own statements repeatedly 

made this point. 51See 18(a) Interview of Representative Mullin. 

With respect to the payments from Mullin Plumbing, the Committee determined that participation in the radio show and filming 

new advertisements did generate significant income for Mullin 

Plumbing.50 In his interview, Representative Mullin stated numerous times, in various ways, that the advertisements he appeared in 

were an important driver of revenues for the Mullin Companies. 

For example, when asked the purpose of the advertisements, Representative Mullin stated, ‘‘It keeps customers coming in. It keeps 

us busy. Any company that has to advertise, they do it for a particular purpose. They don’t do it just for the sake of spending 

money.’’ 51

Because the radio show and advertisements were a driver of revenue, and not simply general oversight and management of the 

firm, some portion of the payments that Mullin Plumbing characterized as distributions should be deemed compensation, and would 

be subject to the outside earned income limit. For several reasons, 

the Committee did not assess what portion of the payments were 

compensation subject to the outside earned income limit. 

First, for calendar year 2013, the outside earned income limit for a Member was $26,955. If Representative Mullin’s actual return on 

equity was $28,045, or more, his earned income from Mullin 

Plumbing would be within the outside earned income limit. Based 

on the equity that Representative Mullin did have in Mullin 

Plumbing, $28,045 represents a reasonable return on his equity. 

Of course, the reasonableness is not dispositive. In general, the 

Committee will require an actual apportionment of the payments 

to earned income versus return on equity. However, it bears emphasis that Representative Mullin initially approached the Committee voluntarily, after his election to the House, to discuss a 

range of issues related to his ownership of, and involvement with, 

the Mullin Companies. During those discussions, Committee staff 

did not discuss whether Representative Mullin could film new advertisements for the Mullin Companies, or whether doing so would 

raise an issue with the outside earned income limit. However, staff 

does appear to have said that Representative Mullin could continue 

to participate in the radio show, provided that he was not compensated. Unfortunately, the unique treatment of income from S– 

Corps does not appear to have been flagged during staff’s discussions with Representative Mullin. If it had been, Representative 

Mullin might have adjusted his actions accordingly. 

Moreover, because this matter began as an advisory matter, and 

Representative Mullin has consistently cooperated with that process, the Committee believes it would be appropriate to treat any 

conclusions regarding the payments Representative Mullin received 

as they would be treated in the advice and education context, and 

to advise Representative Mullin concerning his options in the future. The Committee regularly advises Members on how to wind 


SSpencer on DSKBBXCHB2PROD with REPORTS
14 

52 In a submission to OCE, Representative Mullin stated: ‘‘[F]ollowing my November 2012 

meeting with House Ethics staff, I and others involved in the Mullin businesses structured those 

businesses, and my participation in them, to accord with our understanding of Ethics staff guidance. In fact, we spent numerous business hours and thousands of dollars to implement this 

ethics guidance, including the hiring of a new chief executive officer to replace me.’’ See Letter 

from Representative Mullin to Representative Goss and Representative Skaggs, Nov. 8, 2013, 

at 2 (Attached as Exhibit 1). In addition, Representative Mullin transferred ownership of Mullin 

West to his spouse on December 31, 2012, on the advice of Committee staff. It is true that Representative Mullin continued to receive payments from Mullin West for several months in 2013. 

However, it appears these payments were the result of an automated disbursement process, 

which was not changed when the corporate transfer occurred. 53 5 U.S.C. app. § 501(a)(1). 

down certain family-owned businesses when they are elected to 

Congress. That process can take an extended period of time, and 

the Committee does not punish Members who are not compliant 

with the applicable House Rules during a transition period, as long 

as they are making a good-faith effort to follow the Committee’s advice. In response to the Committee’s guidance on other issues concerning the Mullin Companies, Representative Mullin has made 

several changes to the ownership and practices of the companies, 

which reflect his good-faith efforts to follow the Committee’s advice.52

Accordingly, based on all of the particular circumstances of this 

matter, the Committee determined to resolve the issue of the payments from Mullin Plumbing without any additional action. 

With respect to the payments from Mullin West, it is unnecessary to assess whether the advertisements generated significant income for the company because Representative Mullin was not an 

owner of the company. Prior to his election to Congress, the Committee recommended that Representative Mullin transfer ownership of Mullin West to his wife. Representative Mullin did transfer 

the company. However, due to an accounting error, Mullin West 

continued to make regular payments to Representative Mullin. 

