STATE OF NEW MEXICO OFFICE OF THE STATE AUDITOR

RISK ASSESSMENT REPORT NEW MEXICO PUBLIC REGULATION COMMISSION

Hector H. Balderas State Auditor October 12, 2011

TABLE OF CONTENTS I. II. EXECUTIVE SUMMARY………………………………………………………....3 BACKGROUND…………………………………………………………………….5 A. Context and Procedural History………………………………………………. .5 III. RISK ANALYSIS OF WRIGHT EXPRESS GAS CARD PURCHASES……….8 A. Summary of Exhibits…………….……………………………………………..8 B. OSA Procedures and Results…………………………………………………...8 C. Agency-wide Analysis Required……………………………………………….12 IV. RISK ASSESSMENT OF PER DIEM AND MILEAGE………………………...13 A. OSA Procedures and Results…………………………………………………..13 B. Agency-wide Analysis Required……………………………………………….15 V. VI. REFERRAL OF THE RISK ASSESSMENT REPORT………………………...16 EXHIBITS…………………………………………………………………………..17 A. 2011 Monthly Calendar of Commissioner Block’s Gas Card Usage……….18 B. Vehicle Gas Cards Used………………………………………………………..24 C. Questionable Gas Card Transactions…………………………………………25

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I.

EXECUTIVE SUMMARY

On September 20, 2011, the Special Counsel for the House Rules Impeachment Investigation Subcommittee (Subcommittee), Robert J. Gorence, requested the assistance of the Office of the State Auditor (OSA) in providing the Subcommittee copies of documents the OSA received from the Public Regulation Commission (PRC) related to the potential misappropriation of state resources by the now former Commissioner Jerome J. Block. On September 21, 2011, the OSA provided certain documents in response to Mr. Gorence’s request, and notified him that the OSA planned to provide the Subcommittee with an official analysis of documents and information related to the allegations against Commissioner Block. The OSA also informed Mr. Gorence that the State Auditor hoped an analysis conducted by OSA auditors would assist the Subcommittee with its mission. Accordingly, this Risk Assessment Report was originally prepared as a courtesy to the Subcommittee. The assessments contained in this report are not part of a formal audit engagement of the PRC. Therefore, the OSA is not required to release this report pursuant to Section 12-6-5 NMSA 1978. The report focuses solely on the transactions involving Commissioner Block and not the PRC as whole which will be addressed in a special examination conducted by independent public accountants (IPA) under the OSA’s direction. However, given the risks identified by the report related to gas and travel charges, and the concern that others may have assisted or illegally profited from Commissioner Block’s actions, the OSA will refer this report to the Attorney General (AGO), the Tax Fraud Investigations Division of the Taxation and Revenue Department (TRD Tax and Fraud), the PRC, the Legislative Finance Committee (LFC) and the Department of Finance and Administration (DFA). As part of the risk assessment, the OSA requested and reviewed the Wright Express (WEX) Gas Card Usage Reports for Commissioner Block from the beginning of his term in office, January 1, 2009, through July 31, 2011. The time period under review was based on the beginning of Commissioner Block’s term through August 2, 2011, the date the PRC notified the OSA of potential fraudulent use of state-issued gas cards by Commissioner Block. Upon initial review of WEX gas card reports, the OSA noted a high percentage of questionable and frequent gas charges; however, the lack of records (vehicle logs, etc.) made it more difficult to pinpoint inappropriate use. Therefore, the OSA analyzed the reasonableness of the charges. Based on OSA’s review of the WEX Gas Card Usage Report for Commissioner Block, the OSA identified 193 of the total 288 gas card charges as questionable gas charges. The 193 questionable gas card charges, for a total 2,463 gallons at a net cost of $8,189, are fully detailed in EXHIBIT C in this Risk Assessment Report. During our review we also noted Commissioner Block’s pin number was used in making gas card charges on 18 different WEX gas cards. Of those 18 cards, 17 were assigned to vehicles designated for use by specific PRC divisions or employees. The true extent of this risk needs to be further tested agency-wide. The OSA also requested and reviewed the official records of the PRC meeting minutes in order to compare Commissioner Block’s physical attendance to gas card charges made with his pin number. Based on OSA’s review, there appear to be a number of instances in which the gas card pin number assigned to Commissioner Block
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was used while he was documented as being physically present at a PRC meeting. There was no support or justification contained within the documentation provided by the PRC to explain the irregularities. Also, as part of its risk assessment, the OSA requested and reviewed the PRC’s general ledger detail of all per diem and mileage reimbursement disbursements requests for Commissioner Block from January 1, 2009 through July 31, 2011. Based on the general ledger detail, Commissioner Block’s travel amounted to $11,737.27 during less than a two and a half year time period (February 2009 to June 2011). The analysis of travel and per diem reveals a number of instances in which the PRC reimbursed Commissioner Block even though he failed to provide itemized receipts. In two instances, Commissioner Block circumvented procurement procedures related to air travel. We also noted occurrences in which Commissioner Block’s pin number was used for a gas card purchase at a location different than that of the location of travel and during the same date and time. Additionally, there remains an outstanding travel advance of $1,003.96 awaiting receipts from Commissioner Block to support the travel paid in advance. The PRC indicated that Commissioner Block had not provided receipts or reimbursed the PRC at the time of his resignation. On September 28, 2011, Commissioner Block pleaded guilty to numerous felonies, including fraudulent use of a state credit card, and agreed to resign from the PRC. Commissioner Block formally submitted his resignation on October 7, 2011. However, based on the results of OSA’s Risk Assessment Report, the responses received from the PRC to the OSA’s inquiries, reports from other sources and certain reports made to the OSA on its Fraud Hotline, the OSA has determined that risks exist in the PRC that require further analysis and test work. Those risks also include the PRC’s lack of policies related to use of state vehicles for commuting purposes and the failure to keep records regarding the business and personal use of vehicles by PRC commissioners, which is required for federal tax fringe benefit purposes. Due to these concerning risks, the State Auditor determined that a special audit should be conducted pursuant to Section 12-6-3(C) NMSA 1978. OSA auditors designed the objectives of the special audit engagement to test certain risk areas related to travel, per diem, vehicle and gas charges due to serious concerns over the misappropriation and inadequate protection of public resources. The full results and risks identified by this Risk Assessment Report are explained below.

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II. A.

BACKGROUND Context and Procedural History

On August 2, 2011, the Acting Administrative Services Division (ASD) Director/Chief Financial Officer (CFO) of the PRC notified the OSA of instances of potential fraudulent use of state-issued gas cards by the now former PRC Commissioner Jerome J. Block. The Acting ASD Director/CFO provided the notification pursuant to Section 12-6-6 NMSA 1978, which requires that government agencies immediately report to the State Auditor “any violation of a criminal statute in connection with financial affairs.” The OSA requested additional information and documents from the PRC on August 8, 2011 and August 10, 2011. The PRC provided a timely response to the OSA’s requests on August 18, 2011. Based on OSA’s auditors’ review and analysis of information and documentation received from the PRC, information reported to the OSA by other sources, information reported on the OSA’s Fraud Hotline, and a risk review performed by OSA auditors, the State Auditor determined that a special audit should be conducted pursuant to Section 12-6-3(C) NMSA 1978. That section provides that the State Auditor “may cause the financial affairs and transactions of an agency to be audited in whole or in part.” OSA audit staff also met with the PRC’s IPA for its fiscal year 2011 financial audit in order to discuss and coordinate the planned test work. OSA auditors designed the objectives of the special audit engagement to test certain risk areas related to travel, per diem, vehicle and gas charges due to serious concerns over the misappropriation and inadequate protection of public resources. The OSA and the PRC scheduled an entrance conference for September 13, 2011 at the PRC in order to discuss the special audit’s scope and fees. During this scheduled entrance conference at the PRC, PRC Chairman Patrick Lyons engaged in verbally abusive and physically threatening behavior which exhibited an explicit intent to intimidate OSA staff, obstruct the OSA’s audit work and limit the scope of the special audit. As the stated basis for his hostile attacks, Chairman Lyons repeatedly cited the findings of the OSA’s Special Audit of the State Land Office (SLO), which the OSA released on December 20, 2010. Chairman Lyons explicitly stated that the PRC was not going to pay for the special audit and that OSA auditors would not be allowed access to the PRC. He openly attacked the professional qualifications and competency of the OSA’s audit staff and made derogatory and insulting comments to OSA staff present at the entrance conference. Chairman Lyons brought a bankers box filled with SLO documents to the entrance conference and, in one instance, engaged in physically threatening behavior by picking up the box, leaning over the conference table and slamming the box down on the table directly in front of the OSA’s Chief of Staff in an intimidating manner. He also stated that he directed PRC staff to withhold information from the OSA about the potential misappropriation of state resources by Commissioner Block. Chairman Lyons’ personal bias as a result of the SLO Special Audit, his abusive behavior towards OSA staff, and his explicit statements evidencing his intent to limit the OSA’s access to records, caused the State Auditor great concern that OSA auditors would be able to independently and safely carry out their duties. Government Auditing Standards (GAGAS or Yellow Book) and AICPA professional standards set forth that an auditor’s independence may
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be impaired and the auditor may not have complete freedom to make an independent and objective judgment, thereby adversely affecting the audit, if certain conditions exist. In accordance with GAGAS and AICPA standards, the State Auditor determined that Chairman Lyons’ behavior constituted external interference which would restrict OSA auditors’ work or interfere with OSA auditors’ ability to form independent and objective opinions, findings and conclusions. Therefore, on September 14, 2011, the State Auditor designated the PRC for an examination of PRC transactions and controls related to travel, per diem, vehicle and gas charges that have occurred from January 1, 2009 through August 30, 2011. The State Auditor mandated that an IPA selected by the PRC and approved by the State Auditor to conduct the examination. In his September 14, 2011 letter designating the PRC for the examination, the State Auditor set forth the specific objectives of the examination to be performed by the IPA under the OSA’s direction. Those objectives are as follows:  To determine if PRC complied with provisions of the New Mexico Administrative Code, Sections 1.5.3 through 1.5.4 NMAC, and other applicable state purchasing regulations during the processing of per diem and mileage payments; To determine if PRC has proper internal controls established and in place over travel transactions and whether those controls are being followed; To determine if PRC properly followed and monitored compliance with gas card regulations; To determine if PRC has adequate, complete documentation on file to substantiate and support all per diem and mileage payments and gas charges; and To determine if PRC is complying with the commuting policy and relative state and federal requirements related to commuting and fringe benefit allocation and notification.

