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FEDERAL ELECTION COMMISSIONWASHIthC1ON. C 01)
THIS IS THE BEGINING OF IJR #
DATE FILMED ilk CIERA NO,
CAMERAN
I
7q
- glr_ -
0 *tr-01
REPORTS ANALYSIS REFERRAL
TO
OFFICE OF GENERAL COUNSEL
DATE: March 4, 1998
ANALYST: Andrew Dodson
COMMITTEE: TECO Energy Inc. Employees' PAC(C00161422)Raymond Henagan, Treasurer*
(February 21, 1997 - Present)P.O. Box IllTampa, FL 33601
II. RELEVANT STATUTE: 11 CFR §104.5(c)(2)(i)(A)
2 U.S.C. §434(ay4)(A(iv)
-I. BACKGROUND:
Failure to Timely File the 1997 Mid-Year Report
The TECO Energy Inc. Employees' PAC ("the ConmittPe) failed totimely file the 1997 Mid-Year Report of Receipts and DisburCments overing theperiod from January 1, 1997 through June 30, 1997. The CommidPe was notifiedon December 30, 1996 and July 7, 11997 that the report was d in 31, 1997(Attchment 2). A Non-Filer Notice was sent to theC aunAugsmt 19, 1997 for faih to file the 1997 Mid-Yew Rapsi
on Sept Im 15, 1997, the Reports Analysis DivisW ("AI) maytattempted to contact the Committee Treasurer, Raymond Hmgam, and left a
Fessagp. On September 16, 1997 Ms. Robin Hastings calfd ft andst~ted that tbe report would be filed as soon as possible (A 4).
On N ber 3, 1997 the Commission received io ,s 1997Mid-Year Rmat (Attachment 5).
Two nib. pea*i agsd as fteasur and owi perso identifid as treasue but lD hasobmo sjd~ mPGOOL
.... [l[ll
FEM GEWTN mmu
cMITE lEEKOF 31KLU UDUITS5 - (E)
MUITTEE OMM EEMSTF
Attachment #,Page I of 2
itl l J
~SUBUTSLIVENE M'IES
I OF nlIIE ILNPWES LDCTINOF FILER
TEED OW lK EIPLW' PEDCTED UEIZATIE: Eli
195 STAIU F MUlRTI - MODITluST FE *ITIUk NUMTIE
FIR mI~l Im TSTAIWI ff IZTINMOM
VWa-99 - -Mg
19% STATIEJI Ff 1ZTIE - INWIRoL 01MI'L E lY Tl
'ST LEMTE I*IhT1UIL ET1m
JULY SEEVFIE-RIOV
VLII WL
FE-WOM
POST-8EKI TWOM--
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IS KN161422 NUIPT OMLIFIO
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9.024,735
1,33SUP
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-N--31ES-31KIS-31EM-3tllic
-31M-311h5-lum
-11SP5
-31395
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579"4S/313
*UM1235
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All Reports Have Been Reviewed.
'~
------------------ *- ------------------------- ft--- --- -ft --- ft - -- - - - ------- --- M ------------- M-M ---------- - --- ft ........ ft.-
AIMIME li L F I!11 U1 - (C)S
Attachment #IPage 2 of 2
mE i
-- ~-~--~---~------------------
cuMrnITHE n E-3S 1I21-RCM MTES
I OF NlIIWIFMES LK TIUOF FILER
US UNITIU: MIV STA9E OF I AI3III - imIT
W-EM NMI -MTItE F FAILI TO FILE
All Reports Haxe Been
10 01161%2 EW FNP IMLIFIO
23.023.0
139WIN
IS,W
NEWIJIB?
IJIU'
-Ju
-3115?
2 M116/15M11 7FEL12"II6ii g71Efl!75l~2 SIFELfMI
A ThTAL PM
Rev i ewed.
Ending Cash-On-Hand as of 12/31/97: $25 ,56
Outstanding Debts and Obligations Owed to the Commimttee: SO
Outstanding Debts and Obligations Owed
---------- - ------------------ - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - ftft . .
by the Comm-ittee-
Am ent # 2P of4
YEAR.END
REPORT NOTICEFEDERAL ELECTION COMMISSION
PARTINS l38 PAC$ December 30, lt
QUAmTI.LY AD ROTIY FILUs
Te01Ma UPORING 3ntxo*11736716 - M"41/AILIMGDA5B**
WIO MUST FILBAll party committees and PACs (nonconnected committees and separatesegregated funds) must file a Year-ond Report.
L"SinCommittees should affix the pool-off label from the envelope toLine I of the report. corrections should be made on the libel.COI IL1AMcSTreasurers of political committees are responsible for filing allreports on time. Failure to do so Is subject to enforcement action.Committees filing illegible reports or using non-FRC forms (exceptfor F3C approved computer generated forms) will be required torefile.
ITbese Mes indicate the beginning and the end of the resorperiod. A reporting period always begins the day after thee mad*date of the last report filed. If the committee Is me and haspreviouslY filed a re rt the first report mset cover all1e wt occurred before te committee registered.
