This file contains archived live captions of the audit hearing of the Colorado Republican Committee held by the Federal Election Commission on Decenber 06, 2016.  This file is not a transcript of the meeting, and it has not been reviewed for accuracy or approved by the Federal Election Commission.


	>>  Good morning to everyone.  The  audio hearing for federal commission for Tuesday, December 6, 2016 will begin.  We are considering the draft final audit report on the Colorado Republican Committee.  We have Chris Murray who is representing the audited Committee and will give a presentation.  Just to state how we're going to proceed, we will give Mr. Murray an opportunity to give an opening statement which is accompanied by a PowerPoint presentation.  So we're going to lower the screen.  So we will all, in just one moment, take seats in the front row so we can follow along in that PowerPoint presentation.  And then once that's finished, if you want to reserve some time for a wrap-up, summary at the end, but after your intro, commissioner, we will open it up for Commissioners to ask question and then we'll proceed at this point.  This is being conducted in pursuant to a policy that was passed by the commission a few years ago.  The reference to this procedure is in  directive 70.  And why don't we take our seats in the front row and then Mr. Murray, we'll turn it over to you to give your presentation. 
	>>  Thank you Chairman Peterson. 
	>>  Madam secretary, is there any way for me to see the presentation? 
	>>  The presentation should be coming through on the video portion. 
	>>  Okay.  Video portion.  Okay.  Thank you. 
	>>  Steve has a copy of the PowerPoint.  And he's going to send it to you as soon as we can get the computer squared away. 
	>>  Okay.  Thank you very much. 
	>>  Members of the commission, thank you for the opportunity to address you.  If it's okay, I'm going to look a little awkward.  I hope you will look at the screen and not at me as I crane my neck to try to address and you also present the PowerPoint.  This is intended to be a short summary of the basis for the Committee's disagreement with audit division staff on finding 1C and finding 4 in the DFAR.  And I anticipate this will be about 5 to 10 minutes. 
	 Okay.  Members of the commission, the Committee requested a hearing on two issues.  Again, finding 1C and this is the audit division recommendation.  And the issue of the Colorado Republican Committee which is the Committee here, the  issue of its control of the Colorado RNC host account which is, it's what we'll go into the formal name of that entity in a moment which is 501 ( c ) 4 which is a party independent and is not control and is not a Committee required to register or report. 
	 And second is finding 4, which I believe is a little bit simpler issue.  Which is the audit division recommendation that amounts claimed and invoices forget out the vote vendor strategic alied consultants LLC, but disputed and never paid by CRC are nonetheless reportable debt.  And, so, first, we've got the RNC host account.  The important communication with the audit division occurred on January 8, 2014 from the former CRC Chairman.  That gentleman's name is Ryan Call.  He explained what the RNC host account was and it was a separate entity not controlled by the RNC.  And a copy of this e-mail or pertinent portion of the e-mail is there in the PowerPoint.  As you can see, Mr. Call let audit staff know that what the host account was.  It was created to facilitate compliance mainly with article 41 of the Colorado constitution relating to gifts.  It paid for some cultural activities  experiences for members of delegations from Colorado and other states at the Tampa convention. 
	 The e-mail attached to me document to back up Mr. Call's representation including the articles of incorporation for the entity which reference its legal name which is the Colorado Chairman host Committee for the Republican national convention.  The e-mail listed the registered agent before the Committee which at the time was Timothy Gilmore.  Mr. Gilmore, incidentally we're unaware of any effort by audit division to contact Mr. Gilmore or anybody associated with the RNC host account.  I am sitting here front of you unaware of such efforts.  Also, we didn't just provide the form by-laws.  And articles -- I'm sorry, the form articles and incorporations.  We provided the detail articles.  And as you'll see in a moment, the by-laws.  The articles provided information on who had the power to amend the by-laws and it's this Board of Entities.  
