This document addresses the questions posed to the CLAIMS development team related to the posting of draft filing formats on the Internet. If you have additional questions or desire further clarification related to any of the questions contained herein, please email David Hulse. His email address is dhulse@ss.ca.gov.

Question 1: I noticed there was a technical hearing set for May 20^th, 1999. Will there be a similar hearing for non-technical items such as user needs?

Answer: We have started a user’s group for the system. You can be added to the user’s group by contacting David Hulse at the email address listed above. We anticipate that we will have user’s group meetings in the future to address the public disclosure aspects of this system.

Question 2: Please tell us how the proprietary format of SDR Technologies meets the legislative intent of a nonproprietary format.

Answer: The format is being developed under contract to the State of California, with input from the filing software vendors, and is controlled by the State of California. SAIC, SDR or any other vendors do not have any patent, trademark, copyright, or any other intellectual property rights to the CAL filing format. Under the terms of SB 49, the Secretary of State will control creation of the format but any filing entity or vendor wishing to use it is free to do so without any intellectual property right restrictions.

SDR Technologies is a sub-contractor to Science Applications International Corporation (SAIC), the prime vendor for the Campaign and Lobbyist Automated Information Management System (CLAIMS) Project. In this role, SDR is assisting the SOS and SAIC in the development of the format. To reduce project effort, some format data previously developed was reused. The notation and style was maintained for document consistency.

Question 3: Please tell us how an existing format meets the requirement that hearings were to be held prior to the development of the format.

Answer: Due to the critical time nature of the CLAIMS project, a draft of the proposed format approach was posted on the Internet nearly 2 months prior to a planned hearing. All known filing software vendors and interested parties were notified of the posting and references to the posting were placed on the web page. Open feedback was solicited to allow for identification and resolution of issues. It was the intent of the SOS to establish this open dialog using the Internet prior to the hearings and identify any potential issues so that they could be addressed at the hearing. This approach will enhance the effectiveness of the hearing.

The Secretary of State was concerned that if the filing format was not released until September 1999, as mandated by SB49, the vendor community would not have adequate time to develop the software required to file in January, 2000. Our aggressive approach was to begin the development of the filing format using the Internet as a public forum, since the format definition is the critical link between the filing software and the CLAIMS system. The Secretary of State’s intent was to provide the maximum possible visibility, feedback, and time for the vendor community to implement the format.

Question 4: Please tell us why your office waited 19 months after the passage of SB 49 and a mere 3 months before the format was finalized to hold the required hearings for filer and software vendor input.

Answer: The format could not be considered until a number of actions had taken place, most of which were dependent on the budgetary needs and legislative budget cycles under which we operate. We did not have sufficient in-house staff to begin the technical format deliberations. The SOS needed the development contractor to represent the interests of the system to be developed that receives, analyzes and discloses the filings. The analysis of enforcement requirements is complex and the legislative budget was required to address these portions of the filing format. The delay was primarily driven by the state budget cycle. We have proceeded as quickly as we could, given these constraints. The format is not finalized, nor will it be finalized, until after the May 20th hearing.

Question 5: Please tell us if the public hearing on Thursday, May 20, 1999 is only perfunctory or will the concerns of the filer and vendor community be listened to in good faith.

Answer: We will respond openly to all concerns received prior to and at the May 20th hearing. The posting of a draft format and request for feedback on April 2, 1999 was a good faith attempt to hear the concerns of the filer and vendor community. Every question posed to the SOS will receive full consideration and open discussion. We would like the issues to be thoroughly discussed on the Internet. This should permit all parties to understand the issues and make it possible for quick resolution of those issues at the May 20 hearing or any subsequent hearing which, by consensus, we believe necessary or prudent.

Question 6: What is the timing? What is the initial filing period for usage?

Answer: The current interpretation of SB 49 is for the first required electronic campaign filing to be the first pre-election filing for the March 2000 primary, which has a tentative due date of January 27, 2000. The first lobbyist filing would be the first quarterly filing for 2000 with a due date of May 1, 2000. This information is being further clarified in SB 50(Johnson) and, therefore, is subject to change.