   

On September 6, 2011, Ben Lujan, Speaker of the New Mexico House of Representatives, appointed certain House members to a House Rules Impeachment Investigation Subcommittee that was tasked with the investigating the possibility of impeaching Commissioner Block. On September 20, 2011, the Special Counsel for the House Rules Impeachment Investigation Subcommittee, Robert J. Gorence, requested the assistance of the OSA in providing the Subcommittee copies of documents the OSA received from the PRC related to the potential misappropriation of state resources by Commissioner Block. On September 21, 2011, the OSA provided certain documents in response to Mr. Gorence’s request, and notified him that the OSA planned to provide the Subcommittee with an official analysis of documents and information related to the allegations against Commissioner Block. The OSA also informed Mr. Gorence that the State Auditor hoped an analysis conducted by OSA auditors would assist the Subcommittee with its mission. Accordingly, this Risk Assessment Report was originally prepared as a courtesy to the Subcommittee. The assessments contained in this report are not part of a formal audit engagement of the PRC. Therefore, the OSA is not required to release this report pursuant to Section 12-6-5 NMSA 1978. The report focuses solely on the

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transactions involving Commissioner Block and not the PRC as whole which will be addressed in a special examination conducted by an IPA under the OSA’s direction. On September 28, 2011, Commissioner Block pleaded guilty to numerous felonies, including fraudulent use of a state credit card, and agreed to resign from the PRC. Commissioner Block formally submitted his resignation on October 7, 2011. On September 29, 2011, the OSA received the PRC’s contract for Atkinson & Co., Ltd. to conduct the examination of PRC transactions and controls related to travel, per diem, vehicle and gas charges that have occurred from January 1, 2009 through August 30, 2011. The OSA approved the contract on October 4, 2011, but as of the date of this report the contract is still pending approval by the DFA. This Risk Assessment Report was originally prepared for the Subcommittee. However, given the risks identified by the report related to gas and travel charges, and the concern that others may have assisted or illegally profited from Commissioner Block’s actions, the OSA will refer this report to the AGO, the TRD Tax and Fraud, the PRC, the LFC and the DFA.

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III. A.

RISK ASSESSMENT OF WRIGHT EXPRESS GAS CARD PURCHASES Summary of Exhibits

This Risk Assessment Report contains exhibits that illustrate the gas card purchases made with Commissioner Block’s pin number, as explained in the section below which details the results of the OSA’s procedures. Those exhibits are as follows: 1) EXHIBIT A illustrates daily gas usage for the months of January through June in 2011, based on detail provided in the WEX Gas Usage Report submitted to the OSA by the PRC. Based on the WEX Gas Card Usage Report, charges cease after June 16, 2011; therefore, detail in the calendar exhibit is only presented up to June 16, 2011. Additionally, the PRC indicated Commissioner Block’s pin number was cancelled on June 16, 2011. 2) EXHIBIT B lists the 18 different WEX gas cards used with Commissioner Block’s pin number. The exhibit also indicates whether the vehicle was assigned to a department or a PRC employee and the total number of instances a gas card charge was made with Commissioner Block’s pin number. This exhibit illustrates that 102 of the total 288 gas card purchases were made with 17 vehicle gas cards other than the one assigned to Commissioner Block. 3) EXHIBIT C details the list of questionable gas card transactions based on the criteria detailed in part 1(a) below. Details are contained in this exhibit that shows each questionable gas card charge that makes up the total $8,189. B. OSA Procedures and Results

The OSA requested and reviewed the Wright Express (WEX) Gas Card Usage Reports for Commissioner Block from January 1, 2009, the beginning of his term in office, through July 31, 2011. WEX, through a contract with the State of New Mexico, provides gas cards for the State of New Mexico’s government vehicle fleet. The PRC provided the reports, which detailed 288 gas card purchases, in hard copy and electronic format. The OSA also requested vehicle records for all vehicles Commissioner Block used from January 1, 2009 through July 31, 2011. The request for records included, but was not limited to, vehicle logs, receipts for gas and receipts for all other purchases. In response to this request, the PRC stated the following: “The PRC does not retain vehicle records, logs, or gas receipts for any commissioners.” Each government vehicle is assigned an individual WEX gas card. A pin number is assigned to each individual driver authorized to use WEX gas cards, and the driver enters his or her pin number when using a WEX card to make purchases. The pin used in each gas purchase transaction is identified in the WEX gas card report. Generally, the pin number is the last six digits of that individual’s social security number. Commissioner Block’s pin number was the last six digits of his social security number. Per our inquiry with the PRC, Commissioner Block never reported that his pin number had been compromised. WEX gas card reports are submitted to state agencies on a monthly basis. At that time, each agency should have a process in place that requires a review of the gas card charges made.
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For the time period covered for the OSA’s scope of review, January 1, 2009 through July 31, 2011, Commissioner Block’s pin number was entered to purchase gas using 18 different state vehicle WEX gas cards for a total of 288 purchases. Of the 18 WEX gas cards used, one card was designated for Commissioner Block’s assigned vehicle, a 2004 Dodge Durango (plate number G59117). That card was used for 186 of the total 288 purchases. The remaining 102 gas card charges, which were made using Commissioner Block’s pin number, were made with 17 other WEX gas cards that were assigned to 17 other PRC vehicles. See EXHIBIT B for the complete list of gas cards used, including whether the vehicle was assigned to a certain PRC division or employee, and the number of times the gas cards were used for each PRC vehicle from January 1, 2009 through July 31, 2011. Based on our limited review of the WEX reports, a high percentage of questionable and frequent gas charges exist; however, the lack of records (vehicle logs, etc.) makes it more difficult to analyze reasonableness of the gas charges. It is important to note that Section 1.5.4.9 NMAC provides that vehicle operators shall be used for only official business and only for items listed in Section 1.5.4.12 NMAC. Section 1.5.4.12 NMAC provides that the State of New Mexico credit cards shall be used only for official business and only to furnish state-owned vehicles with regular gasoline, unleaded gasoline, diesel fuel, lubrication, motor oil, car wash; and emergency purchases not exceeding $100.00 in total. In total, as included in EXHIBIT C, 2,463 gallons for a total of $8,189 are identified as questionable transactions based on the criteria specified below. In violation of both state and federal requirements, the PRC does not keep nor require any of its Commissioners to keep documentation which would support the Commissioners’ vehicle use and travel. Due to the lack of records, it is difficult to establish whether or not certain gas card transactions were made strictly for approved PRC business. Given this limitation, the OSA was only able to identify questionable gas card transactions based on a review of the data contained within the detail of the 288 gas card purchases listed in the WEX Gas Card Usage Report. We also compared the gas card purchases with Commissioner Block’s travel times, dates, locations and physical attendance at each of the 252 PRC meetings. Control deficiencies, questionable gas charges and inconsistences which we noted during our review are as follows: 1) Based on the OSA’s review of the WEX Gas Card Usage Report for Commissioner Block, we have identified 193 of the total 288 gas card charges as questionable gas charges. The 193 questionable gas card charges for a total 2,463 gallons at a net cost of $8,189 are fully detailed in EXHIBIT C. a. OSA used the following criteria for determining whether or not a gas card transaction was questionable when analyzing the data provided in the WEX Gas Card Usage Report for Commissioner Block: i. Allowed purchase per Section 1.5.4.12 NMAC – Commissioner Block’s gas usage would be not be allowed if it were for diesel gasoline, unleaded plus gas or super unleaded gas. None of the 18 vehicles to which gas cards was assigned required diesel

