As detailed in the attached Final Board Determination, the Campaign must repay the following:

Transcription

1 August 21, 2012 Manny C. Velazquez People for Manny Velazquez Dear Mr. Velazquez: Please find attached the New York City Campaign Finance Board s (the CFB or Board ) Final Audit Report for the 2009 campaign of Manny C. Velazquez (the Campaign ). The report is based on a comprehensive review of the Campaign s financial disclosure statements and submitted documentation, and incorporates the Board s final determination of August 9, 2012 (attached). The report concludes that the Campaign did not fully demonstrate compliance with the requirements of the Campaign Finance Act (the Act ) and Rules of the Board (the Rules ). As detailed in the attached Final Board Determination, the Campaign must repay the following: Public Funds Repayment (Qualified Expenditure Deficit) $411 Penalties Assessed $1,150 Total Owed $1,561 The full amount owed must be paid no later than September 20, Please send a check in the amount of $1,561, payable to the New York City Election Campaign Finance Fund, to: New York City Campaign Finance Board, 40 Rector Street, 7 th Floor, New York, NY If the CFB is not in receipt of the full amount owed by September 20, 2012 the Candidate s name and the amount owed will be posted on the CFB s website. The CFB also may initiate a civil action to compel payment. In addition, any principal committee of the Candidate will not be eligible to receive public funds for any future election until the full amount is paid. Further information regarding liability for this debt can be found in the attached Final Board Determination.

2 Manny C. Velazquez People for Manny Velazquez -2- August 21, 2012 The January 15, 2010 disclosure statement (#16) was the last disclosure statement the Campaign was required to file with the CFB for the 2009 elections. If the Campaign raises additional contributions to pay outstanding liabilities, please note that all 2009 election requirements, including contribution limits, remain in effect. The Campaign is required to maintain its records for six years after the election, and the CFB may require the Campaign to demonstrate ongoing compliance. See Rules 3-02(b)(3), 4-01(a), and In addition, please contact the Board of Elections for information concerning their separate filing requirements. The CFB thanks you for your cooperation during the 2009 election cycle. Should you have any questions about the enclosed report, please contact the Audit Unit at or Sincerely, Julius Peele Director of Auditing and Accounting c: Manny C. Velazquez People for Manny Velazquez Attachments

3 August 21, 2012 CAMPAIGN FINANCE BOARD FINAL AUDIT REPORT OF PEOPLE FOR MANNY VELAZQUEZ BACKGROUND Among the purposes of the Act are to diminish the role and influence of private money in New York City elections, to increase the information available to the public about elections and candidates' campaign finances, and to reduce the potential for actual or perceived corruption. The CFB is a nonpartisan, independent city agency that serves the public interest by enhancing the role of New York City residents in the electoral process. All candidates for the five covered offices - mayor, public advocate, comptroller, borough president, and City Council member - are required to disclose all campaign activity to the CFB. All candidates must adhere to strict contribution limits and the ban on contributions from corporations, and beginning January 1, 2008, partnerships and limited liability entities. Additionally, participating candidates are prohibited from accepting contributions from unregistered political committees. The CFB also administers the voluntary Campaign Finance Program (the Program ). Candidates who voluntarily participate in the Program can qualify to have private contributions matched with public money in exchange for agreeing to strict spending limits. 1

4 CAMPAIGN INFORMATION The table below provides detailed information about the Campaign: Name: Manny C. Velazquez ID: 1226 Office Sought: City Council District: 10 Classification: Participant Certification Date: June 10, 2009 Committee Name: People for Manny Velazquez Ballot Status: Primary Other Committees: No Party: Democratic Public Funds: Contribution Limit: Received: $55,200 $2,750 Returned: $0 Expenditure Limit: : $43, Primary: $161,000 People for Manny Velazquez 2 August 21, 2012

