This page provides answers to frequently asked questions pertaining to authorized committees of candidates for federal office. If you don't find an answer to your question here, please contact the FEC's Information Division, toll free at 800-424-9530 or by e-mail at info@fec.gov. Committee staff may also speak with the Campaign Finance Analyst who reviews the committee's reports by calling the Reports Analysis Division, toll free at 800-424-9530 (press 5). Additionally, electronic filers may contact the Commission's Electronic Filing Office for technical assistance, toll free at 800-424-9530 (press 4).
I am a new candidate. When do I need to register and start filing?
What indicates that a candidate is campaigning and no longer "testing the waters"?
When do I submit my reports?
Where can I find the registration and reporting forms?
Where do I file reports?
Where can I find the latest contribution limits?
What is my election cycle?
Where, when and on what form should a joint fundraising committee that supports House, Senate and/or Presidential candidates file?
I am a candidate who already filed a Statement of Candidacy (FEC Form 2) for the next regularly scheduled election, but I am also participating in an off-election year Special Election. What do I need to do?
I am a candidate who has already filed the Statement of Candidacy (Form 2) and my Principal Campaign Committee (PCC) has filed a Statement of Organization (Form 1). Due to redistricting, I will be running in a different district. What do I need to do?
My committee files electronically and needs to amended its Statement of Organization (Form 1). Since the original Form 1 was filed on paper should the amendment also be filed on paper?
Are unopposed, independent, and third-party candidates entitled to a separate primary contribution limit? What are the pre-primary election reporting requirements for such candidates?
What date should I use for the "Date of Receipt" of a contribution on the report? When is a contribution considered made?
What is considered an earmarked contribution? How do we report contributions through conduits?
My committee is affiliated with a joint fundraising committee. How do we report transfers-in from that committee?
What is the limit for contributions from partnerships?
How do I report a contribution from a partnership?
What is “Best Efforts” and how do I establish “Best Efforts”?
How can a prohibited or excessive contribution that has been deposited into the campaign’s account be remedied?
What is presumptive redesignation or reattribution?
How do I report a redesignation or reattribution?
How do I report receipt of refunds of contributions made by the committee?
What constitutes an adequate or inadequate purpose for a disbursement? Is there a list to help me?
How do I report reimbursements made to the candidate and campaign staff when they advanced funds for travel and non-travel items?
How do I report credit card payments or reimbursements to individuals?
How do we report disbursements to a payroll company for employees' salary?
How do I report voided checks and un-cashed refunds? What should I do with these funds?
My committee is contributing to another federal candidate committee. What information is required?
How do I report out-of-pocket expenditures (in-kind contributions) from the candidate?
How do I report a loan from the candidate’s personal funds?
The candidate obtained a bank loan and/or loan of money from an advance on a brokerage account, credit card, home equity line of credit or other line of credit and loaned that money to the campaign. How do I report it?
When should I disclose a debt owed by the committee? What if I do not know the exact amount of a debt?
Can I discontinue reporting unpayable debts?
What are 48-Hour Notices and when do I need to file them?
How do I report a 48-Hour Notice for a partnership contribution?
The committee missed the 48 hour requirement for filing 48-Hour Notices. Should I file the notices late?
Can my committee purchase bitcoins as an investment?
How do I report bitcoins purchased as an investment?
Can I use bitcoins that the campaign buys as an investment to purchase goods or services?
Can my committee receive bitcoins as contributions?
How do I determine the value of the bitcoins that I receive as a contribution?
How do I report receiving contributions in bitcoins?
How do I report liquidating bitcoins?
What are the additional disclosure requirements for “bundled” contributions earmarked through a conduit?
What are “covered” periods for Form 3L?
What information is disclosed on Form 3L?
How do I establish a recount fund and report recount donations?
How do I report recount disbursements?
Now that the election is over, are there any special rules on repaying personal loans from the candidate?
Can I collect contributions even though the election is over to help retire our campaign debts?
The committee accepted contributions for the general election, but the candidate lost in the primary election. What should I do with the general election contributions?
How does the candidate forgive a personal loan?
I want to terminate my committee. How do I end my filing requirement?
A person triggers registration and reporting responsibilities when campaign activity exceeds $5,000 in either contributions or expenditures. (Money raised and spent to test the waters, or explore the feasibility of becoming a candidate, does not count toward this threshold until a person decides to run for federal office or conducts activities indicating he/she is actively campaigning rather than testing the waters.) (11 CFR § 100.3(a)(3) and 102.13(a)(2)).
Within 15 days after an individual becomes a candidate as described, he/she must designate a principal campaign committee on the Statement of Candidacy (FEC Form 2) (11 CFR § 101.1(a) and 102.12(a)). Commission Regulations require that the name of the principal campaign committee include the name of the candidate who authorized the committee. (11 CFR § 102.14(a)) Within 10 days after it has been designated by the candidate, the principal campaign committee must file the Statement of Organization (FEC Form 1) (11 CFR § 102.1(a)).
Authorized committees of candidates must file quarterly disclosure reports on FEC Form 3 (for House of Representatives and Senate candidates) or Form 3P (for Presidential candidates). The first report filed by the committee should include any receipts and disbursements made during the “testing the waters” (or exploratory) period. The coverage period of the first report should be adjusted to date back to the beginning of the committee’s financial activity.
What indicates that a candidate is campaigning and no longer “testing the waters”?
The following activities are examples of “testing the waters,” or exploring the feasibility of running for office: polling, making phone calls, traveling around the district, and raising money to pay for this activity under the federal contribution limits. Individuals conducting solely “testing the waters” activity are not required to register and report, even if they raise/spend more than $5,000 (11 CFR §100.72(a) and 100.131(a)).
Taking action to qualify for the ballot (11 CFR §100.72(b) and 100.131(b)).
Once an individual becomes a candidate, funds raised or spent to test the waters apply to the $5,000 threshold. All money raised and spent in the exploratory period has to be reported on the first FEC report (beginning coverage date of the report should be the date of first financial activity).
After registration, candidate campaign committees must file reports on Form 3 (for House of Representatives and Senate candidates) or Form 3P (for Presidential candidates) to disclose all of their activity. The reporting schedule can be found on the FEC web site. Committees of House of Representatives and Senate candidates file on a quarterly schedule.
Committees of Presidential candidates must file monthly during the election year if they have received or anticipate receiving contirbutions or making expenditures aggregating $100,000 or more (11 CFR §104.5(a) and (b)). During the non-election year, committees of Presidential candidates may file on either a quarterly or monthly schedule, and may change their filing frequency once per calendar year by filing a request with the Commission. For more information please consult the RAD Processes page.
All authorized committees must continue filing until terminated, even if the candidate decides to retire, withdraws from the race prior to the primary election, loses the primary, or drops out of the race prior to the general election. Committees seeking to terminate their reporting obligation must file a termination report or a termination request, and must continue to file reports until the Commission notifies them in writing that their termination report or request has been accepted.
In addition to quarterly reports, a committee may be required to pre- and post-election reports and 48-Hour Notices in an election year.
Registration and reporting forms are available on the FEC website, via our automated Fax Line (call 800-424-9530 ext. 1100) and by mail (call 800-424-9530 ext. 1100). Electronic filers may download free FEC File software from our electronic filing web page.
Committees must file electronically if the campaign raises or spends more than $50,000 in any calendar year, or has reason to expect to do so (11 CFR §104.18(a)). The electronic filing requirement does not apply to Senate committees or Joint Fundraising committees supporting only Senate candidates that are required to file with the Secretary of the Senate.
For more information, please consult Campaign Guide for Congressional Candidates and Committees, pages 83-85 [PDF] and our electronic filing web page.
Committees supporting House of Representatives and Presidential candidates must file reports with the FEC via mail at 1050 First Street NE, Washington, DC 20463 or file electronically. Committees supporting Senate candidates must file reports on paper with the Secretary of the Senate, Office of Public Records, 232 Hart Senate Office Building, Washington, DC 20510-7116. Mail addressed to the Secretary of the Senate should be sent to: Office of Public Records, P.O. Box 77578, Washington, DC 20013-7578.
Click on the following link to view the contribution limits for the 2017-2018 election cycle.
Candidate committees must aggregate their activity on an election cycle basis. The election cycle starts on the day after the last general election for the office sought by the candidate and ends on the next general election date for the office sought. Thus, the length of the election cycle varies depending on office sought (i.e., two years for House committees, six years for Senate committees, and four years for Presidential committees) (11 CFR §100.3(b)).
For instance, a 2018 House committee would use the election cycle dates of 11/9/2016 - 11/6/2018. A Senate committee supporting a candidate for re-election in 2018 would use the election cycle dates of 11/7/2012 - 11/6/2018. If your committee was involved or is currently involved in a special election, please note that the date after the special election (or the special runoff election) begins a new election cycle. If you have any questions about your election cycle, please contact your RAD Analyst.
Where, when, and on what form should a joint fundraising committee that supports House, Senate and/or Presidential candidates file?
Joint fundraising committees (JFCs) that only support federal candidates are considered authorized committees , and must file on Form 3 (11 CFR 102.13(c)). These JFCs must follow the filing schedule for authorized committees. JFCs that support both federal candidates and other party or non-party political committees (such as PACs) must file on Form 3X and follow the filing schedule for unauthorized committees (11 CFR §104.5(a) and (c)). JFCs supporting only Senate candidates must file with the Secretary of the Senate. All other JFCs must file with the FEC.
For more information, please consult this Instructional Video on the rules governing joint fundraisers.
