Effect of Ethics 2006 on Description of Purpose

In reality most of the changes made to the financial disclosure act, merely codified the Registry’s existing Rules, while giving a little more explicit explanation of the direction of their original intent for the Act.

An example would be:

In the Campaign Financial Disclosure Rules, last revised in Feb. 1999, Chapter 0530-1, Section 1-.04 and titled Expenditures from Campaign Contributions it says:

When providing the purpose of an expenditure or category of expenditures as required by T.C.A. §2-10-107(a)(2)(B), a candidate shall provide a brief description of why the disbursement(s) were made. . . .credit card payments shall not be deemed sufficient.

The Ethics Act of 2006, effective 2/15/06 added to (B):

The purpose thereof which shall clearly identify that it is an allowable expenditure under §2-10-114. The words ‘reimbursement’, ‘credit card purchase’, ‘other’ and ‘campaign expenses’ shall not be considered acceptable description for purpose. Any purchase made with a credit card shall also be disclosed as a payment to the vendor providing the item or service. Credit card payments to separate vendors shall be disclosed as separate expenditures.

Hasn't ‘A Brief Description of Why the Disbursement Was Made,’ meant to accomplish the same function and goal, to ‘Clearly Identify That It Is An Allowable Expenditure?’

Is there any argument that the General Assembly intended any lower standard than 'clearly allowed' standard, since the inception of the Act in 1980, and just added a ‘Clearly Identify’ as somehow, a higher standard. It has meant the same thing all along. A simple 'why' the disbursement was made, has meant all along to show that it is an allowable expenditure? Is there a problem, here?

Since we’re talking words, let’s try two more. Credit Card.

The long standings Rules are quite clear - credit card payments shall not be deemed
sufficient.

The Ethics 2006 is still quite clear- The words ‘reimbursement’, ‘credit card purchase’ shall not be considered acceptable description for purpose.

The Question: Could the words, "American Express - Monthly Bill", in fact, have any other meaning and was it not meant to say the same thing as, "Reimbursement Credit Card Purchase(s)? " Which, of course, can not legally be considered as an acceptable description for any purpose.

There is nothing in Ethics 2006, or any where else in the rules, that allow the Registry of Election Finance to waive any part of the statute or rules, for any reason. They Can't, BUT, They Do.

The Registry is suppose to enforce not waive. That's A Fact, Jack!!

Stay tuned,

Uncle Ted