Question 7: What happens to the old standard? How long will the EFPOC be supported?

Answer: The current plan is to indefinitely support EFPOC Form 490 filings in the CLAIMS system. We are currently evaluating the feasibility of adopting and supporting the San Francisco Forms 419 and 420 EFPOC-style definitions. In addition, we are considering defining and accepting the Form 405 with an EFPOC-style formatting.

EFPOC will be supported for the specified forms as long as there are sufficient filers using this format.

Question 8: We do not see summary totals for each schedule? Or are they reflected on the summary record?

Answer: They are there for each schedule. The CA_ERF04.txt document does not have much supporting narrative, and we are working on improving the support material.

Question 9: Does an example exist of the output file? Can a format be generated for a typical Form 490 as was done for the earlier filing standard (EFPOC)?

Answer: We are working on the development of example output files. These files will be provided once the final filing format has been determined.

Question 10: Does each record start with a [Header] and end with an [End Header]? If not, what begins each record? Or do the record type and code fields signify a start? Examples would help.

Answer: The [Header] & [End Header] tags appear only once in a file. They are used to bracket all the "TagName = Value" records that convey information "about" the filing that weren’t directly related to the FPPC form content contained in the records following the HDR & CVR records. They appear at the very beginning of a CAL file. The header can be generated by the filing software vendor’s program using their own code or through the optional use of a Header Generation utility that will be provided free of charge by the SOS’s Office.

Question 11: Page 3 - Missing 2 fields "HDR" and "CAL"

Answer: These are text values that are contained in the first two fields following the end header tag. This is shown in the Draft California Electronic Filing Format Guide in the section titled "Constructing a HDR Record".

Question 12: The way dates are handled is good and an improvement over the old standard.

Answer: Thanks.

Question 13: Name handling appears to be very awkward. We are not sure of the value of the name delimiters. Why not separate fields for last name, first name etc with last name being long enough to handle organization names? Is it correct to assume that a double delimiter signifies a field not used?

Answer: The project team is taking a detailed look at this approach. There is some software maintenance benefits associated with the approach and approach is similar to what is in use at the FEC.

Yes, a double delimiter signifies that a field is not used.

Question 14: Can the address be broken out into street number, street name and street suffix. The reason is for future GIS usage.

Answer: We feel this may be unnecessary. GIS software, such as, USPS PAVE and CASS software, uses standard address parsing routines to identify house number, street name, pre and post directionals, street suffix(es), and APT/STE components of a delivery line address. It also deals with ½ numbering for duplex house situations. Little is gained by carrying the delivery address in parsed fields, and vendor campaign databases do not normally store the complete set of delivery line components in the roughly dozen potential components.

Question 15: I’m not sure I understand how amendments will work. I need an example for a specific transaction. It appears that amended transaction ID is the linkage that will cover adds, changes, and deletes (voids). Is this true?

Answer: Your assumption is correct. We agree that the amendment process needs better description. We are working on this description and actively considering alternative approaches. We anticipate that amendments will be a major topic of discussion at the May 20, 1999 public hearing.

Question 16: Assumption - pp11-13. Are these the only record types allowed for the various form types?

Yes. There are not very many kinds of records to parse and check for syntax. That cuts down on a lot of the overhead associated with the EFPOC style. The second field, Form_Type, is used mostly by the print rendering program to know exactly what kind of form a Receipt (RCPT), an Expenditure (EXPN) or a Loan (B1-B3; H1-H3) should be printed on.

Question 17: Good feature. All common fields at beginning of each record type - For example, are fields 1-25 the same for all cover pageforms?

Answer: In truth, cover (CVR) record layouts do vary by form. There is a different CVR layout for each kind of filing’s cover page. The CA_ERF04.txt layout tries to allow for reuse of code by normalizing the information into that which is common among all CVR forms and that, which varies between each CVR form.

The grouping of common followed by variable data allows programmers to make use of common procedures if they want and are able to do so.

Question 18: On Page 17, why can't cover F470 be handled like the other cover pages - i.e. common fields for 1-25?

