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FEDERAL ELECTION COMMISSION
WASHINGTON, D.C. 20463
RQ-2
October 29, 2013
LISA R. LISKER, TREASURER
RUBIO VICTORY COMMITTEE
228 S WASHINGTON STREET SUITE 115
ALEXANDRIA, VA 22314
Response Due Date
12/03/2013
IDENTIFICATION NUMBER: C00494617
REFERENCE: APRIL QUARTERLY REPORT (01/01/2013 - 03/31/2013)
Dear Treasurer:
This letter is prompted by the Commission's preliminary review of the report referenced
above. This notice requests information essential to full public disclosure of your
federal election campaign finances. Failure to adequately respond by the response
date noted above could result in an audit or enforcement action. Additional
information is needed for the following 2 item(s):
1. Commission Regulations require that a committee discloses the
identification of all individuals who contribute in excess of $200 in a calendar
year. (11 CFR § 104.3(a)(4)(i)) Identification for an individual is defined as the
full name (initials for first or last name are not acceptable), complete mailing
address, occupation, and name of employer. (11 CFR § 100.12) Your report
discloses contributions from individuals for which the identification is not
complete.
You must provide the missing information, or if you are unable to do so, you
must demonstrate that "best efforts" have been used to obtain the information.
To establish "best efforts," you must provide the Commission with a detailed
description of your procedures for requesting the information. Establishing
"best efforts" is a three-fold process.
First, your original solicitation must include a clear and conspicuous request for
the contributor information and must inform the contributor of the requirements
of federal law for the reporting of such information. (11 CFR § 104.7(b)(1))
See 11 CFR § 104.7(b)(1)(B) for examples of acceptable statements regarding
the requirements of federal law.
Second, if the information is not provided, you must make one follow-up, stand
alone effort to obtain this information, regardless of whether the contribution(s)
Campaign Finance - Rubio, U.S. Federal Election Commission, Rubio Victory Committee, Missing Information in April Quarterly Report (2013)
U.S. Federal Election Commission · Oct. 29, 2013
The Federal Election Commission issued a compliance notice to the Rubio Victory Committee regarding incomplete contributor identification and undisclosed political action committee contributions in its April 2013 quarterly report. The agency requested amended filings or documentation of best efforts to obtain the required information by December 3, 2013.
campaign finance fec violation
Document text
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RUBIO VICTORY COMMITTEE
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was solicited or not. This effort must occur no later than 30 days after receipt of the contribution and may be in the form of a written request or an oral request documented in writing. (11 CFR § 104.7(b)(2)) The requests must:
• clearly ask for the missing information, without soliciting a contribution,
• inform the contributor of the requirements of federal law for the reporting of such information, and
• if the request is written, include a pre-addressed post card or return envelope.
Third, if you receive contributor information after the contribution(s) has been reported, you should either a) file with your next regularly scheduled report, an amended memo Schedule A listing all the contributions for which additional information was received; or b) file on or before your next regularly scheduled reporting date, amendments to the report(s) originally disclosing the contribution(s). (11 CFR § 104.7(b)(4))
Please amend your report to provide the missing information or a detailed description of your procedures for requesting the information. For more information on demonstrating "best efforts," please refer to the Campaign Guide.
2. A review of the reports filed by your committee (see attached) indicates that your committee received one or more contributions from political action committees which has not been disclosed on their report(s) of receipts and disbursements. Please clarify if the contribution(s) was received from the disclosed donor's federal account and amend your report(s) if necessary.
Please note, you will not receive an additional notice from the Commission on this matter. Adequate responses must be received by the Commission on or before the due date noted above to be taken into consideration in determining whether audit action will be initiated. Failure to comply with the provisions of the Act may also result in an enforcement action against the committee. Any response submitted by your committee will be placed on the public record and will be considered by the Commission prior to taking enforcement action. Requests for extensions of time in which to respond will not be considered.
Electronic filers must file amendments (to include statements, designations and reports) in an electronic format and must submit an amended report in its entirety, rather than just those portions of the report that are being amended. If you should have any questions regarding this matter or wish to verify the adequacy of your response, please contact me on our toll-free number (800) 424-9530 (at the prompt press 5 to reach the
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RUBIO VICTORY COMMITTEE
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Reports Analysis Division) or my local number (202) 694-1162.
Sincerely,
David Butler
Senior Campaign Finance Analyst
Reports Analysis Division
313
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Excessive, Prohibited, and Impermissible Contributions
RUBIO VICTORY COMMITTEE (C00494617)
Contributor Name
Date
Amount
DYKEMA GOSSETT FEDERAL PAC
2/13/13
$1,000.00
EDWARDS WILDMAN PAC INC
3/8/13
$5,000.00
2013 April Quarterly
Report
2013 April Quarterly
Contribution(s) Received, Not Disclosed by Donor(s)
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