	 And the by-laws were included with that e-mail and they included and specified who could direct the entity to make expenditures and again, that's at the discretion of Board of Directors or cooperation which were none of the individuals who controlled the CRC.  And there's some dispute in the record about this and I want to be perfectly candid with the commission.  It may not be a dispute.  It may be a lack of clarity as to when the IEN number for this entity which is separate from the CRC EIN number was different.  I was not a CRC general counsel at the time the audit again.  I just began in the spring of this year, so I kind of jumped into the middle of this, basically when we got the original, the interrim draft audit report.  And I believe and the copy, it's unclear from the copy of the e-mail I have whether this EIN was provided in January of 2014 with Mr. Call's e-mail, or if as it states in the  audit draft report, it was provided at the exit interview.  I've asked my client if they can remember exactly when this was provided.  I don't have a verbatim copy of the e-mail with its attachments.  I had to sort of piece it back together myself.  It is my belief, based on the way these files were kept that this EIN was provided by Mr. Call in January 2014, but at the latest, it's was provided at the exit interview when additional documentation was requested.  And, again,.  EIN is separate from the EIN for the CRC. 
	 Now, in the draft final audit report, the audit division states they they have obtained pertinent bank documentation confirming the CRC's EIN was not associated with the convention account.  Respectfully, remembers of the commission, this is not information that CRC was obligated to provide the staff.  Again, enough information was provided because it happened to be within the control of CRC that demonstrates that this is a separate legal entity.  But we're asked to prove a negative, right?  That we don't control this entity, and that it is not a party Committee that is required to register.  Respectfully, if anybody should have that legal duty, it is the RNC host accounts and the members who run it.  Who are separate individuals and separate account, it's kept separate from the party expectly for that reason.  The CRC beliefs it has provided more than enough demonstration that it doesn't control this account or registered or report. 
	 All right.  The second issue is finding for, this is the alleged vendor debt.  And, again, in December of 2014, so almost a year after the e-mails were laid into the RNC host account, I believe this is one of the sort final issues that was getting cleaned up with audit staff.  CRC had consistently maintained that this $133,487 which have live invoices saying Colorado Republican Committee, you owe us this money and contract.  And this was turned over by the division and staff, and the number is accurate.  We have no dispute over the number.  The issue is whether or not this had to be disclosed, this debt.  And CRC has taken a consistent position that no services were provided under this contract.  And the contract was terminated very shortly after it was signed because of a dispute with the vendor.  Again, I'm not 100% privvy to what that was. 
	 This is a copy of the termination letter as audit division staff notes.  This copy is not signed of I cannot locate a signed copy of the termination letter.  The termination letter of the signed copy was apparently mailed.  And a photocopy of it with Mr. Call, who again was the Chairman at the time with his signature on it was not retained by my client.  With that said, we now have the benefit of, we're sitting here in 2016.  It has been coming up on, well, it has actually been over four years since this debt was allegedly incurred.  CRC has never paid this debt.  Strategic ally has never filed suit against CRC or made any other claim other than the invoices which were turned over in the audit.  And the statute of limitations in Colorado for many states is for two years.  So that statute is run.  Even if it is reportable, it turns out the commission finds this is reportable debt, it is uncollectable and CRC will not pay.  If the CRC is required to report this debt, this is debt that will never come off CRC debt.  It will sit there as phantom debt.  We don't believe that helps the -- and rerecognize this is a down to the structure because committees can always say we don't owe the money and that's all sorts of issues that can happen there.  There could be hidden contributions if you pretend this commission is the dark side of when people say, oh, well, it's not really a debt.  And I understand that.  But this is a legitimately reviewed debt and CRC has been through the process and beliefs this money has never been paid. 
	 It is possible, that at least if the commission finds this should have been reported at the time, and then should have come off maybe when the statute of limitations were in, that would be a position that the committee would be willing to accept.  It just does not want to leave this debt permanently on its reports.  And with that, I thank all of you for your time and look forward to your questions.  And I look forward to addressing you looking forward. 
	
	>>  All right.  All right.  We're now reconstituted.  Mr. Murray, thank you for your opening remarks and summary of the argument that you want to present before the commission.  It is now time to open up questions for commissioners they may have regarding questions at issue.  Commissioner wine Trump. 
	>>  Thank you for coming in and you're very well-organized presentation. 
	 I guess, I want to -- I'm not sure that I'm understanding exactly what your argument is on the disputed debt.  You know that there's a process for reporting disputed debt as opposed to, I guess, one could call it "acknowledged debt." So is it your position, and you referred to it as several times as disputed.  So is it your position that it's they have given up on it so it's no longer a disputed debt?  Or because it's passed the statute of limitation, it's uncollectable anyway? 