*teuports sent registered or certified mall must be postmarked I temaliing datel othrwise, they must be received by the fiig dte.
(ver)
0
FILMSDAI
OrM71T
Pof 4
PARTIES AND PACS YEAR-END
1997 REPORTING SCHEDULEPARTIES AND PACSB
I. SEMIANNUAL FILERS**
REPORTMid-YearYear-End
REPORTING PERIOD01/01/97 - 06;30/9707/01/97 - 12/31/97
EG./CERT.MAILINGDATE**07/31/9701/31/98
FILINGDATE07/31/9701/31/98
I. MONTHLY FILESREG./CEtT.
RAILING PILINGREPORT REPORTING PERIOD DATE*** DATEFebruary 01/01/97 - 01/31/97 02/20/97 02/20/97March 02/01/97 - 02/28/97 03/20/97 03/20/97April 03/01/97 - 03/31/97 04/20/97 04/20/97May 04/01/97 - 04/30/97 05/20/97 05/20/97June 05/01/97 - 05/31/97 06/20/97 06/20/97July 06/01/97 - 06/30/97 07/20/97 07/20/97August 07/01/97 - 07/31/97 08/20/97 08/20/97September 08/01/97 - 08/31/97 09/20/97 09/20/97October 09/01/97 - 09/30/97 10/20/97 10/20/97November 10/01/97 - 10/31/97 11/20/97 11/20/97December 11/01/97 - 11/30/97 12/20/97 12/20/97Year-End 12/01/97 - 12/31/97 01/31/96 0l131/96
CoMttees hat wish to change their filing status must notify theCommlssion In writing when they file their next report due undertheir current reporting schedule.**Comittees that filed quarterly reports in 1996 are only required
to file semiannually in 1997.
***Reports sent registered or certified mail must be postmarked bjthe mailing date; otherwise, they must be received by the CULadate.
FOR MORE INFORMTION CALLs 800/424-9530 OR 202/219-3420
~. , ,'"
S
6
SASpa r-- # 2
MID-YEAR
REPORT NOTICEFEDERAL ELECTION COMMISSION
PARTIES AND PACS July 7,1997
WHO MUST FILEAll Party, Committees and PACs (Nonconnected Committees and Separate Segregated Funds)
must file either a mid-year or monthly report in July.
1. Quarterly FilersKAL.IGLK !.MAILING FILING
REPORT REPORTING PVRIOD* DATE** DAI.
Mid-Year 01/01/97 - 06/30/97 07/31/97 07/31/97
11. Monthly Filers
REGJCERT..M1AILIlNG FILING
BEPORT REPORTING PERIOD* DATI** DATE
July Monthly 06/01/97 -0630/97 07,20 97 0720,97
24 HOUR REPORT ON INDEPENDENT EXPENDITURESAny PAC that makes independent expenditures in connection with a special election may hmto file a 24 hour repor. This reporting qurement %ill be triggered if the committee makes
independent expenditures aggregating $1,000 or more after the 20th day, but more than 24 hours,before the day of the electon.
LA3FLCem~ibS shuld affix the pe-off lab fvo the envelope to line I of the rpmL -i-dmuld be made on te label.
Thes dates mdia the beginning and the end of the reporting perioed A reputinS porW
alys begs the day after the closing date of the last report filed If the rw amnw adh at mprviousy filed a report the firs por must coverall activity that occurvidbb t,.
SReports sent by registered or certified mail must be postmarked by the mailing dte;
WW theymust be receive by the filing date.
hi(mn)
6 pAt of 4#2CHANGE IN FILING FREQUENCYCommittees wishing to change their reporting schedule (for example, from monthly to
semiannual) must notify the Commission in writing when they file their next report due under
their current reporting schedule. Committees may change their filing frequencies no more than
once per calendar year.
ELECTRONIC FILINGFor reports covening activity occurring in 1997 (and later), political committees have the option
of filing electronically. If you are interested in this option, review the enclosed handout entitled
"Electronic Filing Gets Underway at FEC," and call the Data Division at (800) 424-9530 or
(202) 219-3730.
COMPLIANCETreasurers of political committees are responsible for filing all reports on time. Failure to do so
is subject to enforcement action. Committees filing illegible reports or using non-FEC forms
(except for FEC approved computer generated forms) will be required to refile.