Candidates running in off-election year special elections who have received contributions or made expenditures over $5,000 for the special election should file a Statement of Candidacy (FEC Form 2) indicating the year of the special election and designating a principal campaign committee to raise and spend funds for the special election.
If the candidate is also running in regularly scheduled elections and has received contributions or made expenditures over $5,000 for those elections, an additional Statement of Candidacy (FEC Form 2) should be filed to indicate the year of the regularly scheduled election. The candidate can designate the same principal campaign committee or designate a new committee to raise and spend funds for the regularly scheduled elections.
Candidates and PCCs running in regularly scheduled elections in states that have gone through a redistricting process should submit an Amended Statement of Organization AND Statement of Candidacy (Forms 1 and 2) to reflect the new district.
If a committee is an electronic filer, it is required to file all subsequent reports and documents electronically. This includes amendments to the Statement of Organization (Form 1). Note that some electronic filing software may show the first electronically filed Form 1 as "new" rather than "amended." However, if a Form 1 was previously filed, the Statement of Organization will be identified by the FEC as an amendment upon upload.
Unopposed and independent candidates are still entitled to a separate contribution limit for the primary (or convention, if in a state that is holding one to nominate candidates for the general). Unopposed candidates must consider the date on which the election is held to be the date of the election for purposes of designating contributions to the primary. Independent or third party candidates may choose one of these dates to be their "primary” date: (1) The last day on which, under state law, a candidate may qualify for a position on the general election ballot; (2) The date of the last major party primary, caucus or convention in the state; or (3) For third party candidates, the date of the nomination by their party. In terms of reporting, both unopposed and independent/third party candidates, must file the pre-election report applicable to their state and any 48-hour notices for contributions of $1,000 or more, even if they are not actually participating in a primary election or nominating convention.
The “Date of Receipt” field on Schedule A should show the date the candidate, campaign committee, or an agent acting on their behalf actually received the contribution. This is the date used by the campaign for reporting purposes. The date a contribution is made is when the contributor relinquished control over the contribution by either delivering or mailing it to the candidate, committee, or their agent. For mailed contributions, the date of the postmark is considered to be the date when the contributor relinquished control of the contribution (11 CFR §110.1(b)(6)).
If the campaign wishes to use the postmark as evidence of the date a contribution was made, then the envelope or a copy of the postmark must be retained. Campaigns can use the postmark as evidence that a contribution that was received after the date of the election was actually made by the contributor on or before the date of the election. In such cases, campaigns should note the postmark date for the contribution on Schedule A of the FEC report. Campaigns should pay particular attention to postmarks near election day, as the date is used for reporting purposes as well as the calculation of net debts, if applicable (see the section on collecting contributions to retire campaign debts below).
An earmarked contribution is one which the contributor directs (either orally or in writing) to a clearly identified candidate through an intermediary or conduit. An intermediary/conduit could be an individual or a political committee (11 CFR §110.6(b)).
Earmarked contributions are reported as receipts from the original contributor. When a committee receives an earmarked contribution(s) through an allowable conduit, each individual contribution must be itemized when the individual's total contributions to your committee aggregate over $200 per election cycle. This itemization must include the full name, address, occupation, and employer of the individual contributor along with the date the contribution(s) was received by the conduit. Any unitemized contributions received through the conduit must be included in your totals on Line 11(a)(ii) of Form 3 or Line 17(a)(ii) of Form 3P.
In addition, information regarding the conduit or intermediary for each contribution must be itemized on Schedule A as a memo entry whenever the total earmarked through a conduit exceeds $200 election cycle-to-date. The conduit's full name and address (and occupation and employer if the conduit is an individual) must also be provided, along with the date the contribution(s) was received by your committee and the total amount of earmarked contributions received from the conduit (11 CFR §110.6(c)).
Furthermore, certain “bundled” contributions may trigger additional disclosure of the identity of the person who raised the bundled contribution on FEC Form 3L, as summarized in the section on “Reporting Requirement for ‘Bundled’ Contributions” below.
First, make sure the joint fundraising committee (JFC) is properly disclosed on your most recent FEC Form 1 and 2 (Statement of Organization and Statement of Candidacy). Report the net proceeds received from the JFC as a transfer-in on Schedule A supporting Line 12 of Form 3 or Line 18 of Form 3P. Additionally, you must provide a memo Schedule A to itemize your committee’s share of the gross contributions received through the JFC. The memo schedule should itemize each individual who has contributed an aggregate in excess of $200 during the election cycle to your committee and provide the amount of unitemized contributions received. The memo schedule should also itemize your committee's share of all contributions from political committees, regardless of amount (11 CFR §102.17(c)).
A candidate’s authorized committee may not accept contributions from a partnership in excess of $2,700 per election. In addition, a partnership contribution counts proportionately against each participating partner’s own limit with respect to the candidate. Contributions made by individual partners from their own funds, rather than the partnership funds, do not count against the partnership’s limit. 11 CFR 110.1(b)(1) and (e). Contributions from professional corporations and from partnerships using the funds of corporate, foreign national, or federal contractor members are prohibited. 11 CFR 110.1(e), 110.20, 114.2, and 115.4.
If a contribution from a partnership exceeds or aggregates over $200 during an election cycle, the committee must itemize the contribution on a Schedule A supporting Line 11(a)(i) of Form 3 or Line 17(a)(i) of Form 3P. Additionally, if an individual partner’s share of the contribution exceeds or aggregates over $200 in the same election cycle, the committee must disclose, as a memo entry, itemized information on the partner (name, address, occupation, name of employer, amount of contribution, and aggregate total). If no partner’s individual attribution exceeds $200 in the election cycle, you should note that using memo text or an additional description field (11 CFR §104.8 and 110.1(e)).
“Best efforts” is the demonstration that your committee has actively tried to acquire and report information concerning your contributors’ names, addresses, and employer/occupation information.
Your original solicitation must include a clear and conspicuous request for the contributor information and must inform the contributor of the requirements of federal law for the reporting of such information.
If the request is written, include a pre-addressed post card or return envelope.
On your next report, file a separate Schedule A listing the contributors with the additional information as memo entries. Clearly denote "Best Efforts" in the additional text field.
File an amendment to the original report disclosing the information.
A prohibited contribution must be refunded within 30 days of receipt (11 CFR §103.3(b)(1) and (2)).
An excessive contribution can be refunded, redesignated or reattributed within 60 days of receipt (11 CFR §103.3(b)(3)), 11 CFR §110.1(b) and (k), and 11 CFR §110.2(b)). With a redesignation, the contributor instructs the committee to use the excessive portion of a contribution for an election other than the one for which the funds were originally given. With a reattribution, the contributor instructs the committee to attribute an excessive portion of a joint contribution to another individual. See the next two sections for more information on redesignations and reattributions.
Presumptive redesignation and presumptive reattribution allow the committee to designate a contribution to a different election or attribute a contribution to another account holder without first seeking a signature from the original contributor. Committees can use presumptive redesignation and reattribution in the following circumstances.
As redesignated, does not cause the contributor to exceed any other contribution limit (11 CFR §110.1(b)(5)(ii)(B)(1)-(4)).
The committee is required to notify the contributor in writing of the presumptive redesignation within 60 days of the treasurer’s receipt of the contribution, and must offer the contributor the option to receive a refund instead (11 CFR §110.1(b)(5)(ii)(C)). The committee should retain full-size photocopies of the check or written instrument, of any signed writings that accompanied the contribution, and of the notices sent to the contributors.
Please note: presumptive redesignation can only be made within the same election cycle. Also, presumptive redesignation is not an option when the contributor is a multicandidate committee.
If a committee receives an excessive contribution made via a written instrument that has more than one individual’s name imprinted on it but only one signature, the committee may attribute the permissible portion to the signer. The committee may make a presumptive reattribution of the excessive portion to the other individual whose name is imprinted on the written instrument, without obtaining a second signature, as long as the presumptive reattribution does not cause the contributor to exceed any other contribution limit.
The committee is required to notify the contributors in writing of the presumptive reattribution within 60 days of the treasurer’s receipt of the contribution, and must offer the contributor the option to receive a refund if it was not intended to be a joint contribution (11 CFR §110.1(k)(3)(ii)(B)(2)-(3)). The committee should retain full-size photocopies of the check or written instrument, of any signed writings that accompanied the contribution, and of the notices sent to the contributors.
If the original contribution and redesignation/reattribution occurred in the same reporting period, report the contribution as it was originally received. Then, use memo entries to report the information as it has been redesignated and/or reattributed including the date the redesignation and/or reattribution was made.
If the original contribution and redesignation/reattribution occurred in different reporting periods, use a memo entry to report the information as it was originally reported. Then, use additional memo entries to disclose the information as it has been redesignated and/or reattributed including the date the redesignation and/or reattribution was made.
Refunds received by a committee for contributions it made to other political committees or candidates should be reported on Line 15 of Form 3 or Line 21 of Form 3P and itemized on a supporting Schedule A if they aggregate over $200 in an election cycle.
When itemizing disbursements on Schedule B, the itemization should include a brief but specific description of why the disbursement was made. The intent is that any member of the public can look at the purpose and easily understand the meaning. For that reason, vague terms like “consulting,” “professional services” and “materials” are not sufficient.
A non-exhaustive list of purposes that the Commission deems inadequate can be found here. See also the Federal Register Notice: Commission's Statement of Policy on Purpose of Disbursement. A non-exhaustive list of acceptable purposes can be found here.