	>>  That's correct.  It was disputed at the time.  And, so, again, while what we see in the DFAR and this may be a misunderstanding, but we see a D factors recommendation that we amend our reports coming all the way to the present to show this debt as unpaid. 
	 And if that is the position of audit division staff, then we don't believe that we can do that.  Could we amend our provider reports to show this, you know, as disputed debt at the time of payment?  Absolutely, we could do that. 
	>>  And you're not opposed to doing that? 
	>>  No, we're not. 
	>>  Okay.  I just want to be clear on your position. 
	>>  Let me go back.  This vendor, this disputed debt, did this vendor provide any service to the party and/or did it perform partially on the contract for some services?  But then you disputed owing them after a certain time?  Or did you not pay them for any services dispute owing them for any services at all? 
	>>  My understanding was that the party had used this vendor before.  So had paid them for other services.  But --
	>>  In connection with other elections and not this election and get out the vote vendor? 
	>>  Correct. 
	>>  So is it your representation that the party received no services from this vendor in connection with this election? 
	>>  No, I know some services, which were not requested were rendered.  Whether the services -- issue were services were at all issue or counter-productive.  So something happened.  This was not just a phantom invoice that strategic alliance generated and they did absolutely nothing.  Again, and I apologize that I was not party counsel then.  And I know we're here 4 years later and it's not helpful to you.  But this was not an invoice for $133,000 that just showed up, right? ?  Nothing had actually been done.  My understanding is that the contract was entered into, and then it became very clear the minute the services began to be provided that the vendor was not doing what was contracted for and was not capable of doing it on the time scale.  And, so, the contract was terminated. 
	>>  Promptly? 
	>>  Yes, I believe the contract was -- I believe the contract was executed a couple months before, but no services were due to be provided until September of that year, and the termination happened in September.  I know it's just couple of weeks afterwards.  
	>>  And the statute of limitations ran when? 
	>>  So the invoice came in, I believe by the end of September or early October.  It's been a while since I looked at that invoice.  But the invoice came in, let's say October of 2012, it went unpaid.  I think it was due on 30 days notice.  So let's say you know they're in breach of November 2012, so the statute of limitations ran no matter what in November of 2014. 
	>>  And you don't have any correspondence with the vendor? 
	>>  Not that I've been able to locate.  And I apologize, commissioner. 
	>>  Commissioner Winetrump
	>>  So the vendors think you owe them the money? 
	>>  I don't know where the vendor is. 
	>>  When was the last time your Committee had contact with this vendor? 
	>>  Over two years ago.  I mean, that's a ballpark.  I asked my client this question figuring I might get it.  And in our last executive director's term, so it was over two years ago.  Because the current executive director had no contact. 
	>>  So they're not pressing to collecting this debt? 
	>>  I've been general counsel to the Committee March of this year, and I've heard nothing from them at this time and I heard from other vendors who want to be paid so I have not heard from Strategic Alliance. 
	>>  Thank you for the presentation, and, by the way, say, "Hi" to Frank Schreck.  I was there in Las Vegas couple of years ago. 
	 The question I had on the, and since we're having a colloquy on this, what have you discussed with our staff about just amending those reports that shows this dispd? 
	>>  And no, that's on me.  It took me a while to get to the point, because I have taken over the Committee council.  Frankly, I got to a point where I was comfortable with what happened here because there's real reporting requirements that come up with this and as you can imagine, and the response to this audit, we have made already substantial audits from the past reports.  And since I've become counsel, we've agreed to amend the staff reports.  And, so, every time we do that, there's a political consequence within the party that we have to change these reports.  And, so, before we make another amendment, I wanted to be sure it was proper.  So no, there has not been colloquy with the division staff  it is on me. 
	 And it says please prepare the final invoice, and it says we will make arrangements for the prompt and final payment of authorized fee incurred.  So it sounds like to me at the towards the relationship, there was discussions about recognition of services that were not satisfactory.  We will pay them and it's a recommendation and kind of acknowledgement there's probably something owed.  And, so, given that, it looks to me it's pretty much it was there and it was disputed, and it was never enforced by either side, certainly by them. 
	 But I'm just, it seems to me there might be a right way to resolve it. 
	>>  One thing I will say about that letter --
	>>  Any thoughts on that? 
