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Hello all! Here are some of the documents I had the privilege of working on at Arum Group LLC. Take a look and let me know how you feel!!

Document # 1 : Xavier Becerra for Congress

July 31, 2012

Dear __________,

I cannot thank you enough for supporting my 2012 Congressional Reelection Campaign. Your contribution is a generous statement of support that I will not soon forget.

By contributing to my campaign you are helping not only to combat the issues that affect your community, but the issues that affect this nation as a whole. Your contribution will serve to aid my individual campaign as well as countless other Democratic candidates in this upcoming cycle. It is impossible to overstate my appreciation for your steadfast support. My success up to this point is simply a reflection of the hard working citizens who stand behind me. I am running for another term in order to demand a smarter and stronger United States, a nation that is deserving of the generations to come.

United we can build a country that our children’s children can one day be proud of. Thank you again for your support. Please let me know if I can be of any assistance to you or your community. You may contact me through my fundraiser, Madalene Meilke, at (202) 547-6656 or via email at madalene@arumgroup.com.

We look forward to working with you in the years to come. Your continued support is immensely appreciated.

Sincerely,

Rep. Xavier Becerra

Document # 2: DCCC – Convention Rules Memo 

Arum Group, LLC

625 Third Street, NE Suite 2  Washington, DC  20002

Phone: 202.547.6656  Fax: 202.547.8554

June 14, 2012

TO:                 Whom it may concern

FROM:           Benjamin J. Dauber – Summer Intern 2012

RE:                  Legal Issues @ Convention & A note on the STOCK Act

A majority of the legal guidelines regarding campaign finance, event attendance and funding, travel, and lobbyist participation remain the same during convention. However there are several changes that are in place that have heightened importance during convention as well as several alterations from the working rules implemented in 2008. These are the changes as discussed during the DNC briefing, 6/14/12 @ DCCC by Brian Svoboda of Perkins Coie.

For a comprehensive and official version of these changes and rules visit docs.demhouselaw.com

  1. Updated Legal Rules & Exceptions during Convention
  1. Campaign Finance, House Ethic, & Gift Rules all still apply
  2. Member participation in lobbyist sponsored events are restricted
  3. EXCEPTIONS:

i.         FEC rules allow use of campaign funds for travel and other expenses associated with convention

ii.         Gift rule is more lenient

iii.         House guidance clarifies limit on parties & events

  1. Campaign Finance Issues
  1. Travel – Campaign can pay for travel and lodging for:

i.         Candidate

ii.         Candidate’s spouse & children if participating in official events. (or if children are very young)

iii.         Campaign staff – on their own time (vacation, etc.) if engaged in political activities

iv.         Leadership PAC could pay for this as well if doing explicitly PAC related activities

  1. Soft Money

i.         Member & their team cannot raise or spend SM

ii.         Review member participation guidelines to be certain

  1. Events

i.         Campaign can host event (same basic rules as non-convention)

ii.         If the member participates in a non-campaign events that event cannot:

  1. Advocate or solicit funds for the Member
  2. Campaign cannot be involved with this event
  3. Gift Rules

i.         No Blanket Exception

ii.         Usual limits and restrictions apply

  1. No lobbyist gifts
  2. No gifts upward of $49.99
  3. This includes meals and other things of value

iii.         Cannot ear mark gifts through a permitted source or pivot point.

iv.         EXCEPTIONS:

  1. Any gift provided by state, local or federal government
  2. Meals, lodging, etc. provided by a political organization as part of a campaign fundraising event (applies to DCCC, host committee, convention committee, state party, etc. )
  3. Gifts offered to all delegates
  4. Attendance @ a reception  (hors d’oeuvres, etc.)
  5. Attendance @ a widely attended event
    1. Appropriate to member duties
    2. Wide range of people
    3. More than 25 non-congressional attendees
    4. Invite must come from sponsor (no shows or sports events)

** The nature of an event is determined by the intuitive nature of the House Ethics Committee. This means that if high-powered entertainment (E.g. recording artists, celebrities, etc.), or other non-political motives are deemed to be the focus, the event in question is unethical. **

  1. Events Honoring Members
  1. Gift rule issues still apply
  2. Members cannot participate in events that honor them

i.         If listed as “Honoree” or “Special Member” it is still considered event in their honor

ii.         Anything distinguishing them specifically is prohibited – Role? Exclusive speaker, large ceremonial role, etc. = not allowed

  1. If it is honor of a generic delegation or organization, even if it is a very small delegation it is allowed (e.g. House Delegation from Montana)

Common Sense Advice:

 

  1. I.               Confirm specifics of the event W/ Sponsor in writing
  2. II.             Insist on reviewing written materials
  3. III.           In unsure instances ask sponsor if they have received Ethics Committee approval

 

 

The STOCK Act

 

  • Imposes new requirements on members and senior staff (staff w/ salaries exceeding $119,500)
  • Insider Trading – applies to all members, even sharing of info in casual instance such as call time or other similar circumstances
    • Member can only participate in IPO’s of open to general public
    • Post Employment Negotiations – disclosure requirements extended to include senior staff.
    • Financial Disclosure Requirements expanded – disclose personal mortgages – PTR’s < $1,000, PFD’s must be available for review no later than 8/31/12

 

Again refer to demhouselaw.com for an official version of these changes

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Posted October 2, 2012 by dauberb

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