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gas. Additionally, unleaded plus and super unleaded gas are specifically unallowed purchases under Section 1.5.4.12 NMAC. ii. Multiple gas card purchases in the same day with different gas cards in different locations. Also, multiple gas card purchases in the same day with different gas cards in different locations. iii. Multiple gas card purchases in the same day that exceed the gas tank capacity for the vehicle to which the card was assigned. iv. Gas card purchases while Commissioner Block was documented as physically present in a different location other than the location where the purchase was made. v. A pattern of gas card purchases which occurred in the same general vicinity to each other and that exceed tank capacity. 2) An example of questionable transactions is as follows: a. On May 16th, 2011, Commissioner Block’s pin was used 5 times with two different cards assigned to two different PRC vehicles. One card, number 0144, was used to purchase gas in Santa Fe at 11:20 A.M. and 11:25 A.M. that day for 15.57 and 9.74 gallons of unleaded gas, respectively. The vehicle to which the card is assigned is identified by the PRC as a 2006 Ford 500. Fueleconomy.gov indicates this vehicle has a tank capacity of 20 gallons. Minutes after the Ford 500 was filled up in Santa Fe, Block’s assigned vehicle card was used at an Espanola gas station at 11:46 A.M. for 8.061 gallons of unleaded gas. Just a few hours later, two more gas purchases were made with Block’s assigned vehicle card in Española at 2:37 P.M. and 3:54 P.M. for 15.993 gallons of unleaded gas and 45.86 gallons of super unleaded gas, respectively. The total cost of fuel this day was $351.82. The OSA noted multiple occurrences similar to this example. See EXHIBIT C for all 193 questionable transactions. 3) The OSA’s assessment also revealed that between January 1, 2009 and July 31, 2011, super unleaded or unleaded plus gas was purchased in 37 instances, for a total of $1,673.23. Commissioner Block’s pin number was also used to purchase $148.80 in diesel gasoline, which was a fuel type that was not required by any vehicles driven by Commissioner Block. According to the New Mexico Administrative Code, Sections 1.5.3.19(E) NMAC, if an authorized driver (Commissioner Block) uses the fuel credit card to purchase an unauthorized item (unleaded plus and super unleaded fuel) or service, the state agency (PRC) shall collect the cost of the unauthorized purchase from the authorized driver. It appears as though Commissioner Block has paid the PRC in March of 2011 for two diesel purchases made in February of 2011. 4) OSA requested and reviewed the official records of the PRC meeting minutes during the time period from January 6, 2009 through July 14, 2011 for the purpose of comparing Commissioner Block’s physical attendance to gas card charges made with his pin number. The OSA reviewed each of the 252 meeting minutes provided by the PRC in order to
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determine whether or not Commissioner Block was physically present at each meeting. We compared the attendance data with gas charges to determine if any of the gas charges took place while Commissioner Block was noted as being physically present at a PRC meeting. Based on the OSA’s procedures and the results of those procedures, there appear to be a number of instances in which the pin number assigned to Commissioner Block was used while he was documented as being physically present at a PRC meeting. No support or justification contained within the documentation provided by the PRC explains the irregularities. We noted the following gas charges that took place while Commissioner Block was listed as being physically present at a PRC Meeting: a. Per the meeting minutes, a PRC meeting was held at the PERA building in Santa Fe, New Mexico on January 21, 2009 at 9:36 A.M. and adjourned at 1:25 P.M. The meeting minutes also indicate Commissioner Block seconded the motion to adjourn the meeting. The detail of gas charges using Commissioner Block’s pin includes a purchase with the gas card for vehicle G62117 at 11:07 A.M. in Santa Fe for 18.35 gallons of unleaded gas. b. Per the meeting minutes, a PRC meeting was held at the PERA building in Santa Fe, New Mexico on July 30, 2009 at 9:35 A.M. and adjourned at 11:30 A.M. The meeting minutes also indicate Commissioner Block moved to adjourn the meeting. The detail of gas charges using Commissioner Block’s pin includes a purchase with the gas card for vehicle G62117 at 10:57 A.M. in Santa Fe for 19.45 gallons of unleaded gas. c. Per the meeting minutes, a PRC meeting was held at the PERA building in Santa Fe, New Mexico on August 19, 2010 at 9:35 A.M. and adjourned at 12:00 P.M. The meeting minutes do not include any indication that Commissioner Block was not present for the duration of the meeting. The detail of gas charges using Commissioner Block’s pin includes a purchase with the gas card for vehicle G62117 at 11:23 A.M. in Española for 18.804 gallons of unleaded gas. d. Per the meeting minutes, a PRC meeting was held at the PERA building in Santa Fe, New Mexico on March 10, 2011 at 9:30 A.M. and adjourned at 12:15 P.M. The meeting minutes do not include any indication that Commissioner Block was not present for the duration of the meeting. The detail of gas charges using Commissioner Block’s pin includes a purchase with the gas card for vehicle G62117 at 11:23 A.M. in Española for 18.804 gallons of unleaded gas. e. Per the meeting minutes, a PRC meeting was held at the Clayton Civic Center in Clayton, New Mexico on June 9, 2011 at 10:30 A.M. and adjourned at 12:30 P.M. The meeting minutes also indicate Commissioner Block moved to adjourn the meeting. The detail of gas charges using Commissioner Block’s pin includes four different purchases with the gas card for vehicle G59117. The purchases took place from 10:28 A.M. and 8:34 P.M. at the same gas station in Española for 41.316 gallons of unleaded gas and 15.569 of unleaded plus gas for a grand total of $193.91. As noted below in the risk assessment of Commissioner Block’s per diem and travel, the four gas card purchases were not for the same vehicle listed as the vehicle driven by Commissioner Block on the “Itemized Schedule of Travel Expenses” for travel to Clayton on June 8, 2011 and June 9, 2011.
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5) See EXHIBIT A for an illustration of daily gas usage for the months of January through June in 2011. 6) See EXHIBIT B for a listing of the vehicle gas cards used and number of instances. The PRC has not provided records to support the transactions made, such as gas receipts or vehicle logs and has responded that “The PRC does not retain vehicle records, logs, or gas receipts for any commissioners.” There is a possibility that there are records kept on the 17 other vehicles used that were not Commissioner Block’s assigned vehicle. The PRC is currently checking to see if there are records relating to Commissioner Block’s use of the other 17 vehicles. That information was not provided to the OSA prior to completion of this Risk Assessment Report. C. Agency-Wide Analysis Required

Based on the gas card usage explained above, the responses received from the PRC to the OSA’s inquiries, and certain reports made to the OSA on its Fraud Hotline, the OSA has determined that risks exist in the PRC that require further analysis and test work. Furthermore, the OSA requested the PRC’s policies related to authorization to use a state vehicle for commuting purposes pursuant to Section 1.5.3.20 NMAC. The PRC replied that it has “no current PRC policies regarding vehicle use by commissioners for commuting purposes.” Not only did this create difficulty in reviewing Commissioner Block’s gas usage, it also reveals a significant risk that exists regarding the lack of records and controls over all Commissioners’ use of vehicles. In addition, upon OSA’s request for federal tax fringe benefit allocation or notification for Commissioner’s personal use of state-issued vehicles, the PRC responded that it “does not calculate fringe benefit allocations for personal use of a state vehicle for any commissioner.” Therefore, this area requires additional test work since there appears to be noncompliance with federal tax regulations applicable to fringe benefit allocation. The State Auditor has mandated that these risk concerns be addressed during a special examination by an IPA under OSA direction.

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IV. A.

RISK ASSESSMENT OF PER DIEM AND MILEAGE OSA Procedures and Results

The OSA requested and reviewed the PRC’s general ledger detail of all per diem and mileage reimbursement disbursement requests made by Commissioner Block from the beginning of his term in office, January 1, 2009, through July 31, 2011. Specifically, the OSA reviewed the “Itemized Schedule of Travel Expenses” processed for and paid to Commissioner Block for that time period. We requested and reviewed supporting documentation for per diem and mileage reimbursement disbursements made to Commissioner Block, including supporting receipts and supporting documentation for the purpose of the trips and locations, dates and times. The OSA also requested any non-travel related reimbursements from the PRC to Commissioner Block, but per the PRC there were no such transactions. In response to the OSA’s request, the PRC provided 247 pages of documentation related to travel advances and reimbursements made to Commissioner Block. The OSA also reviewed each of the 247 pages of travel detail submitted by the PRC in order to compare the travel times, dates and locations to the gas card purchases. Based on the PRC’s general ledger detail, Commissioner Block’s travel reimbursements amounted to $11,737.27 during less than a two and a half year time period (February 2009 to June 2011). Based on the OSA’s procedures and the results of those procedures, there appears to be a number of instances in which the PRC reimbursed Commissioner Block even though he failed to provide itemized receipts. In two instances, Commissioner Block circumvented procurement procedures related to air travel. We also noted occurrences in which Commissioner Block’s pin number was used for a gas card purchase at a location different than the location of travel during the same date and time. Additionally, Commissioner Block is yet to provide receipts in support of a travel advance he received in the amount of $1,003.96. Per inquiry to the PRC, Commissioner Block had not provided receipts or reimbursed the PRC at the time of his resignation. If the PRC is unable to obtain receipts from Commissioner Block to support the travel, it will have a disbursement to Commissioner Block that is not supported by receipts or other acceptable documentation. Control deficiencies and inconsistences noted during OSA’s review are as follows: 1) OSA noted 13 instances in which Commissioner Block did not provide itemized receipts to support meal costs totaling $441.63. One example includes a receipt lacking itemization for $30.56 at a Microbrewery in Albuquerque. Another “receipt” simply reads “guest receipts” with a hand-written total of $43.42, and there is no description which explains what constituted the charges. One hotel receipt indicates “RMSERV” in the amounts of $31.35 and $32.34, and has no other detail of the charges. Yet, the PRC reimbursed Commissioner Block for the amounts. 2) In a reimbursement related to a conference Commissioner Block attended in Ojai, California, the PRC reimbursed Commissioner Block for a Saturday night hotel room charge at a “package rate” of $350 plus $45.50 in tax. It is unclear why Commissioner Block was
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charged the “package rate,” provided the conference literature indicates a room rate of $250 is to be honored for the conference, which included the Saturday night stay in the dates listed. Furthermore, the conference’s first session began on Sunday at 3:30 P.M. The remainder of Commissioner Block’s stay for the conference was at the $250 rate. 3) Per our discussion with the PRC Acting ASD Director/CFO, Commissioner Block frequently failed to submit receipts within the required two week time period in which receipts were to be submitted to support advance travel payments made to him. At the time of completion of this Risk Assessment Report, Commissioner Block had not yet submitted receipts that support a travel disbursement advanced to him in the amount of $1,003.96 for travel in midJuly 2011. Per the PRC, it has made multiple requests to Commissioner Block to submit the required receipts that support the advanced travel payment. 4) Based on the documents we reviewed, Commissioner Block was registered for a conference held in Atlanta from November 13, 2010 through November 18, 2010. During this time, on November 14 and 15, 2011, gas purchases were made with Commissioner Block’s pin number. On November 14, 2010 at 11:14 P.M., 10.76 gallons of unleaded gas was purchased for $30.12 at a Santa Fe gas station. On November 15, 2010 at 7:56 a.m., 12.25 gallons of unleaded gas was purchased for a total of $32.58 at a Santo Domingo tribal gas station. Both gas purchases were made with Commissioner Block’s pin number, and both took place while documents indicate Commissioner Block was in attendance at the conference in Atlanta. In a memo contained in the documents submitted to the OSA by the PRC, it appears as though Commissioner Block had requested an affidavit of lost receipts for the entire trip. However, per our discussion with the PRC Acting ASD Director/CFO, the PRC denied Commissioner Block’s request for an affidavit of lost receipts for the entire trip. The PRC also subsequently requested that Commissioner Block reimburse the PRC due to his failure to provide adequate receipts for meals and lodging for the conference in which Commissioner Block was paid in advance. In August 2011, Commissioner Block paid the PRC $570.35. a. After the OSA’s review of the documentation originally submitted by the PRC to our office, the PRC supplied us with more information and documentation regarding this conference trip. The documentation indicated Commissioner Block changed his outgoing flight for the conference from November 13, 2010 to November 15, 2010, incurring a total rebooking fee of $907.70, which was in addition to the original $302.90 for the initial flight. The changes to the scheduled travel cost three times the originally scheduled flight. In addition, Commissioner Block circumvented purchasing controls by contacting the travel agent directly and requesting two changes to his flight schedule and incurring costs. These changes were not done in accordance with PRC’s purchasing policies. 5) In an instance of travel to Clayton, Commissioner Block received $103 for per diem for an overnight stay for the night of June 8, 2011. He left at 2:00 P.M. that day and returned at 7:00 P.M. on June 9, 2011. The vehicle documented as driven on the per diem form is a 2009 Ford Escape, plate number 1466SG. However, on June 8 and June 9, 2011 (same time as Commissioner Block’s travel to Clayton), five gas charges were made using Commissioner Block’s pin number in Española for plate number G59117. The charges total
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66.70 gallons for a total cost of $239.37. Not only are there gas charges in Española when Commissioner Block is documented as present in Clayton, but the charges in Española before, after, and during the trip are not for the same vehicle listed on the per diem form submitted by Commissioner Block. B. Agency-Wide Analysis Required

The OSA’s risk assessment reveals risks related to the PRC’s failure to require itemized receipts when reimbursing the Commissioner for per diem payments. Our risk assessment also identified risks related to receipts that support advance travel payments not being provided in a timely manner, and revealed concerns over Commissioners being able to circumvent purchasing controls. Additional testwork and analysis is required at the agency-wide level to determine the extent of the risks. The State Auditor has mandated that these risk concerns be addressed during a special examination by an IPA under OSA direction.