	>>  I apologize.  I have asked former Chairman Call to assess the letter.  Did they provide it and do you remember?  And that letter, former Chairman Call is himself a lawyer and practices election law.  And apparently, that letter was a form letter that was used for terminations.  He had a form letter for anything.  He's a pretty organized guy.  So it was a form letter that was used for if a dispute with a vendor came up and took that out of the firm's practice, he could not remember if there were actually services provided that they paid for and that paragraph was intended to acknowledge something real, or it was just in there because of the contract termination letter. 
	>>  Well, it seems to me, I guess you don't have a signed copy, right? 
	>>  I do not, no. 
	>>  You're kind of stuck with the language here.  And I don't mean it in a negative way.  Maybe it seems to me a solution would be and I don't know what the staff feels about that, but that's one issue that can be resolved in that way. 
	>>  It may be. 
	>>  That's all I have for the moment. 
	>>  Commissioner Goodman. 
	>>  Have you discuss we had your report analyst the constructer of reporting disputed debt, and then how to retire that debt once the dispute is resolved one way or another? 
	>>  Yes, our accountant is familiar how to do that as well. 
	>>  Okay. 
	>>  I have more questions.  
	>>  Sure.  Go ahead. 
	>>  Shifting subjects.  Do you know who the officers and directors of the Chairman's Committee are? 
	>>  As of today, I believe the Chairman --
	>>  So the entity still exists? 
	>>  I think it's dormant.  But as of today, Mr. Gilmore is still the head of that entity. 
	>>  Is Mr. Gilmore, do you know Mr. Gilmore? 
	>>  I do not.  I know he's with Brownstein.  I know he left so he's not with Brownstein anymore. 
	>>  This Committee was formed and put into place with the Brownstein attorneys, just the cork of -- Denver is a small town.  So I didn't join Brownstein until 2015, and it's formed over there.  Now it's somewhere else. 
	>>  Do you know if Brownstein is still the registered agent? 
	>>  Brownstein is still the registered agent. 
	>>  Do you know who it is now? 
	>>  I believe it is a woman named Melissa  Kypers
	>>  Do you know at the time who the officers and directors were? 
	>>  I don't know.  I believe, I don't know that there are anymore people other than Ms. kypers Was listed here.  If there was more people, I don't know here. 
	>>  I was struck by, you made representation that none of the people who controlled the Chairman's Committee controlled the state party. 
	>>  Correct. 
	>>  So do you know who the officers and directors who controlled the Chairman's Committee were? 
	>>  Again, I know it was controlled by Ms. kyper And Gilmore.  Other thing I was able to establish withcertainty. 
	>>  They were not party people. 
	>>  I asked them if they were the Board on this thing and they said, no.  Was there any executive director or party staff on there?  Were there any members of the party Executive Committee on there?  And the answer was no. 
	>>  Any explanation for how the bank record ended up on the party? 
	>>  No.  I wouldn't be surprised at all.  Because I practice in this space and these committees are relatively common.  I wouldn't be surprised if it was an idea that was hatched at the time party.  And some friends went out and then did it and it was left to them.  
	>>  Umm-hmm. 
	>>  Mr. Vice-Chairman. 
	>>  Thank you.  I wasn't sure from the conversation before that we started today whether or not there was reluctance to provide information, because it was felt it wasn't necessary or because the information was not available to you and you didn't want to go hunt it down? 
	>>  So the answer is --
	>>  Either point on one.  We're asked to get information you don't have or normally would not have.  On the other hand, some of these documents are in the possession.  So it seems to me, there was a Nexus here where there could be some information that has been asked for that would be forthcoming.  So I'm curious to know what your attitude is on providing information that, the Chairman. 
	>>  Any information that the Committee has on its position, we're happy to provide.  And my understanding it's all been provided.  And, so, when it comes down to, again, and I know this isn't an ideal posture and I hate to be the new kid on the block.  But it comes down to, we've had new party officers.  And I step into this, and there are no -- I do have to go chase down records from an entity that I don't control if we're going to provide more information at this point, whether that was true at the time that the party was interacting with audit division staff earlier, candidly I can't tell you.  I believe it was true at the time as well.  But they provided everything they had.  And that's how these questions came up in the first place.  And then when it got to the end of the road for, you know, there's no information in our files, we said look, we gave you everything we've got.  We're not going to chase stuff that's not under our control. 