FOR INFORMATION, CALL: (80) 424-953 or (M01)1944
(jI AMG 19 OT
4 ELECTRONIC MAIL SERVICESCONFIRMATION OF MAILGRAM TOITECO ENERGY INC EMPLOYEESO PAC
RAYMOND HENAGANPO Box IIITAMPA FL 33601-0111
FEDERAL ELECTION COMMISSIONSHAWN WERTH999 E ST* NH.WASHINGTON DC 204630001
IDENTIFICATION NUMBERS C0016142Z
REFERENCES AID-YEAR 10110111997 06130/19971
DEAR TREASURER:
IT HAS COME TO THE ATTENTION OF THE FEDERAL ELECTION COMNSSIONT"AT YOU MAY HAVE FAILED TO FILE THE ABOVE REFERENCED REPORT OF
- RECEIPTS AND EXPENDITURES AS REQUIRED BY THE FEDERAL ELECTION
CAMPAIGN ACT, AS AMENDED. YOU VERE PREVIOUSLY NOTIFIED OF THE DUEDATE FOR THIS REPORT.
IT IS IMPORTANT THAT YOU FILE THIS REPORT IMMEDIATELY WITH THEFEDERAL ELECTION COMMISSION* 999 E STREET. NoMe. WASHINGTON# D.C.20443 (OR WITH THE SECRETARY OF THE SENATE$. A COPY OP THE REPORTOR RELEVANT PORTIONS SHOULD ALSO OE FILED WITH THE SCKETARY OFSTATE OR EQUIVALENT STATE OFFICER.
LTHOUGH THE CONNIS*10 OUT INTIATE1 AN &It -4WeNPScENMTt ACTION Calr sU TIs RAot*r. i PsoANDA LETTER OP EXPLANATION WILL " TAE* INTO CONSIIRIATe.
IF YOU HAVE ANY QUESTIONS REGARDING THIS MATTER, PLEASE CONTACTJENNIFER Ko WALL CM OUR TOLL FREE NURSER 4l01424o849 o OLOCAL NURER IS (20l)219-SI0o
SINCERELY.
ASSISTANT STAFF 914CWSREPORTS ANALYSIS DIVISION
.~ 4 ~
,t
S A: fttachm I t I'sPage-lof
TELECON
ANALYST: Andrew Dodson
CONVERSATION WITH: Robin Hastings, PAC Coordinator
COMMITTEE: TECO Energy INC Emplyees' PAC
DATE: September 16, 1997
SUBJECT: Failure to file the 1997 Mid Year report
On 9/15/97 1 called Raymond Henagan ,treasurer of TECO Energy INCEmployees' PAC, and left a message concerning the failure of theto file a 1997 Mid Year report. On 9/16/97 Robin Hastings reftrned my calland stated that she would file the report as soon as possible.
A
'70M 43h EPORT OF RECEISAND DISBURSEMENTS'For Oie o Ta1 An ~holduj Cm w F-wdlh~ hoage)
I. NIE OF coMMTTEE (i )
Enemrgy Inc .,m AADDORESS (nuftor ww ob") r]Check IdnNo a Vw~ usy reports
P.O. Bxc 111
CITY. STATE W ZIP CODE
Tapa, FL 33601
t#5
REDEIVE.DFEDERAL ELE r'o;jCON Ile, ,, •.Ai O
NOY 3 IZ o7 ii '52. FEC IDENTIFICATIO NUMBER-
C00161422a m3 T , oowimtaeoe s fieda AFrCid elle
cowwfrtea. (e FEC FORM II)
4. TYPE OF REPORT
(a)[]"uIs 15Quuift Repoi
EI415 Ousileily Pe0cm
EOcwmbr 1s Ouwteuly Rp
QJnur 31 Yew End Repor
[!]Jhy 31 Mod Yew QRep r. ~Icm Yew Onl)
Mor"d eP~nor Due On
oFdbniy 20QMawh 20
o Aprti20[Q]May 2D
o June 20
0 Aus4t2
C) Sepsember 20
[ Twelfth day repo precedng
o Novefnbot200 Decore 2o) Januvy31
(TM ol E0cton)
election an m the State of
ThiiieW day repot following the General Election oor
(b " sremvr ~pt n Mi e, W? Sthe SUe of
OJyu 1&0N
SUMMARY COLUMN A COLUMNCoviorm omd 111197 . mo 6/30/97 71 Po cakw,...o0
(b) CashonHOm dgS181nn-1o6l PqmtPWWd .................................. $ 9,892.27 W
to TOW m t. 23o659.88 S23,659.8momfiow mim~ml~dlimOmmm 33,SS2.15 S33, =s.
& ln wWa S4nL $,, 7 b, im 6(" 15,153.20 $ 153.20a Dao *&vdTO onsO COMON
Dabo m4qN ow"eeomom mn9.d...-..WSwm" mu Socom
u a m Ie imom
vp- - 1 09 W
mo 4po W~ o o0 Sibm AMbd
'4'
I
00
FIDERAL ELECION COMMISSION999 E Street, N.W.