5 OBJECTIVES The overall objective of the CFB s audit was to determine whether the Campaign complied with the Act and Rules. Specifically, CFB staff evaluated whether (1) the Campaign accurately reported financial transactions and maintained adequate books and records; (2) the Campaign adhered to contribution limits and prohibitions; (3) the Campaign disbursed funds in accordance with the Act and Rules and complied with the expenditure limits; and (4) the correct amount of public funds was received, any additional funds are due, or any return of public funds is required in accordance with the Act and Rules. SCOPE AND METHODOLOGY Prior to the election, CFB staff performed an initial review of the Campaign s reporting and documentation of contributions for public funds eligibility and compliance with the Act and Rules. After the election, CFB staff performed an audit of financial disclosure statements five through sixteen (see Appendix #1), covering the period from April 16, 2008 through January 11, The audit was conducted in accordance with generally accepted government auditing standards (GAGAS) and included tests of records and other auditing procedures as necessary. This audit was performed in accordance with the audit responsibilities of the CFB as set forth in Administrative Code CFB staff examined the bank statements submitted by the Campaign from April 16, 2008 through January 25, 2010 and reconciled transactions to the Campaign s disclosure statements during this period to verify that all financial transactions were accurately reported and documented. People for Manny Velazquez 3 August 21, 2012

6 CFB staff conducted a comprehensive review of all financial transactions reported in the Campaign s disclosure statements to determine whether contribution limits and prohibitions were adhered to. Additionally, CFB staff reviewed the Campaign s reported expenditures to ensure that the Campaign disbursed funds in accordance with the Act and Rules and complied with the expenditure limits. CFB staff reviewed the Campaign s eligibility for public matching funds, all matchable contribution claims by the Campaign for compliance with the Act and Rules, and the Campaign s disbursements of public funds. The review was done to ensure that the correct amount of public funds was received by the Campaign, and to determine whether any additional public funds are due or whether any return of public funds by the Campaign is necessary. On September 15, 2010, CFB staff issued a Draft Audit Report to the Campaign that contained preliminary findings of non-compliance with the Act and Rules and recommended corrective actions. The Campaign subsequently responded to the Draft Audit Report. Based on CFB staff recommendations and the Campaign s responses, the Board issued this Final Audit Report. People for Manny Velazquez 4 August 21, 2012

7 CONCLUSION The Campaign did not fully demonstrate compliance with the requirements of the Campaign Finance Act and the Rules of the Board as detailed below: Disclosure Findings - Accurate public disclosure is an important part of the CFB s mission. Findings in this section relate to the Campaign s failure to completely and timely disclose the Campaign s financial activity. The Campaign did not report or inaccurately reported financial transactions to the Board (see Finding #1). The Campaign did not report all advances correctly (see Finding #2). Contribution Findings - All campaigns are required to abide by contribution limits and adhere to the ban on contributions from prohibited sources. Further, campaigns are required to properly document and disclose all contributions. Findings in this section relate to the Campaign s failure to comply with the requirements for contributions under the Act and Rules. The Campaign did not disclose and/or document in-kind contributions received (see Finding #3). The Board found the Campaign in violation and assessed a $250 penalty. The Campaign accepted a contribution from a prohibited source (see Finding #4). The Board found the Campaign in violation and assessed a $550 penalty. Expenditure Findings - Campaigns participating in the Program are required to comply with the spending limit. All campaigns are required to properly disclose and document expenditures and disburse funds in accordance with the Act and Rules. Findings in this section relate to the Campaign s failure to comply with the Act and Rules related to its spending. The Campaign did not address discrepancies in documentation provided to substantiate reported expenditures (see Finding #5). The Board found the Campaign in violation and assessed $350 in penalties. Public Matching Funds Findings - The CFB matches contributions from individual New York City residents at a $6-to-$1 rate, up to $1,050 per contributor. CFB staff performs reviews to ensure that the correct amount of public funds was received by the Campaign and that public funds were spent in accordance with the Act and Rules. Findings in this section relate to whether any additional public funds are due, or any return of public funds by the Campaign is necessary. People for Manny Velazquez 5 August 21, 2012

