Saturday,

A ugust 2 9, 2 015 at 6 :06:49 PM M ountain Daylight Time

Subject: Re: Le&er to Chairman House re: Prohibited Loan

Date: Friday, August 28, 2015 at 2:53:23 PM Mountain Daylight Time
From:
To:
CC:

Steve House
Concerned GOP Members
Leo Jankowski, Derec Shuler, KRAIG ANDREWS, Jeremy Weathers, Isaiah Hess, robert miles, ,
Derrick Wilburn, Brandi Meek, Mike Kopp, Lilly Nunez, Je Hays, Richard Elsner, , Janell Reid, Rick
Fernandez, , , Sandra Foote, Bill Cadman, brian, Joy Homan, Anil Mathai, ROBERT, Doug
Childress, Randy Corporon, George Athanasopoulos, Murray, Christopher O.

Mr Anthanasopoulos, Mr Childress, and Mr Corporon,

I am in receipt of your letter and provide the following response

with guidance from our attorney.

While it would be optimal for the CRC to have entered into an agreement
with Centennial Bank whereby the loan was secured by collateral or a pledge
of future receipts (11 C.F.R. 100.82(e)(1) and (e)(2), the FEC regulations
also provide that a loan may be considered to have been made on a basis that
assures repayment on a case-by-case basis. 11 C.F.R. 100.82(e)(3). Because
the FEC typically enforces prohibited loan provisions against standing
committees (like party committees) only if and when a loan is defaulted on,
loans that are otherwise commercially reasonable that are paid on time will
not draw FEC enforcement.

Reference 100.83(e)(3):

(3) If the requirements set forth in this paragraph are not met, the
Commission will consider the totality of the circumstances on a case-by-case
basis in determining whether a loan was made on a basis that assures
repayment.

If necessary the state party could go back to the bank to accept some pledge
of future receipts as an addendum to the agreement governing the line of
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of future receipts as an addendum to the agreement governing the line of

credit, which would allow the CRC to avail itself of the safe harbors at 11
C.F.R. 100.82(e)(1) and/or (e)(2). We do not believe this action is necessary
at this time and will take no further action.

Sincerely

Steve House
Chairman
Colorado Republican Committee
5950 S. Willow Drive, Suite 210
Greenwood Village, CO 80111
303-758-3333 | Desk
steve@cologop.org

On Thu, Aug 27, 2015 at 11:36 PM, Concerned GOP Members <coloradoconcernedgop@gmail.com>
wrote:
Please see the attached letter and documents concerning the Centennial Bank loan.
On Thu, Aug 27, 2015 at 11:04 PM, Concerned GOP Members <coloradoconcernedgop@gmail.com>
wrote:
Please see the attached letter concerning the loan with Centennial Bank.

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