Washington, D.C. 20463
FIRST GENERAL COUNSEL'S REPORT
RAD REFERRAL: 9SNF-01
DATE ACTIVATED: June 18, 1998STAFF MEMBERS:Kamau PhilbertDeborah Rice
RESPONDENTS: TECO Energy Inc. Employees' PAC andRobin J. Hastings, as treasurer
RAD REFERRAL: 98NF-03
DATE ACTIVATED: June 18, 1998STAFF MEMBERS:Ruth HeilizerDeborah Rice
RESPONDENTS: Harry S. Truman Club - Federal mdLinda Tochterman, as treurer
RAD REFERRAL: 98NF-07
DATE ACTIVATED: Jm I IVASSTAFF MEM :Susan LebmaEric Brown
RESPOWDm~TS: Allegheny Teledyne Incoprx aedPolitical Action Committee (AT-PAC) aid
Dale G. Reid, as treasurer
- .. .r. " ,' 'F~tC .:',. .. . .
J E. -
RESPONDENTS:
RELEVANT STATUTE:
SOURCE:
INTERNAL REPORTS CHECKED
RAD REFERRAL: 98NF-08
VATE ACTIVATED: June 18, 1998STAFF MEMBERS:Mary TaksarEric Brown
North Side Good Government Committee andMichael Hagan, as treasurer
2 U.S.C. § 434(aX4XAXiv)
INTERNALLY GENERATED
Referral MaterialsDisclosure Reports
FEDERAL AGENCIES CHECKED: None
I. GENEIATION OF MATrERS
These matters were generated by four referrals that the Office of the General Counsel
received from the Reports Analysis Division ("RAD'). On March 4, 1998, RAD referred TECO
Energy Inc. Employees' PAC and its treasurer based on the failure to timely file te 1997 Mid-
Year Report. On March 6, 1998, RAD referred the Harry S. Truman Club - Federal sd its
tremm based on the failm to timely file the 1997 Mid-Year Report. On Jm 16,199 , R6D
reoWdoh AlqPu1y Teledyne InoprtdPolitical Action Ca.am (AT.AC Qmd
Dale G. Reid, as treasurer, based on the failure to timely file the 1997 Yew End Rert On
June 16, 1998, RAD refered the North Side Good Government Commi and Micluelhagm
as treasurer, based on the failure to timely file the 1997 Mid-Year Repomt.
II. FACTUAL AND LEGAL ANALYSES
Based on the Factual and Legal Analysis, Attachment 1, this Office recommends that the
Commission find reason to believe that TECO Energy Inc. Employees' PAC and Robin J.
Hastings, as treasurer, violated 2 U.S.C. § 434(a)(4XA)(iv).
Based on the Factual and Legal Analysis, Attachment 2, this Office recommends that the
Commission find reason to believe that the Harry S. Truman Club - Federal and Linda
Tochterman, as treasurer, violated 2 U.S.C. § 434(a)(4)(AXiv).
Based on the Factual and Legal Analysis, Attachment 3, this Office recommends that the
Commission find reason to believe that the Allegheny Teledyne Incorporated Political Action
Committee (AT-PAC) and Dale G. Reid, as treasurer, violated 2 U.S.C. § 434(aX4XAXiv).
Based on the Factual and Legal Analysis, Attachment 4, this Office recommends that the
_) Commission find reason to believe North Side Good Govermnent Committee and
Michael Hagan, as treasurer, violated 2 U.S.C. § 434(aX4XA)iv).
III. DISCUSSION OF C LIATION AND CIVIL rl&AUM
)
N
K A2L
*~;~
j~.
iv. RIECOMMZIDATIONS
1. a. Open a MUR in RAD Referra 98NF-01.
b. Find reason to believe TECO Energy Inc. Employees' PAC and Robin J.Hastings as treasurer, violated 2 US.C. § 434(aX4XA)Q'v), and er intoconcliaon prior to a finding of probable cause to beieve.
c. Approve the atahed FacbWad Legal Analysis and Conciliation, Aemnent
2. a. Open a MUR in RAD Refeal 9NF-03.
b. Find rmn - to beliee Hry S. Trmuma Club - Federal ad Link Tocbaerimnas tra , vioated 2 U.S.C. § 434(a(4XAX'i).
c. Afpw d ate cd Factua mad L n yAi .
d. Tks ardw aal ml cblo *a SL
3. a. Opem a MUR in RAD Read 9P4F-47.
b. Find umon to belie *a the Allgeny Tedy I %HiclActin Co- Ail&e (AT-PAC) mad Dlle 0. Rid, a trammu, vlhmld 2 U..C.f 434(aX4XA)(v).
c. Appovw to maed Fa m id Ln Anaysi.
d. Tal no frehe acdion mad close ile.
