Outline for Meeting with John Richardson and Campaign

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November 30, 2009

MANAGING CAMPAIGN FUNDS

(BOTH SEED MONEY AND MCEA FUNDS)

All campaign funds must be deposited into a separate account, including seed
money. Please do not convert seed money to cash.

Campaign funds may not be commingled with other funds.

Commission staff strongly encourages making expenditures directly from

campaign bank account, rather than paying the vendor with other (personal)
funds and seeking reimbursement from the campaign. Advantages:

• Campaign bank account will show all dates and amounts of payments.
This will be useful in preparing campaign finance reports.

• Campaign will have ready access to documentary proof that the vendor
received payment (e.g., a canceled check or a bank account statement
that lists the vendor as the payee).

LEGAL REQUIREMENT TO KEEP RECORDS

(21-A M.R.S.A. §§ 1016(3) and 1125(12-A)
(records will be requested in the post-election audit)

Purpose: to document (create an audit trail) that the reported vendor provided
valuable goods and service to the campaign, and that the vendor received
payment.

1. Account statements. Bank or other account statements for the campaign

account covering the entire campaign. (May be requested by Commission staff
in March 2010 to verify seed money collected.)

2. Vendor invoices. An original invoice or receipt provided by the vendor for

every expenditure of $50 or more that states the particular goods or services
purchased.

3. Proof of payment. A written record verifying that the vendor received the
payment, for every expenditure of $50 or more. Most commonly, this is a
canceled check or a receipt from the vendor showing that the vendor received
payment. The Commission will accept other forms of proof of payment, such as
a bank account or credit card statement showing a transaction that includes the
name of the vendor as the payee.
 Outline for Meeting with John Richardson and Campaign
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November 30, 2009

4. Detailed description of services received worth $500 or more. For any

services (especially campaign staff and consulting services) provided to an
MCEA campaign by a vendor to which the campaign paid $500 or more during
the election cycle, the campaign must keep invoices, timesheets, or other
documents specifying in detail the services which the vendor provided, the
amount paid, and the basis for compensation paid by the campaign.

Purchases made by a consultant and others for the campaign

Record-keeping. The regular record-keeping requirements apply to purchases
made by consultants and others on behalf of the campaign. For expenditures of
$50 or more, the campaign must obtain:

• an invoice or receipt from the ultimate vendor stating the particular goods
or services purchased, and

• proof of payment that ultimate vendor received payment (e.g., canceled

check, receipt marked paid, account statement showing the vendor as
payee)

Campaign finance reporting. Campaign must itemize purchases made by

consultant in campaign finance reports as though the campaign made the
purchase directly (see pages 43-44 of guidebook)

Documenting purchases of advertising time

Candidate must collect invoices or another accounting statement from each
broadcast station and cable company documenting the total value of advertising
time purchased on behalf of the campaign.

2010 MCEA EXPENDITURE GUIDELINES

Required Log for Reimbursements for Travel

If campaign uses MCEA funds to reimburse candidate or supporter for car travel,
the person reimbursed must complete a travel log that the campaign keeps in its
records. Without the travel log, the Commission may disallow the expenditure of
MCEA funds.

Electronics and other Personal Property

Goods purchased with MCEA funds (not seed money) that could be converted to
candidate’s personal use must be reported on Schedules B and E, and must be
sold after the election for fair market value.
 Outline for Meeting with John Richardson and Campaign
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November 30, 2009

POST-ELECTION AUDIT

Minimizing the audit:

• Keep all required records

• Compare reported contributions and expenditures to actual credits and
debits in the campaign bank account
• Make sure consultants obtain required records

QUALIFYING FOR MCEA FUNDS

New requirement: collect $40,000 in seed money contributions from

registered Maine voters

Documentation for contributions must be submitted to the Commission by 5:00

p.m. on April 1, 2010 (see required records listed below)

Campaign does not need to submit proof of voter registration of contributors.

Commission staff will verify registration.

Campaign can collect up to $200,000 in seed money contributions from

individuals

Next campaign finance report due Tuesday, January 19th, 2010 (11:59 p.m.)

Required documentation for $40,000 in seed money contributions

Photocopies of checks and money orders

Each contributor must complete and sign the written acknowledgment form –
except those made by internet on the campaign website.

• The campaign may use a modified form approved by the Commission.

• On-line contributors may make acknowledgement electronically on the
campaign website.

List of seed money contributions in a format determined by Commission (please

see attached instructions)

Transaction report from bank or other credit card processor that contains
cardholder name and that meets specifications of Commission (must include
transaction i.d. or some other information that ties the payment received to the
list of seed money contributions)
 Outline for Meeting with John Richardson and Campaign
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November 30, 2009

Qualifying contributions

3,250 contributions of $5 or more, by check, cash, or electronic payment on the

Commission’s website

Contributors who give in cash must sign a money order

All contributors must sign the Receipt and Acknowledgment form (R&A) form –
except those made by internet on Commission’s website.

Campaign takes R&A form to town clerk to verify registration status of the
contributor

The Commission website will attempt to verify the voter registration of each
contributor. If the software cannot verify the contributor’s voter registration, it is
the campaign’s responsibility to verify the registration with the town clerk and to
submit the written verification by 5:00 p.m. on April 1, 2010

Purchasing money orders to use for cash contributions (reviewed in the

audit)

Keep a record of every purchase of money orders, showing the date, number of
money orders purchased, and amount of purchase (face value of money orders
plus transaction fees)

If you use personal funds to buy money orders, the campaign should

• Report the transaction fees as an in-kind contribution, or

• Use seed money to reimburse the purchaser for the fees

Deadline for submitting qualifying papers to Commission staff

All qualifying papers must be submitted to the Commission by 5:00 p.m. on April
1, 2010, except the candidate may request extensions only for

• seed money campaign finance report

• alphabetical list of qualifying contributions
• Request for Certification form

Under the Commission’s rules, the Commission may not grant an extension for
the other qualifying papers.