OSA – PRC Risk Assessment

15

V.

REFERRAL OF THE RISK ASSESSMENT REPORT

This Risk Assessment Report was originally prepared for the House Rules Impeachment Investigation Subcommittee. However, given the risks identified by the report related to gas and travel charges, and the concern that others may have assisted or illegally profited from Commissioner Block’s actions, the OSA will refer this report to the following entities: 1) 2) 3) 4) 5) 6) New Mexico Attorney General; Tax Fraud Investigations Division of the Taxation and Revenue Department; Public Regulation Commission; Legislative Finance Committee; Department of Finance and Administration; Atkinson & Co., Ltd., the independent audit firm that is conducting the PRC’s fiscal year 2011 financial audit and the special examination mandated by the State Auditor; and House Rules Impeachment Investigation Subcommittee.

7)

OSA – PRC Risk Assessment

16

VI. EXHIBITS

OSA – PRC Risk Assessment

17

EXHIBIT A – Illustration of Daily Gas Card Use for June 2011 Purchases are detailed in summary for each day a purchase was made. The purpose of the calendar presentation is to illustrate the overall questionable nature of the gas card purchases.

June 2011
MONDAY
st

TUESDAY
th

WEDNESDAY 1 19.335 gallons unleaded – $67.17 net cost

THURSDAY 2 21.184 gallons unleaded – $72.05 net cost

FRIDAY 3 28.995 gallons unleaded, 17.319 unleaded plus – $162.08 net cost

SATURDAY 4 14.209 gallons unleaded, 10.575 unleaded plus – $85.93 net cost

SUNDAY 5 No purchases

From the 1 through the 16 of June, 45 gas card purchases were made, totals follow:

Total gallons purchased = 584 Total Net Cost = $1,986.23
6 25.815 gallons unleaded – $87.25 net cost 7 74.516 gallons unleaded, 17.303 unleaded plus – $311.49 net cost 8 9.9 gallons unleaded – $33.23 net cost 9 41.316 gallons unleaded, 15.569 unleaded plus – $193.91 net cost

10 58.735 gallons unleaded – $201.90 net cost

11 42.512 gallons unleaded – $141.86 net cost

12 27.374 gallons unleaded, 13.055 unleaded plus – $136.41 net cost

13 26.999 gallons unleaded – $92.52 net cost

14 11.213 gallons unleaded, 18.268 unleaded plus – $101.77 net cost

15 73.251 gallons unleaded – $242.96 net cost

16 8.635 gallons unleaded, 7.924 unleaded plus – $55.70 net cost

17 No purchase activity after this date.

18

19

20

21

22

23

24

25

26

OSA – PRC Risk Assessment

18

EXHIBIT A (cont.) – Illustration of Daily Gas Card Use for May 2011 Purchases are detailed in summary for each day a purchase was made. The purpose of the calendar presentation is to illustrate the overall questionable nature of the gas card purchases.

May 2011
MONDAY TUESDAY WEDNESDAY THURSDAY FRIDAY SATURDAY SUNDAY 1 10.979 gallons unleaded – $40.03 net cost 7 5.537 gallons unleaded plus – $20.69 net cost 14 21.973 gallons unleaded, 17.157
unleaded plus – $145.64 net cost

60 different transactions took place in the month of May 2011 – totals are as follows:

Total gallons purchased in May 2011 = 837.884 Total Net Cost in May 2011 = $3,004.45

2 8.918 gallons unleaded plus – $33.68 net cost 9 25.701 gallons unleaded – $92.94 net cost 16 49.319 gallons unleaded, 45.86
super unleaded – $351.82 net cost

3 65.921 gallons unleaded – $241.58 net cost 10 33.821 gallons unleaded – $123.82 net cost 17 No purchases

4 12.43 gallons unleaded, 13.802
gallons unleaded plus – $98.10 net cost

5
13.491 gallons super unleaded, 11.666 gallons unleaded – $95.80 net cost

6 30.416 gallons unleaded, 10.748
gallons unleaded plus – $151.28 net cost

8 17.607 gallons unleaded – $63.67 net cost 15 No purchases

11 No purchases

12 11.668 gallons unleaded – $42.89 net cost 19 46.671 gallons unleaded, 9.505
unleaded plus – $196.41 net cost

13 31.317 gallons unleaded – $116.06 net cost 20 No purchases

18 No purchases

21 26.499 gallons unleaded, 15.711
unleaded plus – $150.10 net cost

22 30.193 gallons unleaded – $105.55 net cost 29 21.956 gallons unleaded – $75.00 net cost

23 28.01 gallons unleaded – $95.08 net cost 30 Memorial Day 58.389 gallons unleaded, 11.495
unleaded plus – $240.47 net cost

24 12.924 gallons unleaded, 12.143
unleaded plus – $88.33 net cost

25 18.77 gallons unleaded – $63.75 net cost

26 19.824 gallons unleaded – $67.72 net cost

27 43.755 gallons unleaded – $150.57 net cost

28 4.129 gallons unleaded, 15.108
unleaded plus – $67.94 net cost

31 24.466 gallons unleaded – $85.53 net cost

OSA – PRC Risk Assessment

19

EXHIBIT A (cont.) – Illustration of Daily Gas Card Use for April 2011 Purchases are detailed in summary for each day a purchase was made. The purpose of the calendar presentation is to illustrate the overall questionable nature of the gas card purchases.

April 2011
MONDAY TUESDAY WEDNESDAY THURSDAY FRIDAY 1 22.51 gallons unleaded – $75.88 net cost 8 24.259 gallons unleaded – $84.57 net cost 15 10.713 gallons unleaded – $38.10 net cost 22 Good Friday 10.529 gallons unleaded – $38.07 net cost 29 18.365 gallons unleaded – $66.96 net cost SATURDAY 2 No purchases SUNDAY 3 10.821 gallons unleaded plus – $38.05 net cost 10 No purchases

37 different gas card purchases took place in the month of April 2011 – totals are as follows:

Total gallons purchased in April 2011 = 376.68 Total Net Cost in April 2011 = $1,335.17
4 8.443 gallons unleaded – $28.67 net cost 11 21.646 gallons unleaded – $76.11 net cost 18 8.114 gallons unleaded – $28.86 net cost 25 33.753 gallons unleaded – $120.70 net cost 5 17.914 gallons unleaded, 0.404
super unleaded –

6 No purchases

7 8.252 gallons unleaded – $28.52 net cost 14 8.026 gallons
unleaded, 11.666 gallons unleaded plus –

9 9.615 gallons unleaded – $33.52 net cost 16 14.79 gallons unleaded – $52.59 net cost 23 No purchases

$63.40 net cost 12 No purchases 13 6.729 gallons unleaded – $23.93 net cost 20 16.08 gallons unleaded – $57.35 net cost 27 44.725 gallons unleaded – $159.39 net cost 17 No purchases

19 10.714 gallons unleaded – $38.10 net cost 26 No purchases

$71.43 net cost 21 18.543 gallons unleaded, 12.321
unleaded plus –

24 Easter No purchases

$111.98 net cost 28 27.748 gallons unleaded – $98.99 net cost 30 No purchases

OSA – PRC Risk Assessment

20

EXHIBIT A (cont.) – Illustration of Daily Gas Card Use for March 2011 Purchases are detailed in summary for each day a purchase was made. The purpose of the calendar presentation is to illustrate the overall questionable nature of the gas card purchases.

March 2010
MONDAY TUESDAY 1 10.666 gallons unleaded – $33.24 net cost WEDNESDAY 2 No purchases THURSDAY 3 No purchases FRIDAY 4 No purchases SATURDAY 5 No purchases SUNDAY 6 No purchases

7 16.176 gallons super unleaded – $57.04 net cost

8 No purchases

9 No purchases

10 8.628 gallons unleaded – $28.61 net cost

11 5.79 gallons unleaded – $18.97 net cost

12 10.726 gallons super unleaded – $38.04 net cost

13 No purchases

14 8.673 gallons unleaded – $28.41 net cost

15 No purchases

16 11.267 gallons unleaded – $36.52net cost

17 No purchases

18 11.569 gallons unleaded – $37.90net cost

19 No purchases

20 No purchases

21 10.118 gallons unleaded – $33.15net cost

22 No purchases

23 No purchases

24 8.68 gallons unleaded – $28.45 net cost

25 No purchases

26 2.802 gallons unleaded, 6.928
unleaded plus –

27 7.165 gallons unleaded – $23.69 net cost

$33.71 net cost 28 No purchases 29 11.427 gallons unleaded – $38.01 net cost 30 10.259 gallons unleaded, 16.547
unleaded plus –

31 No purchases

18 different gas card purchases took place in the month of March 2011 – totals are as follows:

$91.14 net cost

Total gallons purchased in March 2011 = 157.421 Total Net Cost in March 2011 = $526.88

OSA – PRC Risk Assessment

21

EXHIBIT A (cont.) – Illustration of Daily Gas Card Use for February 2011 Purchases are detailed in summary for each day a purchase was made. The purpose of the calendar presentation is to illustrate the overall questionable nature of the gas card purchases.

February 2011
MONDAY TUESDAY 1 No purchases WEDNESDAY 2 No purchases THURSDAY 3 No purchases FRIDAY 4 No purchases SATURDAY 5 14.825 gallons super unleaded – $46.20 net cost SUNDAY 6 28.058 gallons unleaded, 18.263
gallons diesel – $141.18 net cost

7 10.434 gallons unleaded – $29.80 net cost

8 No purchases

9 9.884 gallons unleaded – $28.23 net cost

10 No purchases

11 9.871 gallons unleaded – $28.19 net cost

12 No purchases

13 12.907 gallons unleaded – $37.64 net cost

14 9.874 gallons unleaded – $28.20 net cost

15 No purchases

16 No purchases

17 15.572 gallons unleaded, 12.015
super unleaded –

18 21.877 gallons super unleaded – $68.06 net cost

19 No purchases

20 No purchases

$82.12 net cost 21 Presidents Day 12.926 gallons unleaded – $38.72 net cost 22 No purchases 23 No purchases 24 15.404 gallons unleaded, 22.609
gallons super unleaded – $122.52

25 No purchases

26 23.74 gallons diesel – $88.24 net cost

27 15.264 gallons unleaded – $47.57 net cost

net cost 28 No purchases

19 different gas card purchases took place in the month of February 2011 – totals are as follows:

Total gallons purchased in February 2011 = 253.523 Total Net Cost in February 2011 = $786.67

OSA – PRC Risk Assessment

22

EXHIBIT A (cont.) – Illustration of Daily Gas Card Use for January 2011 Purchases are detailed in summary for each day a purchase was made. The purpose of the calendar presentation is to illustrate the overall questionable nature of the gas card purchases.