4. a. Open a MUR in RAD Rear 9PNF-0
S8 Sb. Find resona to believe that North Side Good Governmumt Commitee uidMichael Ham as treasurer, violated 2 U.S.C. § 434(aX4XAXiv), and enter intoconciliation prior to a findig of probable cause to believe.
c. Approve the attached Factual and Legal Analysis and ConcilaioA
5. Approve the a letters.
Lawrence M. NobleGeneral Counsel
___ ___ _BY:Date Lois G. Lri
Associate General Counsel
Attachments:I. TECO Energy Inc. Employees' PAC Factual and Legal Analysis2. Harry S. Truman Club- Federal Factual and Legal Analysis3. Allegheny Teledyne InMorpoated Political Action Committee Factual and Legal Analysis4. North Side Good Government Committee Factual and Legal Analysis5. TECO Energy Inc. Employees' PAC Conciliation Agreement6. North Side Good Government Committee Conciliation Agreement
BEFORE THE FEDERAL ELECTION COMMISSION
In the Matter of
TECO Energy Inc. Employees' PAC andRobin J. Hastings, as treasurer;
Harry S. Truman Club - Federal andLinda Tochterman, as treasurers
Allegheny Teledyne IncorporatedPolitical Action Committee (AT-PAC)and Dale G. Reid, as treasurer;
North Side Good Government Comitteeand Michael Hagan, as treasurer.
RAD Referral#98N7-01
RAD Referral#98N7-03
RAD Referral#98N-07
RAD Referral#98N-08
inf 01A
MVU~P, S~
CERTIFICATION
I, Marjorie W. E no, Secretary of the Federal Election
Comission, do hereby certify that on July 16, 1998, the
Commission decided by a vote of 5-0 to take the following
actions in RAD Referrals #98NF-01, 03, 07, 08:
1. a. Open a MUR in RAD Referral 98NF-01.
b. Find reason to believe TECO Energy Ine.Employees' PAC and Robin J. Xastiug atreasurer, violated 2 U.s.C.I 434(a)(4)(A)(iv). and enter intoconciliation prior to % finding ofprobable cause to believe.
c. Approve the Factual and Legal Analysisand Conciliation Agreement, asrecoumended in the General Counsel'sReport dated July 10, 1998.
2. a. Open a MUR in BAD Referral 98W1-03. I~A\q lb. Find reason to belieoe Harry S. Tzvi-n
Club - Federal and Linda Tochtezaan, streasurer, violated 2 U.S.C.S 434 (a) (4) (A) (iv).
* SFederal Ilection Comission Page 2Certification for RAD Referrals *98NF-01, 03, 07, 08July 16, 1998
c. Approve the Factual and Legal Analysis,an recomended in the General Counsel'sReport dated July 10, 1998.
d. Take no further action and close the
file.
3. a. Open a MUR in RAD Referral 9SNF-07.IN ttzb. Find reason to believe that the Allegheny
Teledyne Incorporated Political ActionComittee (AT-PAC) and Dale G. Reid, antreasurer, violated 2 U.S.C.5 434 (a) (4) (A) (iv).
c. Approve the Factual and Legal Analysis,as recommended in the General Counsel'sReport dated July 10, 1998.
d. Take no further action and close the
file.
4. a. open a MUR in RAD Referral 9SN7-O.I (0
b. Find reason to believe that North SideGood Government Committee and MichaelHagan, as treasurer, violated 2 U.S.C.I 434(a) (4) (A) (iv), and enter intoconciliatia prior to a fiadi ofprobable cause to believe.
c. Approve the Factual and Legal Analysisand Conciliation Agreement, asre mended in the General Counsel 'sReport dated July 10, 1998.
5. Approve the appropriate letters, asrec-anded in the General Counsel's Reportdated July 10., 1998.
(Contismd)
Federal Election Coiission Page 3Certification for RAD Referrals 98WF-Ol, 03, 07, 08July 10, 1998
Comissioners Aikens, Zlliott, McDonald, McGarry, and
Thomas voted affirmatively for the decision.
Attest:
Date' xarj LO W. mimmus
Secr of the Commission
Received in the Secretariat: Fri., July 10, 1998 12:03 p.m.Circulated to the Cosuission: Mon., July 13, 1998 11:00 &a.Deadline for vote: Thurs., July 16, 1998 4:00 p.m.
ird
0 S
FEDERAL ELECTION COMMISSIONWASHINGTON. DC 2043
July 23, 1998
TECO Energy Inc. Employees' PACc/o Robin J. Hastings, Treasurer702 N. Franklin Street, Plaza 9Tampa, FL 33602
RE: MUR 4774
Dear Ms. Hastings:
On July 16,1998, the Federal Election Commission found that there is rea o to believethat TECO Energy Inc. Employees' PAC ("Committee") and you, as treasue, volftd 2 U.S&C.§ 434(a)(4XAXiv), a provision of the Federal Election Campaign Act of 1971, a ancaed ('theAct"). The Factual and Legal Analysis, which formed a basis for the Commissim's finding, isattached for your infomat
You may submnit any fatal or legal mateals that you believe are m vm to heCommission's c Uosdatim of this matk. Pleae sbmit such nmarial to t e O iComl's Offic witN 15 doy of you MCC* of this wboemll. heSK, -shmld be sAilcd under oath. In the Aee of additionl information, the Boo usyfind probaMe caw to believe th a vbon has occurrd and proceed wv A
In order to expedftf the 1s81,10. oftt nhs , the oiomt
of thi 0 s per so a b i .(p.dls w sob eir a es*foba U" P* Ws soft* -NO8m
If yu we ec sd in expeditin the rslution of thi miser by ihcuue conciliation, and if you avce with the pro0vision of the enclosed a~n p
d Mretne I cmeU along with the civil penalty, to the C mmieimdonciliaio eg*im prior to a findin of probabile cue to bie a. ~ too
mxwm of 30 days. you duld respond to ths notification as soon as po@h ,
- f eremft ilm of ti ffmii n t outiasly geiiwiigat last five days primr to td s da&W oft*ae opqim i
delimutbawe In addition, the Office of the Genel Coumiel ordinar lybeyond 20 days.