8 The Campaign did not document sufficient qualified expenditures equal to the amount of public funds it received (see Finding #6). People for Manny Velazquez 6 August 21, 2012

9 FINDINGS AND RECOMMENDATIONS 1. Financial Disclosure Reporting - Discrepancies Campaigns are required to report every contribution, loan, and other receipt received, and every disbursement made. See Administrative Code 3-703(6) and Rule In addition, campaigns are required to deposit all receipts into an account listed on the candidate s Certification. See Administrative Code 3-703(10) and Rule 2-06(a). Campaigns are also required to provide the CFB with bank records, including periodic bank statements and deposit slips. See Administrative Code 3-703(1)(d), (g), and Rules 4-01(a),(b)(1),(f). The Campaign provided CFB staff with its bank statements covering the period April 16, 2008 through January 25, 2010: Bank Washington Mutual/Chase Account Type Checking a) The Campaign did not report the following transactions that appeared on its bank statement: Check No./ Transaction Paid Date Amount Debit 09/08/09 $ Debit 09/09/09 $ /16/09 $ /17/09 $ Total $ People for Manny Velazquez 7 August 21, 2012

10 b) The Campaign reported the following transactions that do not appear on its bank statements: Statement/ Name Check No. Schedule/ Transaction ID Paid Date Amount ligenio, argentia /F/R /14/09 $ Garcia, Jose Ramon /F/R /15/09 $ Vasquez, Mary /F/R /15/09 $ Total $ Previously Provided Recommendation a) You must provide documentation for and amend your disclosure statements to report these unreported transactions. b) For transactions reported in the Campaign s disclosure statements but not appearing on the Campaign s bank statements, you must provide evidence to show that the transaction cleared the bank (i.e., a copy of the front and back of the check, or the missing bank statement), was reported in error, or amend your disclosure statement to void the check and forgive the expenditure payment. Any forgiven liabilities will be considered as in-kind contributions. Please note that any newly entered transactions will only appear as new transactions in an amendment to the last disclosure statement, even if the transaction dates are from earlier periods. Also note that the Campaign must file an amendment for each disclosure statement in which transactions are being modified. Once all data entry is completed, you should run the Modified Statements Report in C-SMART to identify the statements for which amendments must be submitted. If any new transactions have been added, you must amend Disclosure Statement 16. People for Manny Velazquez 8 August 21, 2012

11 Campaign s Response a) In response to the Draft Audit Report, the Campaign stated it had amended its disclosure statements to report these transactions. However, the Campaign failed to report the four transactions in its disclosure statements. b) In response to the Draft Audit Report, the Campaign stated that the checks were not cashed and it amended its disclosure statements to report these transactions as forgiven liabilities. The Campaign failed to amend its disclosure statement to report the three transactions as forgiven liabilities. Board Action a-b) The Board has taken no further action on these matters other than to make them part of the Candidate s record with the Board. 2. Advances For each advance, campaigns are required to report the name and address of the person making the purchase (the advancer), the amount, and the name of the vendor from whom the purchase was made. See Administrative Code 3-703(1)(g), 3-708(8) and Rule 3-03(c)(3). The Campaign did not properly report the names of vendors for the transactions listed in Exhibit I. Previously Provided Recommendation For each transaction listed in Exhibit I, you must amend your disclosure statements to report the name and address of each vendor from whom the purchase was made. People for Manny Velazquez 9 August 21, 2012