January 2011
MONDAY TUESDAY WEDNESDAY THURSDAY FRIDAY SATURDAY 1 No purchases SUNDAY 2 No purchases

4 different gas card purchases took place in the month of January 2011 – totals are as follows:

Total gallons purchased in January 2011 = 71.821 Total Net Cost in January 2011 = $200.51
3 No purchases 4 13.797 gallons unleaded – $37.48 net cost 11 No purchases 5 No purchases 6 No purchases 7 No purchases 8 No purchases 9 No purchases

10 No purchases

12 39.162 gallons unleaded – $110.29 net cost 19 No purchases

13 No purchases

14 18.862 gallons unleaded – $52.74 net cost 21 No purchases

15 No purchases

16 No purchases

17 Martin L. King HOLIDAY

18 No purchases

20 No purchases

22 No purchases

23 No purchases

24 No purchases

25 No purchases

26 No purchases

27 No purchases

28 No purchases

29 No purchases

30 No purchases

31 No purchases

OSA – PRC Risk Assessment

23

EXHIBIT B – Vehicle Gas Cards Used
Jerome Block Jr Wex Gas Card Usage Report Jan 1, 2009 to July 31, 2011 Employee or Division Vehicle Card Assigned Description of Vehicle 1 assigned to PRC employee 04 DODGE DURANGO-CHAR.GRAY Vehicle Card Department 5000 10 5000 4 3400 1 3100 3 5000 1 UNASSIGNED 1 UNASSIGNED 1 UNASSIGNED 4 131000 1 TRANS 1 5000 8 TRANS 186 3500 10 5000 18 3000 1 SFMO 33 TRANS 2 3300 3 288 Total purchases 102 with other vehicles than Block's assigned vehicle 000906SG

Card Number 0112 - 1 Total times used 0111 - 2 Total times used 0126 - 1 Total times used 0083 - 1 Total times used 0165 - 1 Total times used 0170 - 1 Total times used 0169 - 1 Total times used 0167 - 1 Total times used 0171 - 1 Total times used 0172 - 1 Total times used 0059 - 1 Total times used 0187 - 1 Total times used 0144 - 1 Total times used 0138 - 2 Total times used 0163 - 1 Total times used 0183 - 1 Total times used 0189 - 1 Total times used 0100 - 1 Total times used

Customer Vehicle ID 209040

2 assigned to PRC employee 04 DODGE DURANGO-GRAY

209041

3 assigned to PRC employee 04 DODGE DURANGO 4X4 SUV-WH

221340

4 Not provided

Not provided

5 PSB-CHECK OUT VEH.

08 FORD EXP, 4X4-WH

6 CRD CK. OUT VEH.

08 HONDA HYBRID-SILVER

000995SG

7 ASD-CK OUT VEH.

08 HONDA HYBRID-SILVER

000996SG

8 ASD COS

08 HONDA HYBRID-SILVER

000998SG

9 assigned to PRC employee 08 DODGE CALIBER-KHAKI

001004SG

10 TSD APPLICATIONS

08 DODGE CALIBER-KHAKI

001005SG

11 assigned to PRC employee 01 FORD CROWN VIC-BLK

2FAFP71W31X159539

12 COMM. BLOCK

04 DODGE DURANGO-TAN

G59117

13 FFTA CK. OUT

06 FORD FIVE HUNDRED-RED

G61442

14 assigned to PRC employee 05 FORD EXP, 4X4, WHITE

G62117

15 INSURANCE - CHECK OUT. VEH. 08 FORD ESCAPE, 4X4, 4 DOOR-BLK

G70714

16 assigned to PRC employee 09 FORD ESCAPE-WH

G77609

17 assigned to PRC employee 09 FORD ESCAPE-WH

KC85019

18 Not provided

Not provided

TEMP 7

OSA – PRC Risk Assessment

24

EXHIBIT C – Questionable Gas Card Transactions (page 1 of 5)
Jerome Block Jr Wex Gas Card Usage Report Jan 1, 2009 to July 31, 2011 Card Number 0187 - 1 0187 - 1 Vehicle Card Dep Customer Vehicle ID Transaction Date Transaction Time Merchant TRANS G59117 6/16/2011 2:43:41 PM CHEVRON TRANS G59117 6/16/2011 2:51:10 PM CHEVRON Merchant Name CHEVRON 0302023 CHEVRON 0302023 Merchant City ESPANOLA ESPANOLA Product UN+EADED PLUS UNLEADED Units Net Cost (=) 7.924 $27.07 8.635 $28.63 16.559 $55.70 14.208 13.393 22.176 23.474 73.251 4.41 13.858 11.213 29.481 13.335 13.664 26.999 13.055 27.374 40.429 14.062 15.3 13.15 42.512 $47.40 $44.68 $73.98 $76.90 $242.96 $15.24 $47.89 $38.64 $101.77 $45.02 $47.50 $92.52 $45.64 $90.77 $136.41 $47.48 $50.77 $43.61 $141.86

0187 - 1 0187 - 1 0187 - 1 0172 - 1

TRANS TRANS TRANS TRANS

G59117 G59117 G59117 001005SG

6/15/2011 6/15/2011 6/15/2011 6/15/2011

11:42:09 AM 11:45:31 AM 12:54:51 PM 10:59:15 AM

CONOCO CONOCO CONOCO PHILL 66

OHKAY EXPRESS MART OHKAY EXPRESS MART OHKAY EXPRESS MART ALLSUPS 336

ESPANOLA ESPANOLA ESPANOLA SANTA FE

UNLEADED UNLEADED UNLEADED UNLEADED

0187 - 1 0187 - 1 0187 - 1

TRANS TRANS TRANS

G59117 G59117 G59117

6/14/2011 6/14/2011 6/14/2011

3:17:28 PM CONOCO 3:19:02 PM CONOCO 5:25:23 PM CHEVRON

OHKAY EXPRESS MART OHKAY EXPRESS MART CHEVRON 0208520

ESPANOLA ESPANOLA HERNANDEZ

UN+EADED PLUS UN+EADED PLUS UNLEADED

0187 - 1 0187 - 1

TRANS TRANS

G59117 G59117

6/13/2011 6/13/2011

9:42:53 AM CONOCO 8:30:04 PM CHEVRON

OHKAY EXPRESS MART CHEVRON 0208520

ESPANOLA HERNANDEZ

UNLEADED UNLEADED

0187 - 1 0187 - 1

TRANS TRANS

G59117 G59117

6/12/2011 6/12/2011

4:21:13 PM CONOCO 9:15:58 PM CHEVRON

OHKAY EXPRESS MART CHEVRON 0302023

ESPANOLA ESPANOLA

UN+EADED PLUS UNLEADED

0187 - 1 0112 - 1 0112 - 1

TRANS 5000 5000

G59117 209040 209040

6/11/2011 6/11/2011 6/11/2011

12:26:46 PM CONOCO 10:06:00 AM SHELL 9:54:00 AM SHELL

OHKAY EXPRESS MART SO CERRILLOS SI SO CERRILLOS SI

ESPANOLA SANTA FE SANTA FE

UNLEADED UNLEADED UNLEADED

Card Number 0187 - 1 0187 - 1 0187 - 1 0112 - 1 0112 - 1

Vehicle Card Dep TRANS TRANS TRANS 5000 5000

Customer Vehicle ID Transaction Date Transaction Time G59117 6/10/2011 12:53:39 PM G59117 6/10/2011 2:59:10 PM G59117 6/10/2011 1:48:37 PM 209040 6/10/2011 1:43:01 PM 209040 6/10/2011 8:36:12 AM

Merchant CONOCO CHEVRON CHEVRON PHILL 66 PHILL 66

Merchant Name OHKAY EXPRESS MART CHEVRON 0208520 CHEVRON 0208520 ALLSUPS 345 ALLSUPS 345

Merchant City ESPANOLA HERNANDEZ HERNANDEZ SANTA FE SANTA FE

Product UNLEADED UNLEADED UNLEADED UNLEADED UNLEADED

Units Net Cost (=) 9.853 $33.27 22.298 $77.95 16.31 $57.02 4.429 $14.51 5.845 $19.15 58.735 $201.90 13.208 11.25 16.858 15.569 56.885 9.9 12.649 18.269 24.453 14.13 5.015 17.303 91.819 $44.59 $37.98 $56.91 $54.43 $193.91 $33.23 $42.71 $61.68 $82.56 $47.42 $16.63 $60.49 $311.49

0187 - 1 0187 - 1 0187 - 1 0187 - 1

TRANS TRANS TRANS TRANS

G59117 G59117 G59117 G59117

6/9/2011 6/9/2011 6/9/2011 6/9/2011

10:28:16 AM 8:33:17 PM 8:34:18 PM 8:02:28 PM

CONOCO CONOCO CONOCO CONOCO

OHKAY EXPRESS MART OHKAY EXPRESS MART OHKAY EXPRESS MART OHKAY EXPRESS MART

ESPANOLA ESPANOLA ESPANOLA ESPANOLA

UNLEADED UNLEADED UNLEADED UN+EADED PLUS

0187 - 1 0187 - 1 0187 - 1 0187 - 1 0187 - 1 0112 - 1 0187 - 1

TRANS TRANS TRANS TRANS TRANS 5000 TRANS

G59117 G59117 G59117 G59117 G59117 209040 G59117

6/8/2011 6/7/2011 6/7/2011 6/7/2011 6/7/2011 6/7/2011 6/7/2011

1:46:45 PM CHEVRON 5:57:46 PM 6:19:25 PM 8:24:37 PM 9:17:16 PM 4:07:36 PM 6:16:46 PM CONOCO CONOCO CONOCO CHEVRON PHILL 66 CONOCO

CHEVRON 0302023 OHKAY EXPRESS MART OHKAY EXPRESS MART OHKAY EXPRESS MART CHEVRON 0302023 ALLSUPS 336 OHKAY EXPRESS MART

ESPANOLA ESPANOLA ESPANOLA ESPANOLA ESPANOLA SANTA FE ESPANOLA

UNLEADED UNLEADED UNLEADED UNLEADED UNLEADED UNLEADED UN+EADED PLUS

Card Number 0187 - 1 0112 - 1 0112 - 1

Vehicle Card Dep Customer Vehicle ID Transaction Date Transaction Time TRANS G59117 6/6/2011 10:04:51 AM 5000 209040 6/6/2011 7:46:00 PM 5000 209040 6/6/2011 8:52:19 AM