The correct format for reporting these transactions depends on various factors. There are different rules for travel advances/reimbursements and non-travel advances/ reimbursements. Other factors include the timing of the advance and reimbursement, the amount of the advance, and any prior contributions made by the candidate and applicable campaign staff.
For travel advances, individuals (including the candidate, a paid staff member or a volunteer) can voluntarily spend up to $1,000 for their own unreimbursed transportation expenses on behalf of the campaign without making a contribution. Payments for travel expenses exceeding $1,000 (per candidate, per election) are considered in-kind contributions unless they are reimbursed within the following time periods: (1) if the individual paid with cash or a personal check, within 30 days from the date the expense was incurred; or (2) if the individual paid with a credit card, within 60 days of the closing date on the credit card billing statement (11 CFR §116.5(b), FEC Advisory Opinion 1992-01).
Non-travel advances are considered in-kind contributions until they are repaid by the committee (FEC Advisory Opinion 1992-01).
If there are multiple credit card payments on a report, you should clearly identify to which payment each memo entry relates.
If there are multiple reimbursements on a report, you should clearly identify to which reimbursement each memo entry relates.
How do we report disbursements to a payroll company for employees’ salary?
To report a voided payment to a vendor (reported in a prior period on Line 17 of Form 3 or Line 23 of Form 3P), itemize a negative payment to the same vendor on Schedule B of the report covering the period when you voided the check. Include all relevant information (date voided, amount, address, city, state, zip code), and enter "voided check" in the purpose field. Using memo text or an additional text field, indicate the date of the original disbursement and clarify if the check was reissued.
To report an un-cashed refund (reported in a prior period on Line 20(a), (b) or (c)) of Form 3 or Line 28(a), (b), or (c) of Form 3P), report a negative transaction on the same line on which the original refund was reported. In the purpose field, enter “un-cashed refund.” Using memo text or an additional text field, indicate the date of the original disbursement and clarify if the check was reissued.
The disgorgement to the Treasury should be itemized on Schedule B supporting Line 21 of Form 3 or Line 29 of Form 3P with a purpose which explains why the funds are being disgorged. Use memo text or an additional text field, if necessary. In addition, you must itemize as a memo entry the original transactions making up the disgorgement.
Contributions to other federal candidate committees should be reported on Schedule B supporting Line 21 of Form 3 or Line 29 of Form 3P. In addition to the regular itemization information (recipient committee’s full name, complete address, date, amount and purpose), you must also include the recipient candidate’s name, the election designation, and the office sought (House, Senate or President) including the state and Congressional district, if applicable (11 CFR §104.3(b)(3)(v)).
If a candidate uses his/her personal funds to make expenditures on behalf of the committee without intending to be reimbursed, this constitutes an in-kind contribution from the candidate to the committee. In addition to reporting it on Schedule A if it exceeds the $200 itemization threshold for the election cycle, the committee must also itemize it on Schedule B for Operating Expenditures. In addition, out-of-pocket spending by candidates, as agents of their authorized committees, requires memo entry itemization of the ultimate vendor if the aggregate amount of payments to that vendor exceeds $200 for the election cycle. The memo entry must include the date, amount, and purpose of the out-of-pocket payments, as well as the name and address of the vendor to which payment was made.
Report the initial receipt of the loan from the candidate on Schedule A supporting Line 13(a) of Form 3 or Line 19(a) of Form 3P, regardless of the amount of the loan 11 CFR §104.3(a)(4)(iv)). The loan must also be reported continuously on Schedule C until it is repaid in full. Make sure to include all loan terms on Schedule C. If there is no due date or interest rate, you can enter “none” or “n/a,” but you cannot leave these fields blank. Be sure to include the term “personal funds” on either Schedule A or C. Any loan payments must be reported on Schedule B supporting Line 19(a) of Form 3 or Line 27 of Form 3P and on Schedule C (11 CFR §104.3(b)(4)(iii)). Any interest payments must be reported as an operating expenditure and require itemization on a Schedule B supporting Line 17 of Form 3 or Line 23 of Form 3P once payments to the candidate exceed $200 in the election cycle.
For more information, please consult Campaign Guide for Congressional Candidates and Committees, pages 28-30, 91, 108 [PDF] as well as FEC Form 3 Instructions and FEC Form 3P Instructions.
Report the receipt of the loan on Schedule A supporting Line 13(a) of Form 3 or Line 19(a) of Form 3P, regardless of the amount. List the candidate as the loan source and note what kind of loan it is. The loan must also be reported continuously on Schedule C until it is repaid in full. Only the candidate needs to be listed as the source of the loan on Schedule C. The type of loan the candidate receives must also be disclosed in either the first box for endorsers and guarantors with a notation for loan type or in the box for “Loan Source” after the candidate’s name. Schedule C should disclose the loan terms between the candidate and the committee. Make sure to include all loan terms on Schedule C. If there is no due date or interest rate, you can enter “none” or “n/a,” but you cannot leave these fields blank.
The committee must also file a Schedule C-1 to disclose the terms between the candidate and the bank. For electronic filers, the Schedule C-1 can be filed electronically. For this type of loan, neither the treasurer’s signature nor lender certification is required. A copy of the loan agreement is not necessary.
The committee can either repay the candidate or the bank for this type of loan. The repayments must be itemized on Schedule B supporting Line 19(a) of Form 3 or Line 27(a) of Form 3P for a candidate repayment, or Line 19(b) of Form 3 or Line 27(b) of Form 3P for a bank repayment. When repayments are made to the candidate, the committee is not required to report the repayments made by the candidate to the lending institution (11 CFR §104.3(a)(3)(vii)(B) and (b)(2)(iii)(A)).
Any interest payments must be reported as an operating expenditure and require itemization on a Schedule B supporting Line 17 of Form 3 or Line 23 of Form 3P once payments to the candidate exceed $200 in the election cycle.
For more information, please consult Campaign Guide for Congressional Candidates and Committees, pages 28-30, 91, 108-112 [PDF] as well as FEC Form 3 Instructions and FEC Form 3P Instructions.
A debt of $500 or less is reportable once it has been outstanding 60 days from the date incurred (the date of the transaction, not the date the bill is received). The debt must be disclosed on the next regularly scheduled report. A debt exceeding $500 must be disclosed in the report covering the date on which the debt was incurred. Debts must be reported on Schedule D until they are repaid in full (11 CFR §104.3(d) and 104.11). If the exact amount of a debt is not known, the committee may report an estimated amount, provided they note that the figure is an estimate. The committee must either amend the report (and all subsequent reports) to indicate the correct amount, once a correct figure is known, or include the correct figure, along with an explanation of the change, in the report for the reporting period during which the amount is determined.
A committee with unpayable debts (e.g., debts owed to defunct entities) that wants to discontinue reporting them should call their campaign finance analyst in the Reports Analysis Division (RAD) for assistance. RAD typically advises committees to file a statement on Form 99 (Miscellaneous Text Statement) that includes a request to discontinue reporting the debt and an explanation of why the debt is unpayable and what efforts the committee has made to contact the vendor, including the timeline and any supporting details. Terminating committees filing a Debt Settlement Plan (FEC Form 8) should include the debt on the Form 8 and explain the circumstances in the appropriate section(s). Committees are advised to continue reporting the debt until they have verified with RAD that a debt may be taken off future reports.
48-Hour Notices are reports of "last minute" contributions and/or loans of $1,000 or more received less than 20 days but more than 48 hours before the day of any election in which the candidate is running. The 48-Hour Notice must be filed within 48 hours of the campaign's receipt of the contribution/loan.
House and Presidential committees file these notices with the FEC. Committees that file electronically must file 48-Hour Notices in an electronic format. A paper-filing committee may also file online using the FEC’s web-based forms. Paper-filing committees that choose to file using the paper version of FEC Form 6 must fax the notice to the FEC at 202-219-0174.
Senate committees must file these notices with the Secretary of the Senate using a paper version of the FEC Form 6 or may use their own stationery for the notice, provided that it contains the candidate’s name and the office sought, the identification of the contributor, and the amount and date of receipt of the contribution. Senate committees must fax the notice to the Senate at 202-224-1851. Committees should keep fax receipts of all transmissions.
In addition to filing the 48-Hour Notices, committees must itemize all last-minute contributions in their next scheduled report (11 CFR §104.5(f)).
For more information, please consult Campaign Guide for Congressional Candidates and Committees, pages 81-82 [PDF] as well as the Form 6 and Form 6 Instructions.
If a partnership gives a contribution of $1,000 or more to your committee during the 48-Hour Notice period, the committee should file a notice for the partnership. There is no need to report the individual attribution on the 48-Hour Notice.
48-Hour Notices must be filed within 48 hours of a contribution’s receipt. Should you miss this deadline, RAD still recommends that you file the notice, provided it is before the date of the applicable election.
Yes. In Advisory Opinion 2014-02, the Commission concluded that a committee can purchase bitcoins with funds from its campaign depository for investment purposes. The bitcoins do not need to be deposited in a campaign depository within 10 days of receipt. Bitcoins may be received into and held in a bitcoin wallet until the committee liquidates them.
When the committee sells any bitcoins purchased from funds transferred from a campaign depository, the committee must report any earnings or losses as an "other receipt" (Line 15 for Form 3 filers; Line 21 for Form 3P filers; Line 17 for Form 3X filers). Losses should be reported as a negative entry.
No, committees cannot use bitcoins to purchase goods or services. The committee must sell the bitcoins and deposit the proceeds into the campaign depository before using the funds to make disbursements for goods and services.