12 Campaign s Response The Campaign responded to the Draft Audit Report and stated the names of vendors have been properly reported on C-Smart. The Campaign deleted 7 advances totaling $ without an explanation. The Campaign also failed to amend its disclosure statement to report the underlying vendors for Transaction ID 11/P/R (see Exhibit I). Board Action The Board has taken no further action on this matter other than to make this a part of the Candidate s record with the Board. 3. Unreported/ Undocumented In-Kind Contributions In-kind contributions are goods or services provided to a campaign for free, paid by a third party or provided at a discount not available to others. The amount of the inkind contribution is the difference between the fair market value of the goods or services and the amount your Campaign paid. Liabilities for goods and services for the Campaign which are forgiven, in whole or part, are also in-kind contributions. In addition, liabilities for goods and services outstanding beyond 90 days are in-kind contributions unless the vendor has made commercially reasonable attempts to collect. An in-kind contribution is both a contribution and expenditure subject to both the contribution and expenditure limits. See Administrative Code 3-702(8) and Rules 1-02 and 1-04(g). Volunteer services are not in-kind contributions. See Administrative Code 3-702(8) and Rule Campaigns are required to report all in-kind contributions they receive. See Administrative Code 3-703(6) and Rule In addition, campaigns are required to People for Manny Velazquez 10 August 21, 2012

13 maintain and provide the CFB with documentation demonstrating the fair market value of each in-kind contribution. See Administrative Code 3-703(1)(d),(g) and Rules 1-04(g)(2) and 4-01(c). a) CFB staff s review of expenditure documentation submitted by the Campaign revealed instances where the Campaign paid a lesser amount than the original invoice amounts (see Exhibit II). Since the Campaign paid the lesser amounts shown on the invoices and did not report the unpaid balances as liabilities on subsequent statements as either still outstanding or as paid, the differences between the invoice amounts and the amounts paid are deemed unreported inkind contributions totaling $ b) CFB s staff review of the Campaign s reporting and the documentation submitted by the Campaign revealed that the Campaign made a payment of $ to Flex Communication Corp. by Committee check #1023 dated August 25, However, the Flex Communication Corp. receipt dated August 26, 2009 indicates that the total amount of $1, was received (see Exhibit III), suggesting that the remaining balance of $ may have been paid by someone other than the Campaign, despite the Campaign having reported an outstanding liability of $ to Flex Communication Corp. If the difference was paid by anyone other than the Committee it should have been reported as an in-kind contribution. c) CFB staff s review of expenditure documentation submitted by the Campaign revealed instances where the invoice and wage record amounts were altered to lesser amounts (see also Finding #5b). Since the Campaign paid the lesser amounts and did not report the unpaid balances as liabilities on subsequent statements or as paid, the differences between the invoice and wage record People for Manny Velazquez 11 August 21, 2012

14 amounts and altered amounts are deemed unreported in-kind contributions totaling $1, (see Exhibit IV). Previously Provided Recommendation a) You must explain why your Campaign did not pay for the total amount on the invoices. If the goods/services provided were given free of charge, you must report an in-kind contribution for the difference between the total invoice amounts and the actual payments. If your Campaign paid the full amount for each invoice, you must provide all copies of the canceled checks (both front and back) to show the payments. In addition, you must amend your disclosure statements to report all the transactions. If the difference was absorbed by the vendor you must amend your disclosure statements to report the in-kind contribution and explain your initial failure to report the in-kind contribution. If the amount is still outstanding, provide documentation of the vendors attempts to collect. b) You must explain the status of this outstanding liability: If the liability remains outstanding, you must provide documentation such as current invoices, collection notices, and/or a letter from creditor proving that the debt remains outstanding. If the liability has been paid by someone other than the Campaign, you must amend your disclosure statement to report the in-kind contribution and explain your initial failure to report the in-kind contribution. People for Manny Velazquez 12 August 21, 2012