Merchant CONOCO SHELL PHILL 66

Merchant Name OHKAY EXPRESS MART ST MIKES SS ALLSUPS 336

Merchant City ESPANOLA SANTA FE SANTA FE

Product UNLEADED UNLEADED UNLEADED

Units Net Cost (=) 9.724 $33.22 8.95 $30.21 7.141 $23.82 25.815 $87.25 10.575 9.758 4.451 24.784 14.112 14.883 17.319 46.314 12.938 8.246 21.184 13.742 5.593 19.335 $37.39 $33.33 $15.21 $85.93 $48.21 $52.63 $61.24 $162.08 $43.55 $28.50 $72.05 $47.50 $19.67 $67.17

0187 - 1 0187 - 1 0112 - 1

TRANS TRANS 5000

G59117 G59117 209040

6/4/2011 6/4/2011 6/4/2011

7:30:11 PM CONOCO 7:34:41 PM CONOCO 7:56:40 PM CHEVRON

OHKAY EXPRESS MART OHKAY EXPRESS MART CHEVRON 0304515

ESPANOLA ESPANOLA SANTA FE

UN+EADED PLUS UNLEADED UNLEADED

0187 - 1 0187 - 1 0187 - 1

TRANS TRANS TRANS

G59117 G59117 G59117

6/3/2011 6/3/2011 6/3/2011

10:57:13 AM CONOCO 10:16:44 PM CHEVRON 5:21:33 PM CONOCO

OHKAY EXPRESS MART CHEVRON 0208520 OHKAY EXPRESS MART

ESPANOLA HERNANDEZ ESPANOLA

UNLEADED UNLEADED UN+EADED PLUS

0112 - 1 0187 - 1

5000 TRANS G59117

209040

6/2/2011 6/2/2011

12:42:00 PM UNBRANDED 1:34:18 PM CONOCO

QUICK FUEL OHKAY EXPRESS MART

ALBUQUERQUE ESPANOLA

UNLEADED UNLEADED

0187 - 1 0112 - 1

TRANS 5000

G59117 209040

6/1/2011 6/1/2011

7:28:26 PM CONOCO 5:31:32 PM CONOCO

OHKAY EXPRESS MART QUIK STOP #11

ESPANOLA SANTA FE

UNLEADED UNLEADED

OSA – PRC Risk Assessment

25

EXHIBIT C (cont.) – Questionable Gas Card Transactions (page 2 of 5)
Card Number 0187 - 1 0187 - 1 0187 - 1 0144 - 1 0187 - 1 Vehicle Card Dep Customer Vehicle ID Transaction Date Transaction Time Merchant TRANS G59117 5/31/2011 4:20:22 PM PHILL 66 TRANS TRANS TRANS G59117 G59117 3500 G61442 G59117 5/30/2011 5/30/2011 5/30/2011 5/30/2011 1:14:37 PM 1:16:50 PM 6:23:53 PM 7:47:41 PM CONOCO CONOCO PHILL 66 CONOCO Merchant Name RHOC KICKS 66 OHKAY EXPRESS MART OHKAY EXPRESS MART QUIK STOP #5 OHKAY EXPRESS MART Merchant City ESPANOLA ESPANOLA ESPANOLA SANTA FE ESPANOLA Product UNLEADED UNLEADED UNLEADED UNLEADED UN+EADED PLUS Units Net Cost (=) 24.466 $85.53 14.737 37.521 6.131 11.495 69.884 21.956 15.108 4.129 19.237 9.79 17.445 16.52 43.755 8.621 11.203 19.824 18.77 12.924 12.143 25.067 $50.34 $128.17 $21.31 $40.65 $240.47 $75.00 $53.43 $14.51 $67.94 $34.23 $58.90 $57.44 $150.57 $29.45 $38.27 $67.72 $63.75 $44.66 $43.67 $88.33

0187 - 1 0187 - 1 0144 - 1

TRANS TRANS

G59117 G59117 3500 G61442

5/29/2011 5/28/2011 5/28/2011

4:52:38 PM CONOCO 11:06:59 AM PHILL 66 7:02:26 PM GIANT

OHKAY EXPRESS MART OHKAY TRAVEL CENTER GIANT #6046

ESPANOLA SAN JUAN PUEBLO SANTA FE

UNLEADED UN+EADED PLUS UNLEADED

0187 - 1 0187 - 1 0144 - 1

TRANS TRANS

G59117 G59117 3500 G61442

5/27/2011 5/27/2011 5/27/2011

5:20:40 PM PHILL 66 5:29:59 PM CHEVRON 12:16:00 PM SHELL

RHOC KICKS 66 CHEVRON 0302023 ST MIKES SS

ESPANOLA ESPANOLA SANTA FE

UNLEADED UNLEADED UNLEADED

0187 - 1 0187 - 1

TRANS TRANS

G59117 G59117

5/26/2011 5/26/2011

2:14:46 PM CONOCO 2:51:39 PM CONOCO

OHKAY EXPRESS MART OHKAY EXPRESS MART

ESPANOLA ESPANOLA

UNLEADED UNLEADED

0144 - 1 0187 - 1 0187 - 1 TRANS TRANS

3500 G61442 G59117 G59117

5/25/2011 5/24/2011 5/24/2011

6:55:37 PM PHILL 66 5:51:21 PM PHILL 66 6:38:33 PM CONOCO

ALLSUPS 345 RHOC KICKS 66 OHKAY EXPRESS MART

SANTA FE ESPANOLA ESPANOLA

UNLEADED UNLEADED UN+EADED PLUS

Card Number 0187 - 1 0144 - 1

Vehicle Card Dep Customer Vehicle ID Transaction Date Transaction Time Merchant TRANS G59117 5/23/2011 10:41:18 AM CONOCO 3500 G61442 5/23/2011 11:20:00 AM PHILL 66

Merchant Name OHKAY EXPRESS MART SDTBE

Merchant City Product ESPANOLA UNLEADED SANTO DOMINGO PUEB UNLEADED

Units Net Cost (=) 13.667 $47.51 14.343 $47.57 28.01 $95.08 15.31 14.883 30.193 4.87 21.629 15.711 42.21 16.832 8.638 12.845 8.356 9.505 56.176 8.016 15.993 15.57 9.74 45.86 95.179 $53.22 $52.33 $105.55 $16.93 $76.05 $57.12 $150.10 $58.51 $30.03 $44.65 $29.04 $34.18 $196.41 $28.98 $57.19 $56.30 $35.26 $174.09 $351.82

0187 - 1 0187 - 1

TRANS TRANS

G59117 G59117

5/22/2011 5/22/2011

3:48:36 PM CONOCO 5:38:37 PM PHILL 66

OHKAY EXPRESS MART RHOC KICKS 66

ESPANOLA ESPANOLA

UNLEADED UNLEADED

0187 - 1 0187 - 1 0187 - 1

TRANS TRANS TRANS

G59117 G59117 G59117

5/21/2011 5/21/2011 5/21/2011

12:20:01 PM CONOCO 12:45:05 PM PHILL 66 3:39:12 PM PHILL 66

OHKAY EXPRESS MART RHOC KICKS 66 RHOC KICKS 66

ESPANOLA ESPANOLA ESPANOLA

UNLEADED UNLEADED UN+EADED PLUS

0187 - 1 0187 - 1 0187 - 1 0187 - 1 0187 - 1

TRANS TRANS TRANS TRANS TRANS

G59117 G59117 G59117 G59117 G59117

5/19/2011 5/19/2011 5/19/2011 5/19/2011 5/19/2011

11:19:05 AM 3:04:32 PM 3:13:13 PM 4:36:41 PM 4:05:28 PM

CONOCO CONOCO CONOCO CHEVRON CONOCO

OHKAY EXPRESS MART OHKAY EXPRESS MART OHKAY EXPRESS MART CHEVRON 0302023 OHKAY EXPRESS MART

ESPANOLA ESPANOLA ESPANOLA ESPANOLA ESPANOLA

UNLEADED UNLEADED UNLEADED UNLEADED UN+EADED PLUS

0187 - 1 0144 - 1 0144 - 1 0187 - 1

TRANS TRANS

TRANS

G59117 G59117 3500 G61442 3500 G61442 G59117

5/16/2011 5/16/2011 5/16/2011 5/16/2011 5/16/2011

11:46:05 AM 2:37:44 PM 11:20:00 AM 11:25:00 AM 3:54:44 PM

PHILL 66 CONOCO SHELL SHELL CONOCO

RHOC KICKS 66 OHKAY EXPRESS MART ST MIKES SS ST MIKES SS OHKAY EXPRESS MART

ESPANOLA ESPANOLA SANTA FE SANTA FE ESPANOLA

UNLEADED UNLEADED UNLEADED UNLEADED SUPER UNLEADED

OSA – PRC Risk Assessment

26

EXHIBIT C (cont.) – Questionable Gas Card Transactions (page 3 of 5)
Card Number 0187 - 1 0144 - 1 0187 - 1 Vehicle Card Dep Customer Vehicle ID Transaction Date Transaction Time Merchant TRANS TRANS G59117 3500 G61442 G59117 5/14/2011 5/14/2011 5/14/2011 12:40:20 PM CONOCO 8:07:00 PM UNBRANDED 6:06:37 PM CONOCO Merchant Name OHKAY EXPRESS MART TRIPLE S GROCERY OHKAY EXPRESS MART Merchant City ESPANOLA ESPANOLA ESPANOLA Product UNLEADED UNLEADED UN+EADED PLUS Units 12.961 9.012 17.157 39.13 7.807 15.397 8.113 31.317 11.668 11.661 14.853 7.307 33.821 25.701 7.544 10.063 17.607 5.537 8.04 22.376 10.748 41.164 Net Cost (=) $47.65 $32.86 $65.13 $145.64 $28.70 $57.21 $30.15 $116.06 $42.89 $42.87 $54.60 $26.35 $123.82 $92.94 $27.28 $36.39 $63.67 $20.69 $29.56 $80.92 $40.80 $151.28