	>>  The bank records, do you have a copy of the document that was signed with the bank to create that account? 
	>>  I do not.  No. 
	>>  And that would be recoverable, wouldn't it be? 
	>>  If the Committee -- recoverable, certainly through the Chairman's host account.  Certainly.  That document has to exist somewhere. 
	>>  So is there a reluctance to get that? 
	>>  Well, I wouldn't say reluctance to help get it.  But the issue is that we don't have legal control over that entity.  And at the end of the day, we don't believe it's promote to hold the Committee responsible the entity for not being able to chase down something that doesn't have the authority to go get.  So we could try to help, but if we're unsuccessful I think doing it because this thing is dormant, and/or the person says we don't want to provide it, we have no legal authority to force them to do that. 
	>>  You know, they refused? 
	>>  I'm not aware that they refused.  I'm also not aware that the request has been made. 
	>>  You understand the presumption of the audit report is that from January of 2012 to June of 2012, the auditors suspect this organization may have used the EIN number of the Colorado state party.  You've seen anything that in your state party records that would indicate your client's EIN number was used? 
	>>  No. 
	>>  One further question.  You did not request an audit, so if you want to defer on this, you can.  But I'm just curious about why you didn't want to discuss the volunteer mail issue.  And whether you were interested in submitting affidavits or post hoc analysis or recognition of people in the direct e-mail. 
	>>  Commissioner, thank you for asking.  The honest reason is that, we believe this issue has been tangled with by the commission before.  And the guidance is clear here.  The sort of the record the audit division was asking for here, while they may be helpful, they're not the sort of thing the audit division, you know, has ever asked for before.  And it's not sort of the evidence that's been required before for the application with that exception.  And I think the record, as it stands, we're comfortable with it.  We believe for the mail pieces that we qualify for under that, that the cards that we submitted which are all the records in our position, and, again, you're dealing with volunteers, again, from long time ago.  It would be a wild goose chase to get post records from volunteers I can't track down anymore. 
	>>  Or people who operated the direct mail program.  We've seen affidavits before from the people who operated the direct mail from that election sfu. just need one or two affidavits from the people who ran it.  That would be suffice. 
	>>  Well, commissionerer, that would be something we attempt to submit. 
	>>  That was a softball. 
	>>  I do want to make the point that we do think some of the, you know, the information that was requested by the audit division here, if there's going to be guidance from the commission going forward, we should have copies of photo I.D., we would be happy to do but it's not something we were required to do at the time. 
	>>  Commissioner. 
	>>  Thank you.  Question about the EIN.  [Phone ringing] I think we lost Commissioner Revel.
	>>  Hearing room.  [Phone line]
	
	>>  You've provided us with a presentation of the copy of the Colorado Chairman host Committee EIN, which I take it was something that you had? 
	>>  This was something that was provided to the audit division.  I believe all the  way back in January of 2014.  That's how I have it. 
	>>  Right.  So that was within the position of the Committee. 
	>>  Correct.  Everything, obviously everything I've shown the commission is in the possession of the Committee. 
	>>  Well, I don't know.  Maybe -- that would be a logical assumption.  But not necessarily, you know, you could have called somebody else up and said, hey, I think this would be helpful for us to have it.  Do you happen to have it?  So I don't want to make any assumptions.  Maybe I'm just not understanding this issue.  Is that your EIN number?  The number they were using is that the one the Committee was also using?  It seems to me that you can verify that easily. 
	>>  This is not the CRC EIN number.  Yeah.  I wish I could quote the CRC EIN number off the top of my head.  I should have been prepared to do that. 
	>>  I thought I heard you say in your presentation that, you know, it would be complicated for you to proof the negative.  But it strikes me to provide here's our EIN number, here's their EIN number, they're not the same number. 
	>>  That's very fair.  Our audit division knows our EIN number, maybe I'm wrong, but it certainly would be something we can provide if that would be helpful. 
	>>  It seems to me, that can solve your,we can solve a negative problem fairly in straightforward way
	>>  Commissioner hunter. 
	>>  Does the audit staff want to comment on that? 
	>>  Mr. Murray, all along we have tried to get a statement from the Committee from the bank that states what -- that this account number is not associated with Colorado's EIN.  That this bank account has a different EIN number.  Can you provide -- could you provide a statement from the bank that says this bank account is not associated with it, with the Colorado EIN? 