Yes, a committee can receive bitcoins as contributions. The Act defines a “contribution” to include “any gift, subscription, loan, advance, or deposit of money or anything of value made by any person for the purpose of influencing any election for Federal office.” In Advisory Opinion 2014-02, the Commission concluded that bitcoins are "money or anything of value" within the meaning of the Act.
The initial receipt of bitcoins as contributions should be reported like in-kind contributions. The committee will disclose the receipt of the contribution and also report the bitcoins as a disbursement. These offsetting entries allow the committee's reported cash-on-hand to remain unchanged while holding the bitcoins outside of a campaign depository. It is recommended to include the number of bitcoins that the committee received and that the bitcoins were not liquidated. Please see Advisory Opinion 2014-02, Attachment 1 for an example of how to report receiving bitcoins as contributions.
Reporting for liquidating bitcoins depends on whether the committee sells to a known purchaser or to an unknown purchaser.
If the committee sells the bitcoins directly to a purchaser, and therefore knows the identity of the purchaser, the purchaser is considered to have made a contribution to the committee. The committee will report the purchaser's name, address, and employer/occupation information as well as the date of the purchase, the value of the bitcoins purchased, and the number of bitcoins purchased as a receipt on the committee's report. The committee will also report a memo entry disclosing the original contributor's information, date of contribution, original value of the bitcoins, and the number of bitcoins originally given to the committee. Please see Advisory Opinion 2014-02, Attachment 2(a) for an example of how to report selling bitcoins to a known purchaser.
If the committee sells the bitcoins through an established market mechanism where the purchaser is not known, the purchaser is not considered to have made a contribution to the committee. The committee will report the market or exchange's name, and address information, as well as the date of the purchase and the value of the bitcoins purchased. The committee should also include a notation stating how many bitcoins were purchased and that the purchaser is unknown. The committee will also report a memo entry disclosing the original contributor's information, date of contribution, original value of the bitcoins, and the number of bitcoins originally given to the committee. Please see Advisory Opinion 2014-02, Attachment 2(b) for an example of how to report selling bitcoins to a unknown purchaser.
A committee must file Form 3L to disclose information about each Lobbyist/Registrant or Lobbyist/Registrant PAC that forwards, or is credited with raising, two or more bundled contributions aggregating in excess of $17,900 (indexed for inflation) during a specific “covered” period (11 CFR §104.22(b)(1)). Bundled contributions include contributions collected and forwarded by a Lobbyist/Registrant or Lobbyist/Registrant PAC either physically or electronically, as well as contributions for which the Lobbyist/Registrant or Lobbyist/Registrant PAC receives credit from the recipient authorized committee. Form 3L is only required if $17,900 threshold is met in a given covered period. Committees should file 3L on the same filing schedule as its current Form 3 or 3P schedule (quarterly or monthly).
For more information, please consult Campaign Guide for Congressional Candidates and Committees, Appendix F [PDF] as well as the Form 3L and FEC Form 3L Instructions.
For more information, please consult Campaign Guide for Congressional Candidates and Committees, Appendix F [PDF] and the FEC Form 3L Instructions.
Schedule A: Is used to disclose reportable contributions bundles by lobbyist/registrants and lobbyist/registrant PACs.
Schedule B: Is only used to disclose bundled contributions that are deposited, reported, and later refunded.
For more information, please consult Campaign Guide for Congressional Candidates and Committees, Appendix F [PDF] of the and the FEC Form 3L Instructions.
A campaign must include amounts received for a recount in its total for "Other Receipts," recorded on Line 15 of Form 3 or Line 21 of Form 3P. The committee must itemize the donation on Schedule A for Line 15 of Form 3 or Line 21 of Form 3P if the aggregate receipts from that donor exceed $200 for the election cycle.
A campaign must include amounts spent on a recount in its total for "Other Disbursements," recorded on Line 21 of Form 3 or Line 29 of Form 3P. The committee must itemize the disbursements on Schedule B for Line 21 of Form 3 or Line 29 of Form 3P if payments to the same payee aggregate more than $200 for the election cycle.
The committee may use contributions to repay the candidate only up to $250,000 from contributions made after the date of the election.
If the committee uses the amount of cash-on-hand as of the date of the election to repay the candidate for loans in excess of $250,000, then it must do so within 20 days of the election. During that time, the committee must treat the portion of candidate loans that exceed $250,000, minus the amount of cash-on-hand as of the day after the election as a contribution by the candidate (11 CFR §116.11(c), FEC Advisory Opinion 2003-30).
If the committee has net debts outstanding for an election, the committee may be able to continue raising money to retire that debt (11 CFR §110.1(b)(3)). A campaign’s net debts outstanding consist of unpaid debts incurred with respect to the particular election minus the cash on hand plus the total amounts owed to the campaign in the form of credits, refunds of deposits, returns and receivables or a commercially reasonable estimate of the collectible amount, and personal loans from the candidate exceeding $250,000. For the purpose of calculating net debts outstanding for a primary election, cash on hand need not include contributions designated for the general election.
A campaign first calculates its net debts outstanding as of the day of the election. Thereafter, the campaign continually recalculates its total net debts outstanding as additional funds are received for, or spent on, the election for which the debt remains.
If the committee is accepting contributions for debt retirement, make sure to disclose the contribution as "debt retirement" on the report and include the applicable election. Please be advised that debt retirement contributions are subject to the contribution limits for that particular election (i.e. if a contributor already gave $2,600 for the 2014 General Election, they cannot contribute towards 2014 General Debt Retirement). The contribution limit does not change over time (i.e. the 2015-2016 limit for individuals is $2,700, but if you are accepting funds to pay debts for the 2014 cycle, the contribution limit for an individual for the 2014 Primary or General Debt Retirement is $2,600).
A candidate is entitled to an election limit only if he or she seeks office in that election. Thus, a candidate who loses the primary (or otherwise does not participate in the general election) does not have a separate limit for the general. If a candidate accepts contributions for the general election before the primary is held and loses the primary (or does not otherwise participate in the general election), the candidate’s principal campaign committee must refund, redesignate or reattribute the general election contributions within 60 days of the primary or the date that the candidate publicly withdraws from the primary race (11 CFR §110.1(b)(3) and 110.2(b)(5)).
If the candidate is forgiving a loan, the candidate must write a letter, preferably on campaign letterhead, addressed to the FEC stating that he/she forgives the loan (Senate committees must send this letter to the Secretary of the Senate). The candidate’s original signature must be on this letter. If you file electronically, contact your software provider for help in disclosing loan forgiveness on the report. If you are a paper filer, reduce the loan amount manually on the report.
Neither the committee seeking to terminate nor any other authorized committee of the same candidate has any outstanding debts or obligations (11 CFR §102.3 and 116.1).
The termination report must also disclose the purposes for which any remaining funds or assets will be used.
Please note that a committee involved in an FEC enforcement action, an FEC audit or litigation with the FEC must continue to file regularly scheduled reports until the matter is resolved.
After the Commission reviews your termination report, a letter will be sent to the treasurer informing him/her of the committee’s status. Do not assume your filing requirement is over until you receive a letter from the Commission stating that the committee has been terminated. Until you receive such a letter, the Committee must continue to file reports.


text:
Human Rights Def. Ctr. v. Bd. of Cty.
Rights Is Not “Toothless,” 17 N. Ky.
Scrutiny, 84 GEO. WASH. L. REV.
John M. Sands, Book Review, FED.
contribution toward the preparation or submission of this brief.
consent on October 5, 2018.
to receive that mail. Thornburgh v. Abbott, 490 U.S.
401, 408 (1989); see Kleindienst v. Mandel, 408 U.S.
them of unconstitutional prison practices.” Pet. App.
persons and/or their loved ones.
considerations discussed in decisions of this Court.
Eleventh Circuit decision is allowed to stand.
their constitutional and other legal rights.
themselves to this kind of speculative assessment.
prisoners of their rights.” Pet. App. 65.
perceived by a cautious warden, it is virtually meaningless.
escape from it.” (emphasis omitted) (citations omitted)).
facts that will support liability. Id. at 555, 557, 561.
those officials find objectionable. See Alphonse A.
First Amendment Rights Is Not “Toothless,” 17 N.
with the requirements of Twombly and its progeny.
constitutional right of access to the courts.” 430 U.S.
effective, and meaningful.” Bounds, 430 U.S. at 822.
less vital for a pro se prisoner.
derivative actions” or “slip-and-fall claims.” See Lewis, 518 U.S.
incarcerated persons. E.g., Human Rights Def. Ctr.
incarcerated individuals”); Prison Legal News v.
right, provides substantial reason to grant review.
the Hard Way: Caged, L.A.
involvement in the world outside the prison gates.
persons in prison. E.g., Human Rights Def. Ctr. v.
Alicia Bianco, supra, 21 ROGER WILLIAMS U. L. REV.
awareness and inform prisoners of their rights.”).
the corrections system,” Pell v. Procunier, 417 U.S.
21 ROGER WILLIAMS U. L. REV. at 13-14.
warranting review by the Court.
asserted for the regulation. 548 U.S. 521, 533 (2006).
following the reasonable-relationship standard, Pet.
security. That ban began in September 2009. Pet.
suggesting they were not at issue in that case. Pet. App. 34.
murder following his release. Id.
contribute to. Pet. App. 39.
FDOC has failed the reasonable-relationship test.
arbitrary or irrational”); Prison Legal News v.
Amendment law in the prison context.
top priority throughout its almost 50-year history.
consultative status by the United Nations.
the system’s exploitation of vulnerable communities.
restricted for those lacking financial resources.
and other especially vulnerable persons.
for thousands of incarcerated people.