Answer: It was a project team decision. There is so little in common between the F470 and the rest of the campaign disclosure covers, that the gains were not worth the cost of developing and using fields 1-25 for a 470, in the team’s opinion. We are open to listen to discussion to the contrary.

Question 19: Page 24 - Not sure how the summary transaction will look. Field names do not correlate for me with the statement.

Answer: We are addressing this issue in a follow-up document discussing how to use the "CAL" format.

Question 20: Could use examples of summary pages - Not clear if a separate format is present for each form type.

Answer: There is a single format applicable to all form types. The construction of summary pages is described in detail in the California Electronic Filing Format User’s Guide.

Question 21: Page 29 Intermediary fields - Do these replace the detail (DTL) records in the EFPOC format?

Answer: Yes.

Question 22: A very good feature is the common format for receipts, expenditures, and loans.

Answer: Thank you. We are glad people like it.

Question 23: Cum-Amt1 and Cum-Amt2 - does this replace the Other Cum Amount in old format?

Answer: Yes.

Question 24: What happened to Other Cum Amount Type and the footnote field?

Answer: This is being evaluated to determine if these need to be added to the format definition.

Question 25: CTRB-Self is a new field.

Answer: Yes. If self employed, the "Ctrb_Emp" field contains the name of individual’s employer (their own business).

Question 26: Why can't S496 and S497 use the normal format for expenditure and a contribution?

Answer: When these forms were addressed, we thought of using the RCPT and EXPN layouts. There were too many fields in those layouts that would be unused. This would make the filing format documentation more complex. This led us to define a unique format.

Question 27: Page 40 - P497 format example. Should the value be F497P1 instead of F467P1? Same for F467P2?

Answer: Yes. Thanks for point that out!

Question 28: Is the proposed standard proprietary? It is not based on EFPOC or is not derived from an open standard such as X.12.

Answer: The CAL format is not proprietary by any common definition of the term. It may be used freely by anyone.

The Secretary of State desired to implement X-12, but as a result of the solicitation and proposal process, and timing and budgetary constraints, several issues were identified that precluded inclusion of X-12 at this implementation phase. These issues include the following:

1. The X-12 standard was not approved until after the Vendor Contract was awarded.
2. No vendor was able to provide a solution that included X-12 within the budget allocation provided by the Legislature.
3. The X-12 format is complex and the SOS was concerned that the smaller filer software providers would be unable to successfully implement the format.
4. Third-party software requirements (translators, VANs, etc.) would increase the cost development as well as the cost of filing software for all filers.
5. No other venue or filing software vendor has implemented an X-12 solution for electronic political disclosure. First-time implementations of any type are higher risk, especially given the aggressive schedule of the CLAIMS project.

The CLAIMS system is being designed so that it could be readily modified in the future to accept filings in the X-12 format provided that funding is made available for this effort.

Question 29: We are concerned that the Proposed standard completely disregards the EFPOC process.

Answer: We recognize the efforts put forward by Electronic Filing Proof Of Concept (EFPOC) vendors and also San Francisco in their extension of the EFPOC style filing format definitions to the forms 419 and 420. From the beginning of the CLAIMS project, we planned for the system to support EFPOC style 490 filings. In addition, we are considering support for Forms 405, 419, and 420 in EFPOC format. We are also evaluating the impact of adopting an EFPOC-style filing format for all 33 forms.

An additional option under consideration is to hold a competitive procurement to have a number of filing software vendors interface their software to the CLAIMS system using the "CAL" format.

Question 30: The proposed standard would be unenforceable by Secretary of State. Based on our technical assessment of the proposed standard and based on our knowledge about how the various California disclosure software products store and report their data, we believe an attempt made by the Secretary of State to enforce the proposed specification "as-is" would result in several existing vendors not being able to comply with the proposed format without completely rewriting their systems. Due to the relatively low profit margins in the client side of disclosure software systems, it is very likely that one or two vendors might decide to leave the market rather than spend the money to revise their systems. The proposed standard is also sufficiently complex to make entry of new vendors into the market difficult, if not impossible, under current market conditions.