0187 - 1 0187 - 1 0187 - 1

TRANS TRANS TRANS

G59117 G59117 G59117

5/13/2011 5/13/2011 5/13/2011

10:32:53 AM CONOCO 6:11:18 PM PHILL 66 6:15:02 PM PHILL 66

OHKAY EXPRESS MART RHOC KICKS 66 RHOC KICKS 66

ESPANOLA ESPANOLA ESPANOLA

UNLEADED UNLEADED UNLEADED

0187 - 1 0187 - 1 0187 - 1 0144 - 1

TRANS TRANS TRANS

G59117 G59117 G59117 3500 G61442

5/12/2011 5/10/2011 5/10/2011 5/10/2011

10:12:32 AM CONOCO 9:12:23 AM CONOCO 9:35:56 AM CONOCO 4:05:00 PM UNBRANDED

OHKAY EXPRESS MART OHKAY EXPRESS MART OHKAY EXPRESS MART NAMBE FALLS TRAVEL C

ESPANOLA ESPANOLA ESPANOLA SANTA FE

UNLEADED UNLEADED UNLEADED UNLEADED

0187 - 1 0187 - 1 0144 - 1

TRANS TRANS

G59117 G59117 3500 G61442

5/9/2011 5/8/2011 5/8/2011

7:12:10 PM CONOCO 10:17:42 AM CONOCO 12:02:12 PM UNBRANDED

OHKAY EXPRESS MART OHKAY EXPRESS MART HOWDY'S# 15

ESPANOLA ESPANOLA LAS CRUCES

UNLEADED UNLEADED UNLEADED

0187 - 1 0187 - 1 0187 - 1 0187 - 1

TRANS TRANS TRANS TRANS

G59117 G59117 G59117 G59117

5/7/2011 5/6/2011 5/6/2011 5/6/2011

4:27:52 PM CONOCO 11:34:36 AM CONOCO 1:47:56 PM CONOCO 11:43:11 AM CONOCO

OHKAY EXPRESS MART OHKAY EXPRESS MART OHKAY EXPRESS MART OHKAY EXPRESS MART

ESPANOLA ESPANOLA ESPANOLA ESPANOLA

UN+EADED PLUS UNLEADED UNLEADED UN+EADED PLUS

Card Number 0187 - 1 0187 - 1

Vehicle Card Dep Customer Vehicle ID Transaction Date Transaction Time Merchant TRANS G59117 5/5/2011 1:00:37 PM CONOCO TRANS G59117 5/5/2011 4:20:42 PM PHILL 66

Merchant Name OHKAY EXPRESS MART RHOC KICKS 66

Merchant City ESPANOLA ESPANOLA

Product Units Net Cost (=) SUPER UNLEADED 13.491 $52.56 UNLEADED 11.666 $43.24 25.157 $95.80 UNLEADED UN+EADED PLUS 12.435 13.802 26.237 22.127 9.38 9.544 24.87 65.921 8.918 10.979 $45.71 $52.39 $98.10 $81.34 $34.29 $35.27 $90.68 $241.58 $33.68 $40.03

0187 - 1 0187 - 1

TRANS TRANS

G59117 G59117

5/4/2011 5/4/2011

2:36:58 PM CONOCO 3:58:19 PM CONOCO

OHKAY EXPRESS MART OHKAY EXPRESS MART

ESPANOLA ESPANOLA

0187 - 1 0187 - 1 0187 - 1 0083 - 1

TRANS TRANS TRANS 3100

G59117 G59117 G59117

5/3/2011 5/3/2011 5/3/2011 5/3/2011

6:54:54 PM 12:18:34 PM 3:19:23 PM 3:57:23 PM

CONOCO CONOCO PHILL 66 PHILL 66

OHKAY EXPRESS MART OHKAY EXPRESS MART RHOC KICKS 66 ALLSUPS 336

ESPANOLA ESPANOLA ESPANOLA SANTA FE

UNLEADED UNLEADED UNLEADED UNLEADED

0187 - 1 0187 - 1

TRANS TRANS

G59117 G59117

5/2/2011 5/1/2011

4:57:49 PM CONOCO 3:01:24 PM CONOCO

OHKAY EXPRESS MART OHKAY EXPRESS MART

ESPANOLA ESPANOLA

UN+EADED PLUS UNLEADED

0187 - 1 0187 - 1

TRANS TRANS

G59117 G59117

4/29/2011 4/29/2011

2:21:47 PM CONOCO 3:42:42 PM CONOCO

OHKAY EXPRESS MART OHKAY EXPRESS MART

ESPANOLA ESPANOLA

UNLEADED UNLEADED

10.457 7.908 18.365 5.277 22.471 27.748 11.968 19.106 13.651 44.725

$38.13 $28.83 $66.96 $19.08 $79.91 $98.99 $42.80 $68.32 $48.27 $159.39

0187 - 1 0083 - 1

TRANS 3100

G59117

4/28/2011 4/28/2011

9:54:47 AM CONOCO 3:45:09 PM PHILL 66

OHKAY EXPRESS MART CERRILLOS SS SV

ESPANOLA SANTA FE

UNLEADED UNLEADED

0187 - 1 0187 - 1 0083 - 1

TRANS TRANS 3100

G59117 G59117

4/27/2011 4/27/2011 4/27/2011

2:20:20 PM CONOCO 4:46:47 PM CONOCO 9:04:54 AM PHILL 66

OHKAY EXPRESS MART OHKAY EXPRESS MART ALLSUPS 336

ESPANOLA ESPANOLA SANTA FE

UNLEADED UNLEADED UNLEADED

OSA – PRC Risk Assessment

27

EXHIBIT C (cont.) – Questionable Gas Card Transactions (page 4 of 5)
Card Number 0187 - 1 0187 - 1 Vehicle Card Dep Customer Vehicle ID Transaction Date Transaction Time Merchant TRANS G59117 4/25/2011 12:41:35 PM CONOCO TRANS G59117 4/25/2011 1:29:26 PM CONOCO Merchant Name OHKAY EXPRESS MART OHKAY EXPRESS MART Merchant City ESPANOLA ESPANOLA Product UNLEADED UNLEADED Units Net Cost (=) 10.662 $38.13 23.091 $82.57 33.753 $120.70 10.529 13.229 5.314 12.321 30.864 3.984 5.359 6.737 16.08 10.714 8.114 14.79 2.677 8.036 10.713 8.026 11.666 19.692 $38.07 $47.57 $19.11 $45.30 $111.98 $14.33 $19.06 $23.96 $57.35 $38.10 $28.86 $52.59 $9.52 $28.58 $38.10 $28.54 $42.89 $71.43

0187 - 1 0187 - 1 0187 - 1 0187 - 1

TRANS TRANS TRANS TRANS

G59117 G59117 G59117 G59117

4/22/2011 4/21/2011 4/21/2011 4/21/2011

6:38:14 PM PHILL 66 12:17:02 PM PHILL 66 5:00:59 PM PHILL 66 6:09:32 PM CONOCO

RHOC KICKS 66 RHOC KICKS 66 RHOC KICKS 66 OHKAY EXPRESS MART

ESPANOLA ESPANOLA ESPANOLA ESPANOLA

UNLEADED UNLEADED UNLEADED UN+EADED PLUS

0187 - 1 0187 - 1 0187 - 1

TRANS TRANS TRANS

G59117 G59117 G59117

4/20/2011 4/20/2011 4/20/2011

11:10:53 AM PHILL 66 2:55:20 PM CONOCO 3:32:15 PM CONOCO

RHOC KICKS 66 OHKAY EXPRESS MART OHKAY EXPRESS MART

ESPANOLA ESPANOLA ESPANOLA

UNLEADED UNLEADED UNLEADED

0187 - 1 0187 - 1 0187 - 1 0187 - 1 0187 - 1

TRANS TRANS TRANS TRANS TRANS

G59117 G59117 G59117 G59117 G59117

4/19/2011 4/18/2011 4/16/2011 4/15/2011 4/15/2011

2:17:31 PM CONOCO 2:11:42 PM CONOCO 1:59:24 PM CONOCO 3:49:53 PM CONOCO 4:54:48 PM CONOCO

OHKAY EXPRESS MART OHKAY EXPRESS MART OHKAY EXPRESS MART OHKAY EXPRESS MART OHKAY EXPRESS MART

ESPANOLA ESPANOLA ESPANOLA ESPANOLA ESPANOLA

UNLEADED UNLEADED UNLEADED UNLEADED UNLEADED

0187 - 1 0187 - 1

TRANS TRANS

G59117 G59117

4/14/2011 4/14/2011

11:02:23 AM CONOCO 12:48:32 PM CONOCO

OHKAY EXPRESS MART OHKAY EXPRESS MART

ESPANOLA ESPANOLA

UNLEADED UN+EADED PLUS

Card Number 0187 - 1 0187 - 1 0187 - 1

Vehicle Card Dep Customer Vehicle ID Transaction Date Transaction Time Merchant TRANS G59117 4/13/2011 2:45:08 PM CONOCO TRANS TRANS G59117 G59117 4/11/2011 4/11/2011 3:38:11 PM CONOCO 3:27:48 PM CHEVRON

Merchant Name OHKAY EXPRESS MART OHKAY EXPRESS MART CHEVRON 0302023

Merchant City ESPANOLA ESPANOLA ESPANOLA

Product UNLEADED UNLEADED UNLEADED

Units Net Cost (=) 6.729 $23.93 8.126 13.52 21.646 9.615 20.444 3.815 24.259 8.252 0.404 8.255 9.659 18.318 8.443 10.821 11.334 11.176 22.51 10.259 16.547 26.806 11.427 7.165 2.802 6.928 9.73 5.717 5.55 11.267 10.726 $28.57 $47.54 $76.11 $33.52 $71.27 $13.30 $84.57 $28.52 $1.49 $28.53 $33.38 $63.40 $28.67 $38.05 $37.93 $37.95 $75.88 $34.12 $57.02 $91.14 $38.01 $23.69 $9.49 $24.22 $33.71 $18.95 $17.57 $36.52 $38.04