15 c) The Campaign must respond to Finding and Recommendation #5b. If these services have not been paid for or were given free of charge, you must report an in-kind contribution for the difference between the total invoice amounts and actual payments. In addition, you must amend your disclosure statements to report the transactions. If you disagree with any of the above findings, you must provide an explanation and documentation to demonstrate that the finding is not a violation. Campaign s Response a) In response to the Draft Audit Report, the Campaign stated that the owner of Evolucion Press had left the country. The Campaign failed to provide documentation of any efforts to obtain the relevant documentation. The Campaign also submitted an updated invoice from Cesar Romero. However, both invoices contained the same number of commercial spots. The Campaign failed to provide an explanation or documentation that explained the price discrepancy. b) In response to the Draft Audit Report, the Campaign submitted a receipt from Flair Communications dated August 28, 2011, showing a $530 payment for four telephones. The Campaign also amended its disclosure statement and reported a $ outstanding liability to Flex Communication (Transaction ID 16/N/R ). The Campaign failed to explain and/or document if the vendor still intends to collect on this debt or that someone other than the Campaign paid for this expenditure. c) In response to the Draft Audit Report, the Campaign stated Noeli Baez (nb) made corrections on invoices she assisted in clerical paper work. People for Manny Velazquez 13 August 21, 2012

16 Board Action a) See Finding #4. b) The Board found the Campaign in violation and assessed a $250 penalty. c) The Board has taken no further action on this matter other than to make this a part of the Candidate s record with the Board. 4. Prohibited Contributions Corporate/Partnership/LLC Campaigns may not accept, either directly or by transfer, any contribution, loan, guarantee, or other security for a loan from any corporation. This prohibition also applies to contributions received after December 31, 2007 from any partnership, limited liability partnership (LLP), or limited liability company (LLC). See New York City Charter 1052(a)(13), Administrative Code 3-703(1)(l) and Rules 1-04(c),(e). An unpaid debt owed to a prohibited entity that is outstanding beyond 90 days is also considered a prohibited contribution unless the entity is still seeking payment. The Campaign may have accepted the following prohibited contributions (see Finding #3a): Name Invoice Amount Amount Paid Unreported In-Kind Amount See Exhibit Evolucion Press $ $ $ II Previously Provided Recommendation You must immediately refund each prohibited contribution by bank or certified check, and provide the CFB with a copy of the refund check, or pay the Public Fund the amount equal to the contribution. In addition, your Campaign must explain why it failed to comply with the prohibited contribution ban. Alternatively, you may provide documentation or evidence showing why each finding above is not a violation because People for Manny Velazquez 14 August 21, 2012

17 the contribution was not from a prohibited entity. Even if the prohibited contribution is refunded, accepting a prohibited contribution is a violation and may result in the assessment of a penalty. Campaign s Response In response to the Draft Audit Report, the Campaign stated that the owner of Evolucion Press had left the country. The Campaign failed to provide documentation of any efforts to obtain the relevant documentation. Board Action The Board found the Campaign in violation and assessed a $550 penalty. 5. Expenditure Documentation Campaigns are required to provide copies of checks, bills, or other documentation to verify all transactions reported in their disclosure statements. See Administrative Code 3-703(1)(d),(g) and Rule 4-01(a). The records should be sufficient to show an audit trail that demonstrates compliance with the Act and Rules. Rule 4-01(d) requires campaigns to retain copies of each bill for goods or services provided, mandates that such documentation must be contemporaneous and contain certain information regarding the goods or services provided. Rule 4-01 specifically addresses situations where contemporaneous records are either missing or incomplete. First, a campaign must attempt to obtain a duplicate or more complete record from the vendor. If that is not possible, a campaign may modify an existing record or create a new record which must clearly identify the record as modified or recreated. In addition, any modified or recreated record must be accompanied by a notarized statement explaining the reason for and People for Manny Velazquez 15 August 21, 2012