0 STECO Energy Inc. Employees' PACPage 2
If you intend to be represented by counsel in this matter, please advise the Commisionby completing the enclosed form stating the name, address, and telephone number of suchcounsel, and authorizing such counsel to receive any notifications and other communicationsfrom the Commission.
This matter will remain confidential in accordance with 2 U.S.C. §§ 437g(a)(4XB) and437g(aXI 2XA), unless you notify the Commission in writing that you wish the investigation tobe made public
For your information, we have attached a brief description of the Commission'sprocedures for handling possible violations of the Act. If you have any questions, please contactDeborah L. Rice, the Paralegal assigned to this matter, at (202) 694-1650.
Sincerely,
Joan D. AikensChairman
EnclosuresFactual and Legal AnalysisProcedursDesignation of Counsel FormConciliaton Agreement
cc: Candidate
0 0tFEDERAL ELECTION COMMISSION
FACTUAL AND LEGAL ANALYSIS
RESPONDENTS: TECO Energy Inc. Employees' PAC MUR: 4774and Robin J. Hastings, as treasurer
This matter was generated based on information ascertained by the Federal Election
Commission ("the Commission") in the normal course of carrying out its supervisory
responsibilities. See 2 U.S.C. § 437g(aX2).
1. THE LAW
The Federal Election Campaign Act of 1971, as amended ("the Act"), provides that in a
non-election year all political committees other than authorized committees of a candidate shall
file a report coveting the period beginning January 1 and ending June 30, which shall be filed no
later than July 31 and a report covering the period beginning July 1 and ending December 31,
which shall be filed no later than January 31 of the following calendar year.
2 U.S.C. I 434(aX4)(AXiv).
The TECO Energy Inc. Employees' PAC ("the Committee") is a political coumittee that
is not an acthor-zed ofim. o a cmd1a Robin J. Hutiap is do emit omwf do.
Canmittee P, ilawl H w1 WK, -8 m lb Cdw = Jaw 3v M&
The Coumtee filed to timely Mie the 1997 Mid-Year Repart of Receips and
Disbursemenu covering the period fnxo January 1, 1997 to June 30,1997.0 Decedw 30,
1996 and July 7, 1997, noties were sent to the Committee infonring them h diue 1997 Mid-
Year Report Wm due mn July 31, 1997. A Hlr-Flrd Nodte w"s amt ComWs dvoa
mailgram on August 19,1997 for failure to file the 1997 Mid-Year Report.
0 2S
The Committee filed its 1997 Mid-Year Report on November 3, 1997, 95 days late. This
report disclosed $23,659.00 in receipts and $18,398.00 in disbursements.
Therefore, there is reason to believe TECO Energy Inc. Employees' PAC and Robin J.
Hastings, as treasurer, violated 2 U.S.C. § 434(aX4XAXiv).
* RECEIVESFEDERAL ELECTION
COMMISSIONSECRETARIAT
S& 3Pl0'N
BEFORE THE FEDERAL ELECTION COMMISSION
In the Matter of
TECO Energy Inc. Employees' PACand Robin J. Hastings, as Treasurer
)) MUR 4774))
GENERAL COUNSEL'S REPORT
I. BACKROUND
Attached is a conciliation agreement which has been signed by Robin J. Hastings, treasurer
of TECO Energy Inc. Employees' PAC.
U. IFAMMEMATIONS
1. Accept the attached conciliation agreement with TECO EnU Inc. El1yPe'
PAC and Robin J. Hastings, as Treasurer.
2. Close the file.
3. Approve the appropriate letter.
Lawrence M. NobleGeneral Counsel
Date
Attachment:Conciliation
BY:J .t4 y /Lois G. LoereAssociate General Counsel
Agreement
Staff Assigned: Kamau PhilbertDeborah L. Rice
~ki~A~
FEDERAL ELECTION COMMISSIONWashington, DC 20463
MEMORANDUM
TO: LAWRENCE M. NOBLEGENERAL COUNSEL
FROM MARJORIE W. EMMONS/LISA R. DAVICOMMISSION SECRETARY
DATE: SEPTEMBER 22, 1998
SUBJECT: MUR 4774 - General Counsel's Report dated September 16, 1998.