Columbia University School of Law operate.
technical assistance to advocates across the country.
Pennsylvania Dep’t of Corrections v. Yeskey, 524 U.S.
priorities, and prospects for rehabilitation.
litigation, policy advocacy, and public education.
regarding censorship of Prison Legal News.
similar issues in federal and state prisons.
makers to advance positive criminal justice reform.
and working to create community driven solutions.

matches: v. v. v. v. v. v. v. v.


text:
This weekend kicks off the Civil War reenactment season for most of California, at Mooney Grove Park in Visalia. It is hosted by the oldest reenactment organization in California, the CWRS – Civil War Reenactment Society. CWRS started the Kearney Park event in Fresno. The living history and soldiers camps open to the public at 9 AM both days. There are two battles each day, usually at 11:00 AM and 3:00 PM. See you there.
Many of these have been blogged about before by many of you or others, so many of you blog analysts of the past ten or fifteen years may say, “that has all been done before.” But here goes. The series of modes being a part of this are: genre v. main stream, Create Space v. Lightening Source, Amazon v. Ingram’s, Big Houses v. Small houses, Social sites v. media interviews, Self publishing v. publisher.
Ignored for the moment are such things “cover” and “title.” Not because they are not important, they are, but because they are more of a subjective thing and not easily measured or quantified. Also set aside for the moment is ebook v. print book.
Is ebook v. print book fair? Or valid? Perhaps it is only fair to compare sales of the same title means anything. And here is where any study can be thrown out. Actual sales figures are not readily available.
Assuming one thing in common: All the books were well written.
If you have more, or a thought, contact me.


text:
Before Judges Long, Stern & Kleiner.
On appeal from Superior Court of New Jersey, Chancery Division, Family Part, Warren County.
Frost & Ironson, attorneys; Ms. Frost, on the brief).
Sanford M. Kahan argued the cause for respondent (Simon & Enright, attorneys; Mr.
Kahan, of counsel and on the brief).
27. The Husband has a pension plan through his employer, Sandoz. The Wife shall receive 50% of all of the benefits the Husband acquired in this pension from the date of marriage to the date of Complaint by way of a Domestic Relations Order. By virtue of the long term marriage, the Wife shall be named as a Joint Survivor on any Pre-retirement survivor annuity as well as on any post-retirement survivor annuity, accrued from the date of marriage to the date of the complaint for divorce, if permitted by the pension plan.
Your average annual compensation is initially based on your total compensation paid over the last ten calendar years preceding your date of retirement. From this ten-year period, your total compensation over the five highest possible average, is extracted and averaged. Total compensation is all compensation paid you in the form of salary and wages, overtime, shift premium, bonus and commissions. [example omitted].
Credited Service is used to determine the amount of your benefits under the Plan. Credited service is accounted for in years and months.
All service rendered by you to the company prior to your sixty-fifth birthday will be recognized as credited service, up to a maximum of forty years. If you terminate your employment with Sandoz and return to the company at a later date, or if in the past you terminated employment with the company and have since been rehired, all prior service rendered by you to the company will be recognized as credited service. However, your prior service will be recognized only after you have completed one year of continuous service since your most recent date of hire.
Your Primary Social Security Benefit is the Social Security Benefit to which you alone are entitled, and does not include any benefits applicable to your spouse and/or dependents.
The Social Security benefit on which your Social Security offset will be based will be determined by reference to actuarial tables supplied by the Retirement Plan Actuary. The use of these tables is intended to develop Social Security benefit values which closely approximate those an employee is likely to receive based on his/her final average compensation at Sandoz. These tables do not necessarily represent the exact actual Social Security benefit to which you are entitled.
your Years of Credited Service.
In July of 1996, approximately two months after the divorce was finalized, Sandoz offered defendant a voluntary retirement incentive package as a result of its merger with Ciba-Geigy and the downsizing that this merger brought about. According to defendant, employees who were offered the retirement incentive package could either accept the package or face the possible elimination of their jobs. Defendant accepted the package and retired on October 1, 1996, more than two years after the divorce complaint was filed.
agree to retire on October 1, 1996.
At the time this incentive package was offered to defendant he was 57 years old and had 30 years of service at Sandoz.
Adding an additional five years of service and five years of age in calculating your pension benefit.
Adding five years means adding five years to the service you actually have.
Adding five years of age means that you are assumed to be five years older for determining your early retirement reduction factor, if any.
For example, if you are age 56 and have 10 years of service, your pension benefit will be calculated as if you are age 61 with 15 years of service. The benefit will then be reduced by 2% for the year between ages 61 and 62 when 100% of the benefit would be payable. Without the enhancements offered by the [voluntary retirement incentive], a pension starting at age 56 would be reduced by 20%.
Pursuant to this package, five years were added to defendant's age and years of service which thereby increased the value of the pay-out. Although defendant was only 57 years old with 30 years of service at the time he retired, he was deemed to be 62 years old and credited with 35 years of service. Because he was assumed to be 62 years old there was no early retirement reduction.
A special incentive payment equal to two weeks of annualized total compensation for each year of service with the company plus eight weeks of annualized total compensation will be paid to you. By counting months of service, the payment calculation will also include partial years of service.
In addition, he received extended medical and dental benefits, an investment plan and special transitional benefits. Only the enhanced pension is at issue here.
Because the QDRO was not yet in place when defendant began receiving his pension, plaintiff did not receive her share at that time. Defendant, however, placed plaintiff's full one-half pension share into a separate interest bearing account until the matter was resolved. On March 20, l997, plaintiff filed a notice of motion for post-judgment relief seeking, among other things, a determination as to whether the enhanced pension was to be shared by her and also seeking counsel fees.
This is a request by the plaintiff that the Court determine the denominator of the coverture f[r]action to consist of the defendant's entire years of service at Sandoz CIBA. Paragraph 27 of the judgment of divorce compels the defendant to turn over to the plaintiff 50 percent of all of the benefits the husband acquired in this pension from the date of the marriage to the date of the complaint, by way of a domestic relations order.
In July 1996, defendant was offered an early retirement package, which he took. [Plaintiff] feels she is entitled to share in the voluntary retirement incentive package. The defendant feels plaintiff should not share in same because this voluntary retirement incentive package was offered to the defendant two months after the divorce.
The language of the property settlement agreement judgment of divorce is clear. Plaintiff is to receive 50 percent of the pension up to the date of the filing of the complaint. [Defendant] received his package two months after the divorce. The complaint was filed June 20th, 1994; the divorce was granted on May 13th, 1996.
Counsel requests $2,362.50 attorney's fees which is denied.
Plaintiff appeals from this decision, contending that defendant acquired all the benefits in the plan during the marriage and that the voluntary retirement package was not a result of defendant's post-complaint work efforts. She also claims entitlement to counsel fees. Defendant counters that the trial judge acted properly by "refusing to modify the clear and precise terms of the property settlement agreement," that the pension enhancement is not subject to equitable distribution and that plaintiff is not entitled to counsel fees. We have carefully reviewed this record in light of the parties' arguments and have concluded that plaintiff is entitled to share in defendant's voluntary retirement package. Thus, we reverse.
The complicating factor here is the retirement incentive package offered to defendant after the divorce. It is this package which is the subject of the parties' contest over distribution. In order to determine whether property is subject to equitable distribution, it is necessary to assess whether it was "legally and beneficially acquired" by the parties during the marriage. Kikkert v. Kikkert, 177 N.J. Super. 471, 474-475 (App. Div.), aff'd o.b., 88 N.J. 4 (1981). Whether the enhanced pension is includable in the marital estate depends upon the nature of the property and how it was earned. Whitfield v. Whitfield, 222 N.J. Super. 36, 47 (App. Div. 1987). See McGrew v. McGrew, 151 N.J. Super. 515, 518 (App. Div. 1977) (considering to what extent the pension benefits have been produced by the mutual effort of the parties).
If we were to accept this superficial analysis as a bar to the inclusion of this significant asset in the marital estate, we would be paying lip service to the theory of equitable distribution while ignoring the reality before us. These parties were married for sixteen years during which time they experienced all of the joys and sorrows of married life. They raised three children. It is uncontroverted that they labored, shoulder to shoulder in the military, establishing homes and supporting their family, both financially and emotionally, all over the world. During the entire marriage, defendant was accumulating credits toward his pension which both parties anticipated he would receive in 1988. Clearly, this pension will not be earned on the 20th anniversary of defendant's entry into the service. Rather, it was earned during each and every day of his 20 years of employment in the military, 16 years of which were spent in the military, 16 years of which were spent in a "shared enterprise" with plaintiff.
Accordingly, we determined that the husband's pension was includable as marital property and that it could not be excluded from the distributable estate "because of the fortuitous timing of the failure of this marriage." Ibid.
[T]he segment of cost-of-living increases attributable to those contributions and services made during the marriage from the joint efforts of both parties are subject to equitable distribution.
Several other decisions are instructive on this issue. In Hayden v. Hayden, 284 N.J. Super. 4l8 (App. Div. l995), another panel of this court excluded a post-divorce pre-retirement cost-of-living increase in valuing a husband's pension. In reaching its conclusion, the court recognized that the cost-of-living increases in Moore were merely adjustments to "the pension payments for the then current real value of the dollar." Id. at 423. As such, they were "as much a part of the pension as the amounts initially established by the pension system on retirement. . . ." Ibid. On the contrary, the court in Hayden found, as a fact, based on its analysis of the pension before it, that the cost-of-living component of pre-retirement salary increases were directly related to work performed after the divorce and thus outside the distribution scheme. Id. at 424.