18 circumstances surrounding the record. The statement must be from a campaign representative who has firsthand knowledge of the recreated document and why the original document is not available or insufficient. Rule 1-02 defines an in-kind contribution as (1) a gift, subscription, loan, advance of, or payment for, anything of value (other than money) made to or for any candidate or authorized committee; and (2) the payment by any person other than an authorized committee of compensation for the personal services of another person which are rendered to the candidate or authorized committee without charge. Rule 1-04(g)(3) states that goods or services provided at less than fair market value are in-kind contributions, the value of which is the difference between the fair market value and the amount paid by the Campaign. a) The Campaign submitted wage records for Francisco Peralta which indicated that the worker was paid twice for the same hours of work on 9/15/09. Francisco Peralta was paid $ by Committee check #1123 for literature handout at P.S. 189 on 2558 Amsterdam for election day flyers from 5:30 A.M. to 9:00 P.M. He was also paid $ by Committee check #1028 for supervising volunteers at election polls and managing volunteers at literature handout locations from 5:30 A.M. to 9:00 P.M on 09/15/09. b) The Campaign submitted three invoices and two wage records that contained alterations. In each instance, the original amount was crossed out and a new, lesser amount was entered on the document with the initials n.b. written beside the altered amount. In each instance, the Campaign paid the lesser amount (see Exhibits IV). People for Manny Velazquez 16 August 21, 2012

19 Previously Provided Recommendation a) The Campaign must explain why it paid Francisco Peralta twice for the same hours of work. The Campaign must explain why the two wage records for Francisco Peralta indicate different rates of pay, i.e., $ per day and $ per day. b) For each altered invoice and wage record, the Campaign must address the following items and provide information as requested: Why were the invoices and wage records altered? What is the name of the individual who authorized the alterations and what was his or her role in the campaign? What is the name of the individual who made the alterations? What or who is n.b.? If n.b. is a person, what is this individual s relationship to the Campaign? Who supervised the workers? Confirm that all alterations were approved by the vendors and wage earners. Provide an explanation from each payee detailing the reason(s) why the amount was reduced and whether or not the Campaign owes the vendor or wage earner for the unpaid amount. Please note that any goods or services that were provided at below fair market value will be considered in-kind contributions, subject to the contribution limits and prohibitions and the expenditure limits (see also Finding #3). In addition, please be note that all of the expenditures referred to in this finding continue to be under review and are not considered qualified expenditures at this time. People for Manny Velazquez 17 August 21, 2012

20 Campaign s Response a) In response to the Draft Audit Report, the Campaign stated this clerical mistake was an oversight by the Campaign. b) In response to the Notice of Alleged Violations, the Campaign stated that invoice alterations were made because the Campaign received less services than the original contract amount. In regards to the employee wage records the Campaign stated that the two employees (Transaction ID 12/F/R & 12/F/R ) did not work the time originally agreed upon so the Campaign reduced their payment according to the hours worked. The Campaign failed to provide documentation from the vendors and wage workers. Board Action a) The Board found the Campaign in violation and assessed a $100 penalty. b) The Board found the Campaign in violation and assessed $250 in penalties. 6. Public Funds - Qualified Expenditure Documentation Public funds may only be used for qualified expenditures by a candidate s principal committee to further the candidate s nomination or election during the calendar year in which the election is held. Expenditures that are not considered qualified include undocumented or unreported expenditures, payments to the candidate or the candidate s relatives, payments in cash, contributions to other candidates, gifts, petition expenditures, and advances except individual purchases of more than $250. See Administrative Code and Rule 1-08(g). Participants must return public funds, or may be limited in the People for Manny Velazquez 18 August 21, 2012

21 amount of public funds they are eligible to receive post-election, if they have not documented sufficient qualified expenditures. See Administrative Code 3-710(2)(b) and Rule 5-03(d). Campaigns are required to obtain and maintain contemporaneous records that enable CFB to verify that expenditures were qualified. See Administrative Code 3-703(1)(d) and Rule These records may include cancelled checks (front and back) and bills for goods or services. Bills must include the date the vendor was hired or the date the goods or services were received, the vendor s name and address, a detailed description of the goods or services, and the amount. CFB Rules provide guidance for situations where contemporaneous records are either missing or incomplete. See Rule 4-01(a). First, a campaign must attempt to obtain a duplicate or more complete record from the vendor. If that is not possible, a campaign may modify an existing record or create a new record which must clearly identify the record as modified or recreated. In addition, any modified or recreated record must be accompanied by a notarized statement explaining the reason for and circumstances surrounding the record. The statement must be from a campaign representative who has firsthand knowledge of the recreated document and why the original document is not available or insufficient. Upon review of the non-contemporaneous record and statement, the CFB may still find the records are not sufficient to adequately document the transaction. The Campaign received $55, in public funds for the 2009 elections. Previously, CFB staff requested documentation to demonstrate that public funds were used for qualified expenditures. Based on all the records submitted, the Campaign has provided sufficient documentation for $54, in qualified expenditures. People for Manny Velazquez 19 August 21, 2012