Given his lack of ownership in Mullin West, such payments cannot 

be considered distributions. Moreover, Representative Mullin does 

not benefit from the protection of seeking the Committee’s guidance, as the mistaken payments were inconsistent with the guidance. The money was paid into a joint account held by both Representative Mullin and his spouse. However, the Committee determined, to be in full compliance with the Committee’s guidance, 

Representative Mullin should return those payments to Mullin 

West. 

D. RECEIPT OF COMPENSATION FOR SERVICE AS A DIRECTOR OR

OFFICER

The Ethics in Government Act (EIGA) states, ‘‘a Member . . . 

shall not . . . serve for compensation as an officer or member of 

the board of any association, corporation, or other entity.’’ 53 House 

Rule XXVI, clause 2, provides that Title I of EIGA ‘‘shall be considered Rules of the House as they pertain to Members . . . of the 

House.’’ Accordingly, House Rule XXV, clause 2(d), incorporates 

EIGA’s prohibition against Members serving for compensation as 

an officer or member of a board of a corporation, association, or 

other entity. Based on Representative Mullin’s apparent statement 

to OCE that he served on the Board of Directors for each of the 

Mullin Companies, and his receipt of payments from two of the 

companies in 2013, OCE found ‘‘Representative Mullin may have 


SSpencer on DSKBBXCHB2PROD with REPORTS
15 

54See OCE’s Referral at 15. 55See n.41, supra. 

received earned income for his service as an officer and as a board 

member.’’ 54 However, if Representative Mullin told OCE that he 

was a Director, it appears he was mistaken. The record is clear 

that the Mullin Companies do not have Directors, and thus Representative Mullin could not have received compensation for service 

as such. 

The record is less clear with respect to Representative Mullin’s 

role as an officer of the Mullin Companies. There is evidence that 

Representative Mullin continued to serve as President of some or 

all of the Mullin Companies after he became a House Member. 

However, it appears that if Representative Mullin did so, it was 

largely on a nominal basis, and his actual responsibilities in the 

day-to-day operation of the companies were significantly reduced 

after 2012.55 Further, the Committee found no evidence that any 

of the payments Representative Mullin received from the Mullin 

Companies were intended to be, or could fairly be characterized as, 

payments for his service as an officer of the Mullin Companies. 

Thus, the Committee did not find that Representative Mullin violated House Rule 25, clause 2(d). 

VI. CONCLUSION 

After an extensive review, the Committee found that this matter 

raised several novel questions regarding the application of House 

rules and other standards of conduct to a Member’s efforts to maintain and promote a family business. These questions were further 

complicated by the procedural posture of the matter, which began 

when Representative Mullin consulted Committee staff after his 

election to the House in order to ensure he and his family businesses would operate consistent with the applicable rules. As Representative Mullin was working with Committee staff to bring his 

family businesses into compliance, OCE began its separate review, 

and eventually referred allegations to the Committee that related 

to issues which were part of the Committee’s advisory process. 

While these issues would typically be treated as advisory matters, 

and the Member would be given time to bring his businesses into 

compliance, OCE’s Referral compelled the Committee to treat the 

issues as an investigative matter. 

Ultimately, the Committee determined that Representative 

Mullin made a good faith effort to seek the Committee’s informal 

guidance on numerous issues with respect to his family business. 

Although the Committee acknowledges that its informal, staff-level 

advice is not a categorical shield from future adverse actions, such 

advice is nevertheless necessary to enable the House community to 

successfully navigate standards of conduct. Members and their 

staff are encouraged to diligently request the Committee’s advice 

and, upon doing so, may rely on the advice to engage in the vetted 

actions. In this case, Representative Mullin sought advice from the 

Committee staff about his family business, and appears to have 

substantially complied with most of that advice. 

To the extent that Representative Mullin substantially complied 

with the Committee’s advice, it would be inequitable to subject his 

conduct to sanction. However, the Committee determined that, to 


SSpencer on DSKBBXCHB2PROD with REPORTS
16 

56The House has long recognized that Members may receive income from the royalties of book 

sales. This restriction does not change the Committee’s longstanding guidance permitting Members’ participate in the promotion of their own books, so long as the Member does so in their 

personal capacity and without using any official resources. 

bring Representative Mullin into full compliance with the Committee’s guidance, he must return $40,000 mistakenly paid to him in 

2013 by a company that he transferred to his wife in 2012. 

Representative Mullin complied with the advice he received regarding his participation in advertisements for his family business. 