In Ryan v. Ryan, 26l N.J. Super. 689 (Ch. Div. l992) the issue was whether the husband's severance pay, which he received over two years after the divorce complaint was filed, was subject to equitable distribution. The husband was offered a severance payment by his employer as an "inducement to leave the company" and as a result of his company's desire "to reduce its overall work force." Id. at 693. The trial judge determined that the payment was based upon the husband's weekly pay and years of service. Id. at 696. Accordingly, the judge concluded that "the severance payment was compensation for past labor, not a replacement for future earnings, because the amount was based on the [husband's] past services to IBM." Id. at 697. Therefore, the payment was considered a marital asset subject to distribution.
With regard to the stock options, we continue to balance the need for definitiveness embodied in the date-of-complaint rule with the need for flexibility inherent in equitable distribution. Assets or property acquired after the termination of the marriage, but as a reward for or a result of efforts expended during the marriage, normally will be includable in the marital estate and thus subject to equitable distribution.
Each of these cases recognizes and applies the same well-established rule: that assets acquired by gainful labor during the marriage or as a reward for such labor are distributable while assets acquired after dissolution due solely to the earner's post-complaint efforts are his or her separate property.
Here, defendant argues that the enhanced pension was not earned during the marriage but was a "replacement for his future earnings" which would otherwise have been his separate property and thus not includable in the distributive pot. A review of the plan, however, belies this view. The enhanced pension benefit was a concomitant of the takeover of Sandoz by Ciba-Geigy, obviously intended to thin the herd of aging Sandoz employees as part of an overall downsizing. It was not offered to every employee who was in danger of losing his or her job. On the contrary, the pension incentive was only offered to employees who had reached age 55 and had worked for Sandoz for l0 years. In other words, it was offered in recognition of age and faithful service. Defendant had already met the qualifications for the incentive package at the time the divorce complaint was filed. He was then 55 years of age and had worked for Sandoz for 28 years. No effort on his part beyond what took place while he was married to plaintiff caused the accretion of his pension. To be sure, accretion due solely to the diligence and industry of a party go to him or her alone. Bednar v. Bednar, l93 N.J. Super. 330, 333 (App. Div. l984). That is not the case here. Here, defendant received the benefit of the pension incentive package because of his age and as a reward for his length of service which was attributable to his efforts during the marriage. Pascale, supra, l40 N.J. at 609.
severance pay based on 3 weeks of annualized total compensation per year of service plus 8 weeks of annualized total compensation as notice pay; the minimum will be 26 weeks and the maximum will be l04 weeks of combined notice and severance pay.
Defendant also received what Sandoz denominated as "severance pay" at a rate of two weeks for each year of service (not three as in the case of an employee who was involuntarily terminated) but otherwise according to the same formula. This is the replacement for future earnings component of defendant's benefit. Like future earnings it is not subject to equitable distribution. In this respect, we note our disagreement with the conclusion reached in Ryan v. Ryan, supra, which we believe failed to account for the nature of a severance benefit. There the trial judge characterized a severance pay package as distributable because it was calculated based on years of service. Ryan, supra, 26l N.J. Super. at 697. The problem with this analysis is that it fails to differentiate between entitlement and methodology. Only those benefits to which an employee's entitlement arises out of labors during the marriage are distributable. Severance pay is not such a benefit but is a wage continuation initiative, replacing current and future earnings which would unarguably be the earner's separate property after divorce. In an alimony situation severance pay, as a replacement for income, is a fund from which such alimony can be paid. Where no alimony is involved, the severance pay belongs solely to the terminated worker who, upon its receipt, is in no better economic condition and whose ex-spouse is in no worse economic condition than would have been the case if the worker had continued working after the divorce. The fact that severance pay is calculated based on years of service is of no consequence. This is simply a mathematical device unrelated to the question of the nature of the benefit and when it was earned. While it is true that longevity of service increases the amount of severance pay, the same can be said of post-divorce earnings, about which there is no suggestion of distributability. Indeed, we note that plaintiff here made no application to distribute the severance pay component of the pension incentive package because she obviously understood this distinction.
In sum, the pension enhancer here was clearly distributable by application of the coverture fraction the parties agreed on because it was earned as a reward for service during the marriage. The decision to take the early retirement package clearly benefitted defendant. If economic justice is the goal, there is no reason why plaintiff, who spent 28 years with defendant while he worked at Sandoz during which years he qualified for the pension incentive, should not share in that benefit.
This is not to suggest that parties cannot bargain away early retirement incentives or other pension enhancers. However, where they are earned in whole or in part during the marriage, they are includable in the pot for equitable distribution absent a bargain to the contrary. Lawyers should keep this in mind in negotiating matrimonial settlements. Future pension benefits can be fluid and changeable; it is often uncertain at the time a deal is struck what the exact value of the bargained for benefit will be when it is paid out. Thus, precision in setting forth the intent of the parties as to future pension enhancements is crucial to avoiding further acrimonious litigation.
We turn finally to the issue of what the denominator of the coverture fraction should be in this case. Is it 28/30 which would reflect the actual years worked by defendant or 28/35 reflecting the years added to his service by the company? We think the former is the correct denominator because it reflects reality. Defendant worked two years after the filing of the complaint before he retired. Thus 28/30 reflects the differential between employment during coverture and further employment. The gift of 5 extra years of service should not be used to reduce plaintiff's fractional share of the pension when no work was actually performed for that service.
Reversed and remanded for calculation of plaintiff's share of defendant's pension consonant with the principles to which we have adverted and for a redetermination of plaintiff's application for counsel fees applying the standards of Williams v. Williams, 59 N.J. 229, 233 (l97l).
Footnote: 1 From the pension materials submitted by the parties it appears that a Sandoz employee could take early retirement if he or she was 50 years old and had worked for Sandoz for l0 years. We reach this conclusion based on the pension calculation methodology which requires averaging the last ten years of compensation and the early retirement penalty provision which only begins at age 50.


M. MURRAY, ET AL., DEFENDANTS.
Plaintiff is a state prisoner proceeding pro se. Plaintiff seeks relief pursuant to 42 U.S.C. § 1983 and has requested leave to proceed in forma pauperis pursuant to 28 U.S.C. § 1915. This proceeding was referred to this court by Local Rule 72-302 pursuant to 28 U.S.C. § 636(b)(1).
Title 28 U.S.C. § 1915 permits any court of the United States to authorize the commencement and prosecution of any suit without prepayment of fees by a person who submits an affidavit indicating that the person is unable to pay such fees. However, [i]n no event shall a prisoner bring a civil action or appeal a judgment in a civil action or proceeding under this section if the prisoner has, on 3 or more prior occasions, while incarcerated or detained in any facility, brought an action or appeal in a court of the United States that was dismissed on the grounds that it is frivolous, malicious, or fails to state a claim upon which relief may be granted, unless the prisoner is under imminent danger of serious physical injury.
"Under the PLRA,*fn3 prisoners who have three complaints dismissed under section 1915(e)(2) are barred from filing additional in forma pauperis complaints unless they are 'under imminent danger of serious physical injury.'" 28 U.S.C. § 1915(g). Lopez v. Smith, 203 F.3d 1122, 1129 (9th Cir. 2000). To meet the exception, plaintiff must have alleged facts that demonstrate that he was "under imminent danger" at the time of filing the complaint. Andrews v. Cervantes, 493 F.3d 1047, 1052-53 (9th Cir. 2007).
Plaintiff alleges he is being poisoned by correctional staff.*fn4 Plaintiff seeks money damages only. Although plaintiff's allegations concern a medical condition, plaintiff does not demonstrate that at the time of filing of his complaint, he was "under imminent danger of serious physical injury." The fact that plaintiff seeks money damages only as a form of relief belies any representation that he might be under imminent danger.
Plaintiff will be directed to submit the entire filing fee of $350.00 within twenty-one days as he is barred from proceeding in this action in forma pauperis under the three strikes provision of § 1915(g). Plaintiff is cautioned that failure to comply with this order will result in a recommendation that this action be dismissed.


text:
...in which I post each Wednesday's game that I play, with my own (doubtless horrificly flawed) annotation, for all to laugh at/critique/offer improvements on.
This week, in my return to the SDCC after four long years away at college, I played against Allen Burke, who made an opening error on the White side of the French Advance and could not quite recover despite fiery attempts to get some counterplay.
I’ve never been a very big fan of this move and am now prepared to call it refuted. Black has a lot of excellent options when White chooses this very fleeting pin. He can play 5…Bd7 which releases the pin, moves the bad bishop to a somewhat better square, and sets a clever little trap based on the knight releasing the pin, for instance 5. Bb5 Bd7 6. Nf3? (or some such) …Nxe5. 7. Nxe5 Bxb5 or 7. Bxd7+ Nxd7; in either case, White has lost an important pawn for nothing.
Still, petty traps aside, I think the best way to deal with this ghost threat is 5…Qb6, which comes right back at White by kicking the bishop and putting more pressure on d4.
Also not a very good move, but White has nothing better. The only other real option is 6. Ba4?, which concedes a critical tempo to Black, which the second player will use to develop overwhelming force against d4 with moves like Ne7-f5. In the long term, White will have to waste more time getting the bishop off the queenside, where Black will eventually start to eat up lots of space. Still, the text is not that healthy either, as we see.