	>>  That's something I cannot guarantee.  Because, again, we do not have control of that entity. 
	>>  No, the Colorado's bank account.  All Colorado's bank account, the accountant question that we're asking about, the convention account, the convention bank account.  
	>>  Oh, that Colorado's EIN is not being used on accounts? 
	>>  That is not being used on this particular bank account.  
	>>  That is probably something we can provide. 
	>>  That's all we wanted.  Thank you. 
	>>  If you were to receive that, that would satisfy the concerns that's been expressed bicep the Committee. 
	>>  Again, I have not made that sort of request to our bank yet in my capacity counsel.  So I don't know if I'm going to run into some hiccups there.  So I hear what you said, and that's something I'm interested in providing. 
	>>  Are there any further questions?  And the only questions I had when I was going over this matter where, and I believe you already addressed them.  But let me just confirm.  One is that not only is the host account a separate legal entity, but the Colorado Republican Committee has no control over it.  There were no overlapping officers and so forth which indicates there's more of a formal relationship between the entities. 
	>>  That is correct.  And that was deliberate.  And my understanding is that was done deliberately there would be absolutely no overlap and the party aired on the side of safety there. 
	>>  From the debt issue, from what I understand from your argument and correct me if I'm wrong, the chief concern you have is any obligation that would impose upon you to require you to put down the debt in your reports and carry that forward somewhat indefinitely.  That if it were, if there were some requirements to report some finite period of time of disputed debt when it would have still been alive on the Colorado book.  From October 12 to November 14.  Then that would be something that you would potentially consider doing.  Or I'm just -- since those were the numbers you gave me that's what I was using.  But what you do not want to have an obligation is carrying forward this $133,000 and change to the vendor to have to continually report that going forward as either debt or dispute debt. 
	>>  Right.  And I should be very clear.  I used the statute of limitation just to illustrate how dead this debt is.  Under, you know, I'm not an accountant and I did not stay at Holiday Express last night.  But the debt, I mean, it is my understanding, again, that there were other than an initial invoice, there were never any serious, I can't find any serious attempt to collect this.  And, so, while --
	>>  Just a single invoice. 
	>>  They may have been two.  But it's my understanding there's never any serious attempt to collect this.  So if it has to show up on an earlier report, we would appreciate guidance either from the commissioners or audit division staff as to when it should show up.  I do not think it should show up until the two year statute of limitation of the contract run. 
	>>  I was just use that go date since that's when the statute ran, and that was the kind of outer boundary.  I'll turn it over to the audit division. 
	>>  Commissioner, thank you.  Mr. Murray, at one point in your presentation, you said something about an October 2012 invoice? 
	>>  Umm-hmm. I used that as an example.  I wasn't sure when the invoice came in whether it was September or October sitting here because I don't have it in front of me. 
	>>  So was there an invoice after that termination letter was sent? 
	>>  I don't know if there was an actual invoice.  My point is that, there may have been -- if there were any invoices, they were never followed up on, right?  And there was never any attempt to made to collect any real debt. 
	>>  Okay.  Because we never did see an invoice.  And I just want to make sure. 
	>>  Okay
	>>  Just for the record, to the extent this group was to perform any services, the get out the vote services which would have been performed from August to November or September to October.  And it usually a service rendered very close to the election. 
	>>  Absolutely.  So my understanding was that this was something that, to the extent services were provided, and I believe, as I've said earlier, there was some sort of activity by this vendor.  Because at the time, it was a real vendor.  I think I would say it happened immediately after the termination letter and they weren't able to perform. 
	>>  The termination letter is dated September 27.  So it would have been right around the time get out the vote drive was getting underway.  
	>>  Correct. 
	>>  Just one more follow-up question, Mr. Murray.  So the contract was for $600,000.  And the termination letter referred to a contract in July, and another contract in September.  And there were payments made in July and August, which this is how we calculated the 33.  So there were some services by this period. 
	>>  Thank you for that clarifying questions.  We're only disputing under this later contract which was for the GOTV work. 
	>>  Commissioner Wientrump.
	>>  Thank you Chairman.  Going back to the host account, you said something --
	>>  [Coughing] I apologize. 
	>>  You said something that indicated that you think the Genesis of this host account may have been that people within the party Committee asked their friends to organize this? 