0187 - 1 0187 - 1 0187 - 1

TRANS TRANS TRANS

G59117 G59117 G59117

4/9/2011 4/8/2011 4/8/2011

12:49:16 PM CONOCO 6:07:03 PM CONOCO 6:12:12 PM CONOCO

OHKAY EXPRESS MART OHKAY EXPRESS MART OHKAY EXPRESS MART

ESPANOLA ESPANOLA ESPANOLA

UNLEADED UNLEADED UNLEADED

0187 - 1 0187 - 1 0187 - 1 0187 - 1

TRANS TRANS TRANS TRANS

G59117 G59117 G59117 G59117

4/7/2011 4/5/2011 4/5/2011 4/5/2011

3:19:56 PM CONOCO 3:28:06 PM CONOCO 3:29:34 PM CONOCO 3:51:13 PM CONOCO

OHKAY EXPRESS MART OHKAY EXPRESS MART OHKAY EXPRESS MART OHKAY EXPRESS MART

ESPANOLA ESPANOLA ESPANOLA ESPANOLA

UNLEADED SUPER UNLEADED UNLEADED UNLEADED

0187 - 1 0187 - 1 0187 - 1 0187 - 1

TRANS TRANS TRANS TRANS

G59117 G59117 G59117 G59117

4/4/2011 4/3/2011 4/1/2011 4/1/2011

8:20:33 AM PHILL 66 4:00:27 PM CONOCO 12:44:35 PM CONOCO 3:17:59 PM CONOCO

OHKAY TRAVEL CENTER OHKAY EXPRESS MART OHKAY EXPRESS MART OHKAY EXPRESS MART

SAN JUAN PUEBLO ESPANOLA ESPANOLA ESPANOLA

UNLEADED UN+EADED PLUS UNLEADED UNLEADED

0187 - 1 0187 - 1

TRANS TRANS

G59117 G59117

3/30/2011 3/30/2011

4:50:45 PM CONOCO 4:51:24 PM CONOCO

OHKAY RV PARK OHKAY EXPRESS MART

ESPANOLA ESPANOLA

UNLEADED UN+EADED PLUS

0187 - 1 0187 - 1 0187 - 1 0187 - 1

TRANS TRANS TRANS TRANS

G59117 G59117 G59117 G59117

3/29/2011 3/27/2011 3/26/2011 3/26/2011

2:27:16 PM CONOCO 3:21:48 PM CONOCO 6:53:08 PM CHEVRON 7:03:11 PM CHEVRON

OHKAY EXPRESS MART OHKAY EXPRESS MART CHEVRON 0208520 CHEVRON 0208520

ESPANOLA ESPANOLA HERNANDEZ HERNANDEZ

UNLEADED UNLEADED UNLEADED UN+EADED PLUS

0187 - 1 0165 - 1

TRANS

G59117 5000 000906SG

3/16/2011 3/16/2011

5:44:27 PM CHEVRON 8:11:00 PM DIAMOND

CHEVRON 0208520 CAMEL ROCK VALERO

HERNANDEZ SANTA FE

UNLEADED UNLEADED

0187 - 1

TRANS

G59117

3/12/2011

11:04:24 AM PHILL 66

BIG ROCK

ESPANOLA

SUPER UNLEADED

OSA – PRC Risk Assessment

28

EXHIBIT C (cont.) – Questionable Gas Card Transactions (page 5 of 5)
Card Number 0187 - 1 0187 - 1 0187 - 1 Vehicle Card Dep Customer Vehicle ID Transaction Date Transaction Time Merchant TRANS G59117 3/10/2011 12:05:16 PM CHEVRON TRANS TRANS G59117 G59117 3/7/2011 3/7/2011 4:09:37 PM PHILL 66 4:11:48 PM PHILL 66 Merchant Name CHEVRON 0208520 BIG ROCK BIG ROCK Merchant City HERNANDEZ ESPANOLA ESPANOLA Product UNLEADED SUPER UNLEADED NONFUEL Units Net Cost (=) 8.628 $28.61 16.176 0 16.176 23.74 22.609 15.404 38.013 9.023 12.854 21.877 12.015 15.572 27.587 9.874 12.907 9.871 9.884 10.434 3.649 24.409 18.263 46.321 14.825 18.862 24.991 14.171 39.162 12.252 10.76 11 23.03 14.951 37.981 18.804 10.634 11.913 22.547 13.084 8.223 7.532 12.61 20.142 17.201 9.69 6.977 15.55 32.217 14.706 22.216 36.922 19.45 18.35 $57.04 (34.74) $22.30 $88.24 $74.52 $48.00 $122.52 $28.39 $39.67 $68.06 $37.80 $44.32 $82.12 $28.20 $37.64 $28.19 $28.23 $29.80 $10.42 $70.20 $60.56 $141.18 $46.20 $52.74 $70.38 $39.91 $110.29 $30.34 $28.15 $29.99 $58.18 $38.51 $96.69 $46.56 $27.39 $30.69 $58.08 $33.58 $21.93 $19.10 $32.36 $51.46 $47.06 $25.84 $17.20 $39.59 $82.63 $36.12 $50.56 $86.68 $45.84 $28.74 $8,189.01

0111 - 2 0187 - 1 0167 - 1

5000 TRANS UNASSIGNED G59117 000998SG

209041

2/26/2011 2/24/2011 2/24/2011

1:00:00 PM SHELL 4:23:31 PM CONOCO 4:17:33 PM CONOCO

ESPANOLA SHELL OHKAY EXPRESS MART GIANT 6861

ESPANOLA ESPANOLA SANTA FE

DSLDIESEL SUPER UNLEADED UNLEADED

0187 - 1 0187 - 1

TRANS TRANS

G59117 G59117

2/18/2011 2/18/2011

1:48:49 PM CONOCO 9:15:13 PM PHILL 66

OHKAY EXPRESS MART ALLSUPS 346

ESPANOLA SANTA FE

SUPER UNLEADED SUPER UNLEADED

0187 - 1 0111 - 2

TRANS 5000

G59117 209041

2/17/2011 2/17/2011

3:03:51 PM CONOCO 6:44:00 PM DIAMOND

OHKAY EXPRESS MART CAMEL ROCK VALERO

ESPANOLA SANTA FE

SUPER UNLEADED UNLEADED

0187 - 1 0187 - 1 0187 - 1 0187 - 1 0187 - 1 0187 - 1 0187 - 1 0187 - 1

TRANS TRANS TRANS TRANS TRANS TRANS TRANS TRANS

G59117 G59117 G59117 G59117 G59117 G59117 G59117 G59117

2/14/2011 2/13/2011 2/11/2011 2/9/2011 2/7/2011 2/6/2011 2/6/2011 2/6/2011

3:24:57 PM CONOCO 10:21:56 AM PHILL 66 4:59:19 PM CONOCO 11:54:42 AM CONOCO 7:04:34 PM CONOCO 12:46:00 PM UNBRANDED 1:12:31 PM PHILL 66 3:23:04 PM UNBRANDED

OHKAY EXPRESS MART POJOAQUE KICKS OHKAY EXPRESS MART OHKAY EXPRESS MART OHKAY EXPRESS MART

ESPANOLA SANTA FE ESPANOLA ESPANOLA ESPANOLA

UNLEADED UNLEADED UNLEADED UNLEADED UNLEADED UNLEADED UNLEADED DSLDIESEL

SANTA CRUZ COUNTRY S SANTA CRUZ POJOAQUE KICKS SANTA FE RHOC EXPRESS ARROYO ESPANOLA

0187 - 1 0187 - 1 0187 - 1 0187 - 1

TRANS TRANS TRANS TRANS

G59117 G59117 G59117 G59117

2/5/2011 1/14/2011 1/12/2011 1/12/2011

8:10:58 PM CONOCO 1:04:09 PM CONOCO 11:55:25 AM PHILL 66 11:56:15 AM PHILL 66

QUIK STOP #12 QUIK STOP #11 QUIK STOP #5 QUIK STOP #5

ESPANOLA SANTA FE SANTA FE SANTA FE

SUPER UNLEADED UNLEADED UNLEADED UNLEADED

0187 - 1 0187 - 1 0187 - 1 0187 - 1 0187 - 1

TRANS TRANS TRANS TRANS TRANS

G59117 G59117 G59117 G59117 G59117

11/15/2010 11/14/2010 10/25/2010 10/22/2010 10/22/2010

7:56:23 AM PHILL 66 11:14:06 PM CONOCO 8:26:21 AM PHILL 66 3:49:31 PM PHILL 66 6:52:00 PM UNBRANDED

PUEBLO GAS 2 GIANT 6861 ALLSUPS 344

SANTO DOMINGO PUEB UNLEADED SANTA FE SANTA FE UNLEADED SUPER UNLEADED UNLEADED UNLEADED

ALLSUPS 336 SANTA FE SANTA CRUZ COUNTRY S SANTA CRUZ

0187 - 1 0187 - 1 0059 - 1

TRANS TRANS

G59117 G59117 5000 2FAFP71W31X159539

8/19/2010 8/6/2010 8/6/2010

11:23:06 AM UNBRANDED 1:04:25 PM PHILL 66 3:13:00 PM UNBRANDED

RHOC EXPRESS ARROYO

ESPANOLA

UNLEADED UNLEADED UNLEADED

CIRCLEK6298 ASM ALB ALBUQUERQUE SANTA CRUZ COUNTRY S SANTA CRUZ

0187 - 1 0059 - 1 0189 - 1 0189 - 1

TRANS

G59117 5000 2FAFP71W31X159539

8/5/2010 8/2/2010 7/28/2010 7/28/2010

8:15:28 AM PHILL 66 4:26:16 PM PHILL 66 4:28:00 PM DIAMOND 3:36:00 PM SHELL

TKJ INC D B A BURGER TKJ INC D B A BURGER CAMEL ROCK VALERO AIRPORT SHELL

SANTA FE SANTA FE SANTA FE SANTA FE

UNLEADED UN+EADED PLUS UNLEADED UNLEADED

TRANS TRANS

KC85019 KC85019

0059 - 1 0059 - 1 0059 - 1 0059 - 1

5000 2FAFP71W31X159539 5000 2FAFP71W31X159539 5000 2FAFP71W31X159539 5000 2FAFP71W31X159539

7/24/2010 7/22/2010 7/22/2010 7/22/2010

7:30:37 PM CONOCO 7:46:00 PM CHEVRON 9:33:46 PM CHEVRON 11:36:02 PM CHEVRON

QUIK STOP #12 CHEVRON 0302023 CHEVRON 0302023 CHEVRON 0309236

ESPANOLA ESPANOLA ESPANOLA SANTA FE

UN+EADED PLUS SUPER UNLEADED UNLEADED UNLEADED

0183 - 1 0126 - 1

SFMO 3400

G77609 221340

2/1/2010 2/1/2010

11:56:00 AM UNBRANDED 11:07:16 AM PHILL 66

M & M STORES INC SDTBE

ALBUQUERQUE UNLEADED SANTO DOMINGO PUEB UNLEADED

0138 - 2 0138 - 2

5000 G62117 5000 G62117

7/30/2009 1/21/2009

10:57:00 AM SHELL 11:07:00 AM SHELL

ALLSUP PETROLEUM INC SANTA FE ALLSUP PETROLEUM INC SANTA FE

UNLEADED UNLEADED

Total Questionable Gas Card Purchases 2,462.78

OSA – PRC Risk Assessment

29

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