Answer: Some software modifications may be necessary for some software providers independent of the filing format selected. The SOS is considering a phased approach where groups of forms are certified in stages. Different vendors may only choose to implement a subset of the 33 forms. This will be discussed in further detail at the May 20 conference.

Question 31: The short development cycle is not justification for introducing a proprietary standard.

Answer: This is not a proprietary standard.

Question 32: The proposed standard ignores the use of EFPOC-based formats in San Francisco:

Answer: See question and answer number 29.

Question 33: We disagree with the amendment approach.

Answer: The amendment process has generated much discussion among the project team and the vendor community. This process and alternate processes will be discussed at the May 20 filing conference.

There are arguments for both the transaction identification approach and the change based approach currently included in the CALdescription.

Question 34: The proposed standard tries to force electronic filings to match CLAIMS database layout.

Answer: The CLAIMS database has not been defined since the filing format has not been defined. The filing format and the information contained within the format drive the database layout. The CLAIMS team is using its experience to normalize the data contained within the filing format. Data normalization is a formal technique used by software designers to eliminate undesirable dependencies and create well-structured data. The benefits of normalization include:

• Elimination of redundancy in the data and processing of the data
• Improved enforcement of data integrity
• Reduced development and life-cycle support costs for both the filing software vendors and the State of California

The filing format must be designed for efficient transmission, processing and storage.

Question 35: Will the system support individual filers who choose to manually create their own comma-separated variable files using a tool like Microsoft Excel and then submit them to the system for electronic filing?

Answer: No, SB 49 requires the Secretary of State to… "(b) Accept test files, from software vendors and others wishing to file reports electronically, for the purpose of determining whether the file format is in compliance with the standardized record format developed pursuant to subdivision (a) and is compatible with the Secretary of State's system for receiving the data. A list of software and service providers who have submitted acceptable test files shall be published by the Secretary of State and made available to the public. Acceptably formatted files shall be submitted by a filer in order to meet the requirements of this chapter."

Question 36: The proposed standard uses arbitrary means of delimiting name fields.

Answer: See question and answer #13.

Question 37: The proposed standard embeds Form 405 within Forms 419, 420, and 490.

Answer: The proposed CAL format also embeds amendment forms 605 and 690 within the appropriate lobbyist reports.

The archival requirements of electronic filing do not allow for "filings within filings". Each filing is a stand-alone report. When a filer is making an amendment to a F490 report, for example, they are amending the F490 report. The EFPOC file design also recognizes this. The F405 is an explanatory sheet that accompanies the amended F490 report – not the other way around. The CAL design recognizes this fact.

Question 38: On page 5 in Amounts note, the text reads....."Monetary amounts are stored with an "explicit" decimal point" The text should read….. "Monetary amounts are stored with an "implicit" decimal point." This issue is the term Implicit vs. explicit.

Answer: Actually dollar amounts *are* put in the electronic filing with an "explicit" decimal point. If you view the ASCII text, you should actually "see" decimal points. If no decimal points appear, no "implicit" ones are assumed - the dollar amounts are taken as a "whole dollar" amount with no cents.

Question 39: As an experienced and frequent user of the information contained in the campaign disclosure statements, I am curious as to the progress made and the availability of information online for the 2000 primary.

Answer: We plan to have the electronic filing history of all filings contained in the State’s current system available as well as the actual filings made in the 1^st Pre-Election filing in January of 2000. We do not anticipate keying in data from pre-2000 year filings; such data will still need to be researched at the PRD’s public counter. The first lobbyist electronic filing is expected to be on May 1, 2000.

Question 40: I would like to know if the users may select various fields for reporting options. For example, can I select just the name and amount of all contributions received by a candidate instead of the additional information such as address or employer?

Answer: The option of reducing the amount of information displayed will be considered by the project team in the development of the disclosure web pages. We will solicit user input when we design our web page layouts and search capabilities.

Question 41: On the Expenditure Schedules, the heading indicates that the layout is for Schedules E, F & G, but I don't see any fields which would reference a G record back to an E or F record. What am I missing?

Answer: This was an area of differing opinions in the EFPOC project. We are considering adding this linkage to the "CAL" format.