The above-captioned document was circulated to the Commsion
on Wedrlday, Stember 16. 1996
Objection(s) have been received from the Commissioner(s) as
indicated by the name(s) checked below
Commissioner Aikens
Commissioner Elliott
Commissioner Mason
Commissionw McD onld
Covmsioer %Pwimp400
Commissioner Thomas xxx
This matter will be placed on the meig agenda for
Tm v n mwmb w e. yoon
PMos notd us who wll so oi your Divbs t Cvi-esi aft Vie nmowt.
BEFORE THE FEDERAL ELECTION COMMISSION
In the Matter of
TECO Energy Inc. Employees' PACand Robin J. Hastings, as Treasurer.
MUR 4774
CERTIFICATION
I, Marjorie W. E ns, Secretary of the Federal Election
Comnission, do hereby certify that on September 23, 1998, the
Comission decided by a vote of 4-0 to take the following
actions in MUR 4774:
1. Accept the conciliation agreement with TECOEnergy Inc. Employees' PAC and Robin J.Hastings, as Treasurer, as recomnded in theGeneral Counsel's Report dated September 16,1998.
2. Close the file.
3. Approve the appropriate letter, asrec-_meded in the e al Counsel' a Reportdated eptmber 16, 1996.
(continued)
Federal Election ComissionCertification for MUR 4774September 23, 1998
Page 2
Comissioners Elliott, Mason, Sandstrom, and Thomas voted
affirmatively for the decision; Comissioners Aikens and McDonald
did not cast votes.Attest:
Received in the Secretariat:Circulated to the Comission:Deadline for vote:Received Objection:Placed on Agenda for:Objection Withdrawn:Withdrawn from Agenda
Secret
Wed.,Wed.,Mon.,•
Tuecs.,Tues.,Wed.,
of the Comission
Sept.Sept.Sept.Sept.Sept.Sept.
16,16,21,22,29,23,
199819981998199819981998
1:304:004:009:53
p.m.p.m.p.m.aom.
2:58 p.m.
lrd
gg.- 9 SYDate I
0 0
FEDERAL ELECTION COMMISSION
WASHINGTON. D C 20463
September 24, 1998
I
Robin J. Hastings, TreasurerTECO Energy Inc. Employees' PAC702 N. Franklin Street, Plaza 9Tampa, FL. 33602
RE: MUR 4774TECO Energy In. E loe' PAC
)
Dear Mr. Hastings.
On September 23, 1998, the Federal Election Commission accepted the sip.ed nciliationagreement submitted on your behalf in settlemm of a violation of 2 U.S.C. § 434(aX4XA'w), a
provision of'the Federal Election Campaign Act of 1971, as amended ("the Act"). Accordingly,the file has been closed in this matter.
The confidentiality provision at 2 U.S.C. § 437g(aX12) no louger apply ul this matter isnow pubfic. In addition, although the complete file must be placed on to publk recard witkn 30rday^ this could occur at my time nA~Uurg ctiwcation of the Co 0i t vow Ifym wiT to
submit any facualorlegal w, ih tappear on the mpubb rerd, pk dow ompossible. While the file may be placed on the public record befre receiving you adtlmaterials, any prisib aYi be added to the puk reod wpm r .
i~nInfomastinon derived is -r ---- with my -oai~a -uy -ia gWnwidmoig11113 the111F& written 11 coanu awe~ Inhe UUum M3 *&*4379(aX)(B). Thlu d mim w'w howevu,
record.
Page 2TECO Energy Inc. Employees' PAC
Enclosed you will find a copy of the fully executed conciliation agremw .' your files.Please note that the civil penalty is due within 3P days of the conciliation agreemeI effectivedate. If you have any questions, please contact me at (202) 694-1650.
Sincerely,
Deborah L. RiceParalegl Specialist
Conciliation Agreemat
rr
BEFORE THE FEDERAL ELECTION COMMISSION
In the Matter of)
TECO Energy Inc. Employees' PAC ) MUR 4774and Robin J. Hastings, as Treasurer )
CONCILIATION AGREEMENT
This matter was initiated by the Federal Election Commission ("Commission"),
pursuant to information ascertained in the normal course of carrying out its supervisory
responsibilities. The Commission found reason to believe that TECO Energy Inc.
Employees' PAC and Robin J. Hastings, as treasurer, ("Respondents") violated 2 U.S.C.
§ 434(aX4XAXiv).
NOW, THEREFORE, the Commission and the Respondents, having particiated
in informal methods of conciliation, prior to finding a probable caue to believM do
hereby agree as follows:
I. The Commission has jurisdiction over the Respondents and th sed maser
of this P and this agr-Pe t has the effect of an mgn tlrlIdPm4"ta
2 US.C. I 437g(aX4XAXi).
II. Respondents have had a reasonable opportunity to demonstra that no action
shoud be taken in this matter.
I. Respondents enter voluntarily into this agreentt with the C U
IV. The pertinent facts in this matter are as follows:
1. TECO Energy Inc. Employees' PAC ("the Committee") is a political
committee within the meaning of 2 U.S.C. § 431(4), and is not the authorized committee
of any candidate. The Committee elected to file its reports with the Commission on
quarterly basis.
