‘THE COMMONWEALTH OF MASSACHUSETTS
OFFICE OF CAMPAIGN & POLITICAL FINANCE
wong s, ULLAN eu: orn) 7273982
January 3,2011
CPP ID# 13946
Michael Rush
Michael Rush Committee
65 Cass Street
‘West Roxbury, MA 02132-4413
Re: CPF-10-25
Dear Representative Rush
‘This office has completed its review of financial activity undertaken bythe Rush Committe:
(Committee) in 2009. The Committe fully cooperated with OCPF and provided all requested
documentation to facilitate the review.
‘Based on the findings of the review, which included an analysis of bank statements, supporing
documentation, and a reconciliation ofthe committee's campaign finance report to these records, te
‘Committe has now filed n amended report forthe time peti, These amendments, as accurately as
possible, disclose the Corrmittee’s activity forthe aforementioned period.
‘Specifically, the review was initiated by OCPF"s recognition of non-disclosure by the
committee of a significan number of PAC contributions. This non-disclosure, acarding tothe
Committee, occured because the Committee had more than one individual responsible forthe
Jhandling of information regarding the receipt of contributions. One individual was responsible for
copying and depositing ccatributor checks, while another was responsible forthe actual dats entry of
the information for campaign finance diselosure purposes. This lack of coordination caused the
‘Committee to understate it receipts in 2009. A similar lack of coordination occurred on the
expenditure side ofthe ledger, resulting in an understating of expenditures.
‘We have concluded thatthe Committee's activity did not comply with Section 18 of the
‘campaign finance law. Seotion 18 requires acurate and timely disclosure of ll contibutions,
‘expenditures, and liabilities. While OCPF has determined that the ers made onthe Committee's
reports were unintentional and did not involve the misuse or personal use of any campaign funds, the
‘Comite, as well as OCPF, has indicated its concern tat all subsequent reports provide accurate and
complete disclosure
‘To ensure such disclosure, the Committee has contracted with a professional fm to handleall
aspects of compliance with the campaign finance law. The Committe has also upgraded its software
to the Reporter 5 version tat OCPF supports and has replaced its treasurer. The Committe is also
‘wotking with is bank to ensue thet account ststements are issued on an end ofthe month bass, rater
‘han inthe middle ofthe month as previously issued.
oS wwwmass.gor/oopt mat eepfBeptstotameusRepresestative Michael Rush
Jamuary3, 2011
Page 2
Indio tothe steps taken above, the Comite will provide OCPF wih copies ots bask
statements expenditure checks, pes sets, and al conor ces recived and deposited with
ach ror. The Commitee wil ag provide tay Farther ocumenaicn requested by OCPE within 10
truss days.
‘To resolve ths matter, which includes noting thatthe Committe retained a third party tits
‘own expense to assist in reviewing this issue the Committe has made a $2,500 payment tothe
‘Commonwealth for cots incured during OCPF's review. The Committee has also agreed toa $3,000
suspended forfeiture ~ ifthe Committee's reports are substantially actrate for ealendar years 2010 ~
2012, the Committee will not have to forfeit this amount tothe Commenwealth.
Inaccordance with an opinion from the Supervisor of Public Records, this eter is public
record. Ifyou have any questions regarding this matter or on any issues of future compliance with the
campaign finance law, please contact this office.
Sincerely,
hael|
Michael ativan
Director
Ce: Genrma Marin, Chick Montana Group