	>>  I shouldn't have been so not percise in my words.  I don't know.  I just don't now how this was formed.  I said based on my experience practice in this area, I wouldn't be surprised at all if somebody whether on the party Executive Committee who had a good idea to do it, right?  And somebody went out and did it.  But I don't know that.  I don't know the answer to your question. 
	>>  Because it would be troubling to me.  I wouldn't want to encourage the situation where a party Committee decides they want to have some off the book operation.  So they just ask their friends to organize it and make sure there's no particular overlap between the individuals who have titles with the party Committee and individuals who have titles with the host Committee.  But they're all friends and they all know what everybody is doing, and they're all working in a cooperative fashion to accomplish the goals.  Whether it's for this kind of function or any kind of function that normally would be done by a party Committee.  I don't want to create a sort of, you know, roadmap for committees that don't want to report certain activities to just off load them to some friends or friendlies and not done in the books. 
	>>  I think that's fair.  I also have no -- I don't believe that's what occurred here.  And I also think if you look at the, again, the limited information that I have about this entity was what was turned over.  It looks like frankly insignificant sums.  
	>>  So, basically, where we find ourselves today, for reasons that you don't really know, your Committee ended up with some paperwork with some of the records of this Committee, which you say was separate from your Committee, and your Committee had no control over it.  You don't know why those records are there.  And you don't know how it was organized.  Basically, we really don't know
	>>  And, again, I apologize, because I'm just not an accountant, and I'm just a lawyer.  I look at this and I see a separate entity.  I see a separate entity and I see the purposes and see disbursements under it.  No, it's a Committee.  It's not a reporting entity.  So I wish I knew the answer to that question.  And I'm hopeful that the next time around, if I'm in front of you, I will have the benefit of much more institutional knowledge and will be more useful to you. 
	>>  And is it your understanding that the failure of the Colorado party Committee that you are representing today, the officials of the party received benefits from this Committee? 
	>>  No, I don't understand they did. 
	>>  Because it's been set the up to provide things to people who went to the convention. 
	>>  I think delegates to the convention is who was set up to.  Delegates both from Colorado and other states.  Look at the document, that looks like to me that it was set up for those people.  The other officials running the Committee. 
	>>  And there were no Colorado party officials who were delegates. 
	>>  One on the delegate side was the party Chairman. 
	>>  So the party Chairman received some benefit from this Committee. 
	>>  I guess, I wish I could just concede that.  I don't know if I can, because I wouldn't be surprised at all if Chairman Call, I mean, he would routinely, in my experience with the guy, you know, not -- there were goody bags for delegates, for example, going places.  He didn't take any of that.  Because he viewed it for the folks who were doing this for the first time and were getting the chance to go. and not something for him as a professional Chairman. 
	>>  But that's based on --
	>>  It's conjecture.  I can't tell you for sure. 
	>>  All right.  And is there call still associated with the Committee? 
	>>  No, he is not. 
	>>  Yes, Ms. Moss. 
	>>  Mr. Murray, one thing I can confirm for the commissioner is Mr. Call did, there was a reimbursement to him for $750 from that account.  But my question is, do you know why there were 8 bank account from this depository that were provided to us at the audit staff?  And they all began with Colorado state Republican central Committee.  And then whatever, like, allocations account or the Colorado state Republican central Committee operations account.  But this particular bank account that we're talking about is named the Colorado state Republican central Committee Republican national convention expense account.  So I guess, do you know why it would be named like that? 
	>>  I do not. 
	>>  If it was not associated with the Colorado Republican Committee's EIN? 
	>>  No, I do not. 
	>>  Okay
	>>  And, again, I really don't, I have no answer for that. 
	>>  Okay. 
	>>  Mr. Vice-Chairman. 
	>>  I see in the termination notice there's two contracts, and are we talking about both of them or the September one? 
	>>  So, --
	>>  One was a registration contract and one was a GOTV contract. 
	>>  Correct so, we're talking about the GOTV contract which was in September. 
	>>  So the registration contract services were provided and everything was satisfactory? 
	>>  Yes, and the debt and the payments, the debt and the disbursementsed were satisfied and reported. In 2011 to 2012, no, it was in prior cycle yes. 
	>>  And that was the end of the relationship? 
	>>  I don't believe we've used that vendor since.  I know we have not used that vendor in 2016. 