However, the Committee believes that, going forward, the House 

would be better served by different guidance with regard to Member participation in advertisements. Therefore, the Committee 

takes this opportunity to clarify its guidance with respect to Member participation in advertisements or other commercial endorsements of goods or services. Under no circumstances should a Member be actively involved in personally selling or endorsing good 

services in which the Member has a financial interest.56

Accordingly, the Committee unanimously voted to adopt this Report, and take no further action. Upon publication of this Report 

and repayment of $40,000 to Mullin West, the Committee considers 

the matter closed. 

VI. STATEMENT UNDER RULE XIII, CLAUSE 3(c) OF THE 

RULES OF THE HOUSE OF REPRESENTATIVES 

The Committee made no special oversight findings in this Report. 

No budget statement is submitted. No funding is authorized by any 

measure in this Report. 


SSpencer on DSKBBXCHB2PROD with REPORTS
17 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 22 HR898.001
18 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 23 HR898.002
19 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 24 HR898.003
20 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 25 HR898.004
21 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 26 HR898.005
22 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 27 HR898.006
23 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 28 HR898.007
24 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 29 HR898.008
25 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 30 HR898.009
26 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 31 HR898.010
27 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 32 HR898.011
28 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 33 HR898.012
29 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 34 HR898.013
30 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 35 HR898.014
31 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 36 HR898.015
32 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 37 HR898.016
33 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 38 HR898.017
34 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 39 HR898.018
35 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 40 HR898.019
36 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 41 HR898.020
37 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 42 HR898.021
38 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 43 HR898.022
39 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 44 HR898.023
40 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 45 HR898.024
41 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 46 HR898.025
42 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 47 HR898.026
43 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 48 HR898.027
44 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 49 HR898.028
45 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 50 HR898.029
46 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 51 HR898.030
47 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 52 HR898.031
48 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 53 HR898.032
49 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 54 HR898.033
50 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 55 HR898.034
51 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 56 HR898.035
52 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 57 HR898.036
53 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 58 HR898.037
54 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 59 HR898.038
55 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 60 HR898.039
56 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 61 HR898.040
57 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 62 HR898.041
58 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 63 HR898.042
59 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 64 HR898.043
60 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 65 HR898.044
61 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 66 HR898.045
62 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 67 HR898.046
63 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 68 HR898.047
64 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 69 HR898.048
65 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 70 HR898.049
66 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 71 HR898.050
67 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 72 HR898.051
68 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 73 HR898.052
69 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 74 HR898.053
70 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 75 HR898.054
71 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 76 HR898.055
72 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 77 HR898.056
73 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 78 HR898.057
74 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 79 HR898.058
75 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 80 HR898.059
76 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 81 HR898.060
77 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 82 HR898.061
78 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 83 HR898.062
79 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 84 HR898.063
80 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 85 HR898.064
81 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 86 HR898.065
82 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 87 HR898.066
83 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 88 HR898.067
84 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 89 HR898.068
85 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 90 HR898.069
86 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 91 HR898.070
87 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 92 HR898.071
88 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 93 HR898.072
89 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 94 HR898.073
90 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 95 HR898.074
91 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 96 HR898.075
92 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 97 HR898.076
93 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 98 HR898.077
94 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 99 HR898.078
95 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 100 HR898.079
96 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 102 HR898.081
97 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 103 HR898.082
98 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 104 HR898.083
99 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 105 HR898.084
100 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 106 HR898.085
101 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 107 HR898.086
102 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 108 HR898.087
103 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 109 HR898.088
104 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 111 HR898.090
105 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 112 HR898.091
106 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 113 HR898.092
107 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 114 HR898.093
108 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 115 HR898.094
109 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 116 HR898.095
110 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 117 HR898.096
111 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 118 HR898.097
112 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 119 HR898.098
113 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 120 HR898.099
114 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 121 HR898.100
115 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 122 HR898.101
116 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 124 HR898.103
117 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 125 HR898.104
118 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 126 HR898.105
119 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 127 HR898.106
120 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 128 HR898.107
121 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 129 HR898.108
122 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 130 HR898.109
123 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 131 HR898.110
124 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 132 HR898.111
125 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 133 HR898.112
126 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 134 HR898.113
127 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 135 HR898.114
128 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 136 HR898.115
129 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 137 HR898.116
130 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 138 HR898.117
131 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 139 HR898.118
132 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 140 HR898.119
133 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 141 HR898.120
134 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 142 HR898.121
135 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 143 HR898.122
136 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert graphic folio 144 HR898.123