22 If the Campaign does not document an additional $ as qualified, the Campaign must repay this amount to the Public Fund. Previously Provided Recommendation You must provide explanations and/or documentation where requested (copies of bills, detailed invoices, consulting agreements, work contracts, credit card statements, and/or fronts and backs of cancelled checks, etc., or recreated/modified records along with the required statements as instructed above). In some cases, you may find it useful to provide evidence of work performed to supplement an invoice or other documentation already provided along with a more detailed description of tasks performed or products received. In addition, you may need to amend your disclosure statements to correct errors in the reporting of expenditures. Campaign s Response The Campaign responded to this finding and submitted additional documentation. However, the documentation was not adequate. Board Action The Board determined that the Campaign must repay $411 1 to the Public Fund. 1 The Board collects public funds in whole dollar amounts. People for Manny Velazquez 20 August 21, 2012

23

24 Exhibit I People for Manny Velazquez 2009 Elections Advances (see Finding #2a) Advancer Name Vendor Name Statement/ Schedule/ Transaction ID Purchase Date Purpose Code Amount Note Baez, Noeli Baez, Noeli 11/P/R /29/09 OTHER $25.29 [1] Baez, Noeli Baez, Noeli 11/P/R /29/09 OTHER $69.15 [1] Baez, Noeli Baez, Noeli 11/P/R /29/09 OTHER $81.00 [1] garcia, cristlan garcia, cristlan 11/P/R /19/09 OTHER $10.00 [1] garcia, cristlan garcia, cristlan 11/P/R /19/09 OTHER $60.00 [1] Velazquez, Manny Velazquez, Manny 10/P/R /21/09 OFFCE $64.99 [1] Velazquez, Manny Velazquez, Manny 11/P/R /21/09 PROFL $ [1] hamburgo, Jorge hamburgo, Jorge 11/P/R /02/09 LITER $1, Total $1, Note: [1] The Campaign deleted these transactions from its disclosure statements.

25 Exhibit II People for Manny Velazquez 2009 Elections Unreported In-Kind Contributions (see Finding #3a) Name Statement/ Schedule/ Transaction ID Paid Date Amount Per Invoice Amount Paid In-Kind Amount Evolucion Press 11/F/R /20/09 $ $ Evolucion Press 12/F/R /14/09 $ $ $ $ Romero, Cesar 10/F/R /10/09 $3, $1, Romero, Cesar 12/F/R /03/09 $ Romero, Cesar 12/F/R /11/09 $1, $3, $3, $ Total $500.00

26 Exhibit III People for Manny Velazquez 2009 Elections Unreported In-Kind Flex Communication (see Finding #3b)

27

28 Exhibit IV People for Manny Velazquez 2009 Elections Expenditure Documentation (see Finding #3c and #5b) Statement/ Schedule/ Transaction ID Timesheet/ Invoice Amount Paid Amount Name Date Paid Variance t.v. revista 12/F/R /11/09 $1, $1, $ technoprint 12/F/R /14/09 $1, $ $ paredes, ricardo 12/F/R /14/09 $ $ $ Morel, Reynaldo 12/F/R /15/09 illegible $60.00 n/a Plasencia, Juan 12/F/R /15/09 $ $60.00 $40.00 Total $1,440.00