	>>  In the letter, it says please acknowledge receipt of that, roughly that language, at the chuck of COLG, chuck. 
	>>  Chuck was the director of the Colorado Republican Party.  That was his e-mail address. 
	>>  And has that person been communicate with? 
	>>  I know who he is, I have not spoken with him in some time
	>>  Ms. Hunter. 
	>>  Thank you.  So my understanding if Mr. Murray provides Ms. Moss with the information we talked about few minutes ago, I don't want to repeat I want in case I say it wrong.  Then this finding 1 is taken care of.  Because in your mind, it would establish that the other entity is independent from the state party. 
	>>  If there is a statement from the bank that says that this particular bank account is not associated with the Colorado Republican Committee's EIN. 
	>>  Okay.  Thank you.  And then to follow-up on some of the discussion that commissioner Wientrump was having, so the delegated selected in most states per rules the state party.  So even though they're elected to the state party rules, they're not official parties.  They're not part of the Executive Committee or they may be voting Republicans, and members of the parties, you know just like I am, but that doesn't mean that they're official members of the party.  
	 And, so, my understanding is that it's fairly common for separate entities to set up, and we've seen this here before, to help defray the expenses of delegates going to the convention as long as there's certain types of expenses and again, that's fairly common.  I don't believe that it's common even, sort of going back in time to say the state party typically paid these expenses.  I think what you were maybe getting at is, maybe there was a point in time where a state party may have been sort of reporting all this stuff, and now maybe they're not.  My understanding is typically, way back in time, didn't pay for certain expenses for the delegate convention. 
	>>  That wasn't my point. 
	>>  Okay.  I thought you were saying some things may have been reported in the past and are not now.  Okay, so say this is different and that if it was an independent Committee, you know, to defray cost of people, they may be delegates in part, but not official part of the state party. 
	>>  And just for the record, my understanding was that at least as long as I haven't had anything to do with the Colorado party which has been about the last 10 years, not in official capacity for the last 10 years, they never paid any expenses for its delegates.  As you might have imagine, it has to come out-of-pocket significantly. 
	>>  Commissioner. 
	>>  Thank you, I'm looking at the September 27 letter, the termination letter.  Terminate all services going forward.  Acknowledges that there have been some services for which money is owed.  And says at your earliest convenience, please prepare final invoices documenting specificity for all services performed and provided, and we'll make arrangement for all service and fees incurred.  Is it your understanding that was paid?  That those invoices were either submitted or paid? 
	>>  I'm certain there were certain invoices for registration work that was done earlier in the year.  And those invoices for paid.  For  get out the vote, I don't know if it was provided.  If one was presented, it was not paid. 
	>>  What I'm trying to figure out is whether this, at least at one point, it a disputed debt.  Whether that represented these services that this letter seems to acknowledge were provided and for which some payment is owed.  Is that the same pod of money or is this a differen pot of money? 
	>>  Again, there was another contract with this vendor.  So the pot of money I know was real debt and was paid and owed and it was for work earlier in the accept, I think on registration.  I don't know that there was ever, I don't know whether an invoice was presented for this work.  I don't know whether there was any real services provided.  I know there was activity after trying to provide the services.  But I don't know the disputed debt that we would be talking about, again, was all for alleged GOTV work which the party, again, doesn't believe it received any services. 
	>>  But you believe took place after September 27 letter? 
	>>  No, that took place before but were impeding.  And. So which might have taken place after as well.  That would have been immediately before or immediately after this letter. 
	>>  Are there any further questions?  Any questions from the auditors?  Anything from Office of General Counsel?  Okay. 
	 Mr. Murray, I don't know if there is any closing remarks you would like to make? 
	>>  No, I believe that we've plowed the furrow.  So commissioners, I very much appreciate your time.  And this is my first time representing the Committee that's availed of this on an audit process.  And, again, I wish we could be a shining example of having ton of institutional memory to make it helpful.  But we very much do appreciate the ability to address you at this stage in the process as opposed to later on, hopefully avoid a later step in the process. Thank you very much. 
	>>  We appreciate your presentation and thank you for answering all the questions from the commissioners
	>>  Say, "Hi" to Frank. 
	>>  I will.  Thank you Mr. Chairman. 
	>>  This audit hearing is adjourned.