Now Black has a very strong game. The bad bishop can now rain the proverbial fire on the White kingside from a6, preventing White from castling Kingside, the former black b-pawn can eventually be used as another attacker on d4 after the elder c-pawn takes on d4 (fully replacing the attacking power of the knight), Black retains the two bishops and White loses them in a position increasingly likely to be forced open, and White has lost his light squared bishop, a critical piece in any White attack on Black’s Kingside, usually White’s best plan in the Advance. This is about as good as Black can possibly be coming out of the Advance variation.
Black also contemplated an immediate center-crushing c5, but decided that it was best to keep White from castling first.
Now White cannot prevent Black from effectively isolating the d-pawn and wresting away control of the center (not to mention taking aim at the c-file). Further, if White trades bishops, Black gains a tempo on the recapture by the knight; he wants to play this knight to either e7 or (as events develop), h6, both of which allow movement to a square that attacks the soon-to-be-weakened e5 pawn.
White sees Black’s plan to add the knight as an attacker (either against d4, or against e5 if the d4 pawn is terminated) and decides to strike first. 10. Bb2, despite the admission of a wasted tempo, still seems better; White can gain a little more time to defend himself while Black brings out the knight, although it’s unclear how White will do this. The best plan would probably involve Nd2 followed by Rc1 while Black plays Nh6, Nf5, and then initiates combat on d4. Rc1 after whatever mayhem takes place on d4 would prevent Black from completely dominating the c-file, as he does in the text.
If 15. Qd4??, then 15…Qe2 mate. Such is the power of Black’s light-squared bishop, which has been transformed from a pathetic non-piece in most French advance lines into a terror that is killing a good deal of White's defensive possibilities.
Now Black owns the c-file.
Even though it’s ultimately doomed to failure, White should get credit for going down swinging. This move activates the only piece that can possibly be activated in the position, and also scares Black into wasting a bit of time.
Black was afraid of the White pawn moving to h5, and so decides to block it. Black should not fear 18. h5, though. Though the knight is prevented from executing the Ne7-Ng6 maneuver, Nh6-Ng4 works just as well for the purpose of threatening the e5 pawn now that no pawn can cover the g4 square. Black also fails to see that White probably had no intention of ever playing h5. White’s intention was probably to play Rh3 (which finally frees the f3 knight, since the White rook can now intercede on the e-file after the knight moves) as soon as possible; though Black saw that White wanted to play Rh3, he was a bit overly scared of h5. Though 17…h5 is hardly fatal, an immediate Nh6 was much better; the text loses a tempo, and if White's coming attack had more sting to it, this would have been critical.
White is valiantly trying for some play on the Kingside, and, as is soon made clear, is willing to give up significant material for any amount of freedom from the crushing immobility he has been suffering since move 14.
Threatening either mate or fatal loss of material, but White still has one last gasp.
This looks a little scary, but White has nothing. The White Queen cannot penetrate further into Black’s defenses, and Qg6 is easily met by Rhg8. White needs more force into this attack, and Black will have far too much time to attack the White King if White tries to bring anything else into position to attack the Black King (if indeed he can). It’s now clear that White is doomed, and the end soon follows.
Intending what? This just makes it very easy for Black.
Retreating the King to the first rank loses immediately to …Rc8+, after which many a mate is possible. Kh2 is also possible, though it works no better than the text does.
At the very least, Black can trade Queens and simplify to an easily-won endgame, all the mating nets that Black probably missed aside. Given how White’s game turned out, I think that playing 6. Ba4 instead of 6. Bxc4?! is better, despite the tempo it cedes to Black. In either case, this game goes to show that 5. Bb5 is a very bad idea for White in the main line French Advance.
Before I get to this week's game, last week's game! Last week I played the talented Jason Qu, who caught me making a tactical oversight, then proceeded to grind me into the dirt for the win. Anderson vs. Qu 1. e4 c5 2. Nf3 e6 3. d4 cxd4 4. Nxd4 a6 White does not enjoy playing the Sicilian on either side of the board, and especially dislikes the ambuguity of the Najdorf variation. 5. Nc3 Qc7 6. Nf3?! White is following the somewhat questionable plan of pushing the e-pawn. Usually White's ideas involve solidifying the center with the bishops and bringing the just-moved knight back to b3 instead of f3. Importantly, on f3, the knight prevents the option of f4, usually a viable attacking weapon for White in such Sicilians as this. 6. ...d6 7. Bd3 Nf6 8. O-O Be7 9. Re1 Nbd7 10. Bf4 e5 White would simply not let up on the idea of playing e5, so Black decides to do it himself. White now fixates on the weakened d5 square and decides that he'll stick a knight there come hell or high water. 11. Bg5 O-O 12. Nd2?! White's plan now is the painfully-long knight tour Nf2-d2-f1-e3, at which point the knight will be aiming at d5. This gives Black a goodly number of tempi, though. 12. ...b5 13. a3 Bb7 14. Nf1 Rfe8 15. Ne3 Qb6 White is having trouble with his d5 plan. Assuming that White either retreats his dark-square bishop or exchanges it for the f6 knight first, White still can't play a knight safely to d5- Black will be able to trade off two pairs of pieces and leave White with a very weak pawn on d5, one on which Black will be able to put significant pressure. Unfortunately, White never got as far as that, seeing only "Hey, I can play a knight there NOW, because if he tries to recapture with the knight, I'll exchange off the dark-squared bishops and have a pretty good game." 16. Ned5? Bxd5 17. Nxd5?? It was bad enough to drop a pawn, but White, happily blitzing along through his moves, doesn't see the problem and dives right in. 17. ... Nxd5 Oops, now White sees it. The knight now guards the bishop, and White's dark-squared bishop is hanging. If White takes the knight, he loses the bishop, and if he takes the bishop, Black recaptures with the knight and has gotten away a knight up. Instead of retreating the bishop and trying to tighten things up, White makes yet another mistake. 18. Bxe7? Exchanging when down is rarely a good idea. 18. ...Nxe7 19. Qf3 Now White adopts a "mate or die" attitude, something that doesn't work very often. 19. ...Ng6 20. a4 bxa4 21. Bc4 Rf8 22. Rxa4 Qxb2 23. Rea1 Qxc7 24. Bd5 Rb8 25. g4 Rb1+ 26. Rxb1 Qxb1+ 27. Kg2 Nf4+ 28. Kg3 Nxd5 29. exd5 Nc5 30. Ra3 Qg6 31. h4 f5 32. g5 h6 33. Kh3 hxg6 34. h5?? Boldly continuing the Kingside attack (and unlearningly playing too quickly) to the end. 34. ...g4 35. Resigns. White is lost even WITHOUT dropping the queen. The young Mr. Qu plays an error-free game and punishes White's repeated oversights with precision.
And I'm back. Law school, sadly, takes up even more time than chess. I'm way behind, and this game was played on June 20th. However, it was not played at the SDCC. I used to belong to the La Jolla Chess Club in my more youthful youth (where I garnered my somewhat sandbaggish 1270 rating), and that club was run by NM Alex London, a great guy and an excellent player who never tires of telling the story of his victory over a middle-period Bobby Fischer. Back in June, my best friend Theron and I went to Alex's apartment and played a three-hour game against him; Theron and I discussed the situation on the board and came to a consensus about the move to make. Theron has brilliant tactical flair and I love playing quiet, strategic positions, so it was thought we might eke out a nice result against the master (indeed, we had obtained a more or less winning position from the White side of a Ruy Lopez from an earlier visit to Alex before that game was mysteriously "adjourned." No one can now find the scoresheet). This time, we volunteered to take the black pieces. NM London v. Anderson & Pummer 1. d4 Nf6 2. c4 g6 Theron knows the King's Indian Defense better than I know my standard 1.d4 responses, so we decided to go with it. 3. Nc3 Bg7 4. e4 d6 5. f4 London plays the Four Pawn Attack variation of the KID and dares us to do our worst. 5. ...O-O 6. Nf3 Nbd7 7. Bd3 c5 Challenging the White center and begging White to play e5, which would turn his center into a more static target. 8. dxc5 Nxc5 9. Bc2 Re8 10 .O-O Qb6?! This creates a discovered check threat and puts pressure on the White b-pawn, but much better moves are available. Significantly, this move blocks Black's own b-pawn, which should be used to challenge White's center even further via b5. 11. Be3! Blocking the discovered check and daring Black to take the knight's pawn. 11. ...Qxb2?! It is highly questionable whether accepting White's pawn offer is worth it. Black's Queen is off balance and White will build up positional advantages as his price for the pawn. 12. Bd4 Qb6 Like a car thief making for the state line. 13. e5! Rending the position open and showing the superiority of the White pieces. 13. ...Nfd7 14. Nd5 Qd8 15. exd6 Bxd4+?! 16. Nxd4 exd6 17. Nb5 Uh-oh. Because of Black's bishop exchange, White is in position for a deadly fork. 17. ...Nb6 Black goes for broke and tries to eat more White pawns instead of wasting tempo saving the exchange. 18. Ndc7 Nxc4 19. Nxe8 Ne3? A fork of one's own, but it is illusory. 20. Qxd6 Qxd6 21. Nbxd6 Nxc2 22. Rac1 Black can't save both knights. 22. ...Ne3 23. Rf3 Resigns 1-0 Black's anti-positional 12th move caused White to offer a pawn in exchange for massive positional compensation. Black greedily accepted and ceded permanent initiative to White. The tactical error on move 15 only accelerated an inevitable process.