2. Robin J. Hastings is the current treasurer of TECO Energy Inc.
Employees' PAC.
3. Jack Amor was the treasurer of the Committee until June 3, 1998.
4. The Federal Election Campaign Act of 1971, as amended ("the Act"),
provides that in a non-election year all political committees other than authrized
committees of a candidate shall file a report covering the period beginning Jamiry 1 and
ending June 30, which shall be filed no later than July 31 and a report coveing the period
beginnig July I and coding December 31, which shall be filed no latertlmn Jam y 31 lf
the daowhkg caendar yew. 2 U.S.C. I 434(aX4XA)(iv).
5. The nm iee failed to tidey fi1 the 1997 Wd-Ysur =ted
Receipts and Disbursements covering the period from January 1, 1997 to June 30, 1998.
On December 30, 1996 and July 7, 1997, prior notices were sent to the Co-'mm
i ni*tw them the 1997 M&d.Year Report wu duean July 31. 1997. A N .4%Iw
NoWIM w U atto the Comttee via nmiW onAugm 19, 1997 f itow sth*
1997 Mid-Year Report. The Non-Filer Notice was not received due to the confusion
regarding who was treasurer.
6. The Committee filed its 1997 Mid-Year Report on November 3, 1997,
95 days late. This report disclosed $23,659.00 in receipts and $18,398.00 in
disbursements.
V. The Respondents failed to timely file the 1997 Mid-Year Report in violation
of 2 U.S.C.§ 434(aX4XAXiv).
VI. Respondents will pay a civil penalty to the Federal Election Commission in
the amount of Nine Hundred Sixty Dollars ($960.00), pursuant to 2 U.S.C.
f) § 437g(a)(5XA).
VII. The Commission, on request of anyone filing a complaint under 2 U.S.C.
f437g(aXl) concerning the matters at issue herein or on its own mztion, may review
Sompliance with this agr If the C believes that this agreent or my
requirment themf ha been violated, it may institute a civil actiom for relief in the
United Sts Diirict Cot for the Disrict of oluniia.
VIE. This -graag ami beCmp effective U of the d oe st Al Mies in
have executed ame and the Cmmis has approved the entire agreemen
IX. R roP, ts dm1f have no mere than 30 days from the date this
becom effetive to comply with md mpim t the requIra nL in d&
toIm-1t Md to so nify the n im.
3
U 0
X. This Conciliation Agreement constitutes the entire agreemet between the
parties on the matters raised herein, and no other statement, promise or agreement, either
written or oral, made by either party or by agents of either party, that is not contained in
this written agreement shall be enforceable.
FOR THE COMMISSION:
Lawrence M. NobleGeneral Counsel
BY:
Associ General Cosel
FOR THE RESPONDENTS:
A"4 ef
mcx7g 1168W h m PAC
1 -, °
FEDERAL ELECTION COMMISSIONWASHINC TON. D C 20*63
THIS IS1}WEI4FMMJ#
DATE FIUED -L- i
-mwCAfM ND, d2~
4 4 '
FEDERAL ELECTION COMMISSIONWASHINGTON. D C 20463
Date: -/ /J /7 f
,Vicrofilm
Press
THE ATTACHED MATERIAL Is BEING ADDED To coswRaUR Y771
1664TECO ENERGY, INC. EMPLOYEES' PAC702 NORTH FRANKLIN ST
TAMPA, FL 33602
(CipA Am I I I &S &-_
1U-27/3110
J$ 96 o.
-D OLLARS " -
of Florida. ofAFloid& i.s .
mta g 14-17 1000166.4'0 1:o3002??: 00 3060 30 W
/
PAYTO THEOROER OF
71~LS6e.c0
FOR
O CT& &e.00- - 9 -- I F los
pc4s-ofv01J 00/,, .,#
FEDERAL ELECTION COMMISSIONWASHINGTON, D.C. 20463
October 28, 1998
TWO WAY MEMORANDUM
OGC Docket
Rosa E. SwintonAccounting Technician
SUBJECT: Account Determination for Funds Received
- We recently received a check from Tam ener I=c 3mploy. PAC,check number 1664, dated ctober 27, 1998, for the amount of 960.00. Acopy of the check and any correspondence is being forwarded. Please indicatebelow which a account the funds should be deposited and give the MUR/Casenumber and name associated with the deposit.
_)
'. BBnin3 ' = = '3lB = i n mmt BIKaBR H i n BB mBmBBB m~fBm m H m _] =-_
TO:
FROM:
Rosa E. SwintonAccounting Technician
OGC Docket
SUBJECT: Disposition of Funds Received
Budget Clearing Account (OOC), 95=3875.16
Civil Penalties Account, 95-1099.160
Other:
ture-' *~L~Z- '
4M~
A.4)E
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TO:
FROM:
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