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Federal Election Commission | United States of America

MUR #5849

BANK OF AMERICA

Summary

RESPONDENTS: Cannon, Kathleen; Bank of America; Rubio, Robert

COMPLAINANT:

SUBJECT: Contributions-National Bank; Contributions-In the name of another

DISPOSITION: The Commission decided by a vote of 4-5 to take the following actions in MUR 5849:1. Accept the Conciliation Agreement with Kathleen Cannon.2. Take no further action with respect to Robert Rubio.3. Approve the Factual and Legal Analysis for Robert Rubio, as recommended in General Counsel's Report #5 dated September 4, 2009.4, Close the file.5. Approve the appropriate letters.
The Commission decided by a vote of 5-0 to take the following actions in MUR 5849:1. Accept the signed conciliation agreement with the Bank of America Corporation, as recommended in the General Counsel's Memorandum dated October 31, 2008.2. Approve the appropriate letters.3.Close the file with respect to the Bank of America Corporation.
The Commission decided by a vote of 4-0 to take the following actions in MUR 5849:1. Find probable cause to believe that Kathleen Cannon knowingly and willfully violated 2 U.S.C. §§ 441b(a) and 441f.2. .......... REDACTED .......... .3. Approve the appropriate letters.
The Commission failed to approve by a vote of 3-3 to find reason to believe that Alec Reinstadtler, Edward Kalush, Jan C. Brown, Wayne Roltzen, Christian Baehr, Don Mills, and Gemma Boykin violated 2 U.S.C. § 441f.
The Commission decided by a vote of 6-0 to: a) Open a MUR.b) Find reason to believe that Kathleen Cannon knowingly and willfully violated 2 U.S.C. §§ 441b(a) and 441f.c) Find reason to believe that Robert Rubio knowingly and willfully violated 2 U.S.C. § 441f.d) Find reason to believe that Bank of America Corporation violated 2 U.S.C. §§ 441b(a) and 441f.e) Approve the Factual and Legal Analyses, as recommended in the General Counsel's Report dated October 2, 2006.f) ...... REDACTED ...... g) Approve the appropriate letters.

Disposition

Disposition Penalty Respondent Citation
Conciliation: Probable Cause $15,000.00 Cannon, Kathleen 2 U.S.C. §441b(a)
2 U.S.C. §441f
Conciliation: Pre Probable Cause $1,800.00 Bank of America 2 U.S.C. §441b(a)
2 U.S.C. §441f
Reason to Believe Finding/No Further Action Rubio, Robert 2 U.S.C. §441f

Documents

Type Date Document
Conciliation and Settlement Agreements 09/25/2009 Kathleen Cannon 299 KB
11/24/2008 Bank of America 301 KB
Complaint, Responses, Designation of Counsel and Extensions of Time 12/10/2006 Designation of Counsel from Robert Rubio 33 KB
11/22/2006 Grant of Extension of Time to Robert Rubio 27 KB
11/21/2006 Request for Extension of Time from Robert Rubio 20 KB
11/13/2006 Grant of Extension of Time to Kathleen Cannon 29 KB
11/01/2006 Grant of Extension of Time to Bank of America Corporation 28 KB
10/31/2006 Designation of Counsel and Request for Extension of Time from Kathleen Cannon 92 KB
10/30/2006 Request for Extenstion of Time from Bank of America Corporation 51 KB
General Counsel Reports, Briefs, Notifications and Responses 09/25/2009 Notification to Bank of America Corporation 23 KB
09/25/2009 Notification with Factual and Legal Analysis to Robert Rubio 95 KB
09/04/2009 General Counsel's Report #5 158 KB
10/31/2008 MUR 5849 (Bank of America) 42 KB
09/25/2008 Notification to Kathleen Cannon 44 KB
06/17/2008 General Counsel's Report #4 536 KB
11/08/2007 Response from Kathleen Cannon 152 KB
10/17/2007 Notification with General Counsel's Brief to Kathleen Cannon 480 KB
12/14/2006 Response from Robert Rubio 65 KB
12/01/2006 Response from Bank of America Corporation 232 KB
10/24/2006 Notification with Factual and Legal Analysis to Kathleen Cannon 551 KB
10/24/2006 Notification with Factual and Legal Analysis to Robert Rubio 224 KB
10/24/2006 Notification with Factual and Legal Analysis to Bank of America Corporation 761 KB
10/02/2006 First General Counsel's Report 1 MB
Certifications 09/23/2009 Kathleen Cannon and Robert Rubio 29 KB
11/12/2008 Bank of America 26 KB
09/25/2008 Kathleen Cannon 25 KB
10/17/2006 Bank of America Corporation; Kathleen Cannon; Alex Reinstadtler; Edward Kalush; Jan C. Brown; Wayne Roltzen; Christian R. Baehr; Don Mills; Gemma Boykin; Robert Rubio 51 KB
Civil Penalties, Disgorgements, Other Payments and Letters of Compliance 10/27/2009 Kathleen Cannon 37 KB
12/08/2008 Bank of America 38 KB

Participants

Relationship Name
Primary respondent Cannon, Kathleen
Previous respondent Bank of America
Rubio, Robert
Respondent's counsel Elias, Marc E., Esq.
Kelner, Robert K., Esq.
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