Next up is my game against Anthony Harbone. This one left me feeling tired at the end. I've faced off against Mr. Harbone several times- all of them have been long, drawn-out battles, and none of them have scored me even half a point. Mr. Harbone is quiet and unassuming in person, and he carries the deceptive rating of 1600, but he is utterly merciless over the board. Beware. Anderson vs. Harbone d4 Nf6 c4 c5 d5 e6 Nc3 exd5 cxd5 d6 e4 g6 Bg5 Bg7 Bb5+ Nbd7 Nf3 O-O O-O a6 Bxd7 Bxd7 e5 dxe5 Nxe5 Bf5 Qb3? What does the Queen hope to accomplish here? There is no real threat to the b-pawn, and Qd2 would have worked much better if Rd1 was White’s goal. On b3 the lady is out of play. 14. …Qc7 Bf4? Pins cut both ways, and though White has a threat in 16. Nxg6, it is easily dispelled. 15. …Nh5 Nxg6 Nxf4 Nxf8 Rxf8 White had little choice after his error in calculation but to take rook and pawn for two pieces. White has a passed pawn, but must find a way to tame black’s scud-like bishops. Rfe1 Be5 g3 Nh3+ Kg2 Kh8 Making way for the rook. Re3?! After 21. Nd1 White can hold off Black’s tactical threats, though his long term chances still seem pretty bad. Now a forcing combination allows White’s rook and poorly-placed Queen to be forked. 21. …Bd4 Rf3 Bg4 Rd3 Rg8 Rf1 c4 d6? White is apparently a member of the “hope they blunder right back” school of thought. White could have done better by letting go of the Queen and Rook in exchange for the remainder of Black’s minor pieces, but it’s almost certainly a lost game either way. 25. …Qc6+ Resigns 0-1 Not a fun game for yours truly.
Throughout this short game, I became more and more confident. I thought I was slowly building up a nice, solid advantage against my opponent, Mark Lawless, and indeed I was. Sadly, slow build-ups of small advantages do not always guarantee victory, for reasons that will be clear. Lawless v. Anderson- C00 French Defense 1. e4 e6 2. Nf3 I don't really like 2. Nf3 much in the French Defense. It just seems boring. 2. ...d5 3. exd5 exd5 4. h3?! Mr. Lawless, during this game and in the post-mortem, revealed a phobia of pins of any sort. A truly irrational fear is the only explanation for this tempo-wasting move. 4. ...Nf6 5. b3 Bd6?! Not the best idea. Black wants to put the Queen on e7 and bust White's fianchetto with Ba3, but this will take a long time. 6. Be2 O-O 7. O-O Bf5 8. Bb2 c5 I decided not to follow through with my Qe2 plan, figuring that if I could enable the d4 push, I'd have a nice positional advantage. 9. d4 Nc6 Black just has to stack pressure on d4 and forceWhite to cede the center by capturing on c5. 10. dxc5? Immediate capitulation. The pawn is already adequately protected, and though Black will continue to develop threats, White can take some time to bolster the d-pawn. 10. ...Bxc5 Black has superior development and a d-pawn that is cramping White, especially if it can stationed and secured on d4. 11. a3? Intending b4, but who cares? 11. ...Re8 12. b4 Bb6 13. Bb5 Along with the pin-phobia, a pin-mania exists, it would seem. 13. ...Qd6? Bad move. This allows c4, and Black has to retreat the Queen to either d7 or d8 anyway. 13. ...Qd7 would have allowed Black to respond to 14. c4 with 14...d4! 14. c4 dxc4?? Ha-ha! Now, Mr. Lawless, when you recapture, I'll simply place a rook on the d-file and crush you to death along that file! And then I'll-- 15. Qxd6 Oh. Right. Hanging queen. 15. ...Resigns 1-0 Look before you leap, folks.
Don't worry, I'm coming back soon with some more unbelievably puerile analysis from this most prolific of class players (Class B now, woohoo!) And I'll be back to the club soon as well to add some more games to my database so you all can analyze my horrifyingly bad style if you've got me up on the pairings page. Coming soon: Anderson v. Borges, 1/2-1/2, a cut and thrust center-counter battle. Anderson v. Castaneda, 1-0, a well-played game by Luis; he had me on the ropes until he stepped into an endgame cheap shot that was my last hope. Lower v. Anderson, 1/2-1/2, a very intense battle where both sides played aggressively (but not perfectly) until wearing each other out into an agreed draw. Wijaya v. Anderson, 0-1, the redoubtable Mr. Wijaya exposed a bad hole in my favorite French defense, but then opened himself up to a nasty tactical combo. Anderson v. Jensen, 1/2-1/2, Rich and I fight it out to a tough King, Knight, and Pawns endgame, where both of us blow several wins before agreeing to a draw. Aiello v. Anderson, 0-1, the infamous game from the Reserve Championship. Roberto had completely busted me in the endgame, but I lashed out with a dubious (or more accurately, should-have-been-losing) sacrifice and shook things up enough to steal a win after an exhausting Queen v. Rook and Bishop endgame with a bunch of pawns still on the board. Anderson v. Broman, 1/2-1/2, with everything on the line, Vincent, who had an incredibly strong tourney, simply parries my assault and virtually guarantees his 1st place finish. Anderson v. Sweitzer, 0-1, Mr. Sweitzer cuts through a confusing middlegame quite skillfully and ends my slim hopes of stealing the Reserve trophy from under Mr. Broman's nose. Lower v. Anderson, 1-0, Marty deals with me quickly and efficiently in this rematch; he seemed to have a much better time of this opening the second game around. Anderson v. Kuhn, 1-0, Tom puts up an excellent fight after fumbling some material, but can't make up the difference.
It seems that h4 leads to good prospects and that you had all the chances here. Yes, it's almost certainly a draw with best play but I think you should have pushed here given your favorable position -- I remember being surprised when I was watching the game at the club and seeing the final position.
Yep, I've got it. I agree that the winning chances are mostly mine, but at the time I calculated that no matter what pawn pushes I executed over on the Kingside, Black would be able to just plant his King over there and prevent any trouble. I can't tell yet what kinds of positions flow if I had continued this game, but you're right; it is very hard for me to get in much trouble.

matches: v. v. v. v. v. v. v. v. v. v. v. v. v.


As we often do, let’s start with some good news. We have a new partner, Tom Greene, who has been practicing in employee benefits and executive compensation for almost 20 years. In addition to his traditional ERISA practice, Tom is already making a difference in our core M&A practice with his deft handling of 409A, 280G, ISO, plan termination, and benefits diligence issues for buyers, sellers, and management teams.
In Tom’s honor, this edition of the Issue Spotter examines how in-the-money stock options may be useful to growth companies. For this discussion, “in-the-money” means the strike price is below the fair market value of the underlying stock on the date of grant, and “growth company” means a relatively young private company whose equity and option holders intend to profit from capital appreciation in a sale of the whole company (rather than through distributions of operating profits or isolated equity sales).
Conventional wisdom says non-qualified options violate § 409A unless the strike price is at least equal to the fair market value of the underlying stock on the date the options are granted. Ensuring an “FMV strike price” is generally a good idea for business, securities compliance, and other non-tax reasons, but it isn’t absolutely required by § 409A.
To set the stage, remember that § 409A regulates the timing of deferrals and payments for “deferred compensation plans.” Generally, common stock options with an FMV strike price are not deferred compensation plans, and are thus exempt from § 409A. Needless to say, being exempt from § 409A means broad flexibility in designing the vesting and exercise provisions for such options, making one’s life a lot easier.
Options issued in-the-money, however, are deferred compensation plans under § 409A. While they aren’t exempt from § 409A, they can comply with it by, among other criteria, limiting and requiring exercise upon the earliest to occur of one or more of six permissible payment events: death, disability, an unforeseen emergency, a specified time or fixed schedule, and, most importantly for growth companies, a change of control or separation from service.
Here’s what makes in-the-money options a real possibility for growth companies: very few option holders ever actually exercise their options prior to a liquidity event or, to a lesser extent, a termination of employment. It’s only a slight exaggeration to say that a typical option holder would barely notice if his or her options could only be exercised on the earlier of a change of control and/or separation from service. With such restrictions on exercise, the options could comply with § 409A even if the strike price were below the fair market value of the underlying stock when granted.
While not normally the preferred approach, options with a nominal or below FMV strike price may be useful in certain circumstances. Most obviously, the company and a new executive may want the executive to share in proceeds from a sale transaction from “dollar one,” that is, based on the entire per-share value upon the sale rather than just the spread between the sale value and the exercise price. Or two or more employees may join the company and receive options at different times but, for various reasons, wish to receive similar equity compensation packages. Startup advisors will recognize another example — a founder may have verbally promised options to certain employees, and the company may even have adopted an option plan and authorize options grants, but the options are never actually granted to the employees until the company’s stock has substantially increased in value.
Complying with, rather than being exempt from, § 409A has some distinct disadvantages, which is why “FMV strike price” is more common. Most significant is the issue of “subsequent deferral.” Subject to some rare exceptions, in-the-money options (like all deferred compensation plans) must be exercised or cashed out upon the relevant payment event, even if the option holder doesn’t receive sufficient cash to pay the resulting taxes. For instance, the change of control may be a stock-for-stock reorganization with no cash consideration, or the separation from service may not include a sufficient severance package. Drafting around this risk may involve additional advance planning and negotiation.
Issuing stock options with an “FMV strike price” surely makes tax and other legal compliance easier, but it is not absolutely required by § 409A. There are circumstances in which in-the-money options may be useful. Such options comply with § 409A as long as exercise is limited to and required upon certain events, most notably a change of control or separation from service.
For more information, please contact Travis Blais or Tom Greene.