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( 2 ) The check McDougal enclosed with his letter to Mr. Campbell is a Whitewater Development Corporation check dated November 7, 1985. The loan number referenced on the memo portion of the check is "Note #975-585." According to the check ledgers for the Whitewater Development Corporation (WDC), the corporation's checking account had the following balances: $189.50 on 10-10-85; and, $12.49 on 10-31-85. However, in order to cover the payment of $7,322.42 on the Clinton loan, a deposit is recorded on November 8, 1985 in the amount of $7,500.00. The deposit is listed as coming from "Madison Marketing." A 1986 Federal Home Loan Bank Board exam gives the impression that Madison Marketing was largely a sham corporation used to divert federally insured resources to insiders. The exam notes that "Until 1986, Susan McDougal owned Madison Marketing." The report also states the following: "Madison Marketing is paid for doing all the general advertising for Madison Guaranty and most of the advertising for Madison Financial's land development projects. All of Madison Marketing's business is derived from Madison Guaranty or its subsidiaries. Since 1983 these payments total $1,532,000." "Given the evidence of Madison Marketing's invoices, it is questionable how much of these advertising services are actually performed by the firm. The actual work ... appears to be performed by others. It would appear that Madison Guaranty could have an employee perform similar work for much less money." "Mr. Latham [an officer of Madison] stated that Madison Marketing made no payments to any stockholders. This statement is false. As part of a test for such payments, the examiners discovered two remittances from Madison Marketing to Susan McDougal [a large stockholder of Madison] which total $50,000. This was a test, and there may be additional payments." CONCLUSION Given the above circumstances, it would appear that federally insured deposits (i.e., funds from Madison Guaranty through Madison Marketing), which, with the later failure of Madison became, in effect, taxpayer obligations, were transferred for the direct personal benefit of the former Governor. The above payment also raises the question of whether Whitewater

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    "ocrText": "( 2 )\nThe check McDougal enclosed with his letter to Mr. Campbell\nis a Whitewater Development Corporation check dated November\n7, 1985. The loan number referenced on the memo portion of\nthe check is \"Note #975-585.\"\nAccording to the check ledgers for the Whitewater\nDevelopment Corporation (WDC), the corporation's checking\naccount had the following balances: $189.50 on 10-10-85;\nand, $12.49 on 10-31-85. However, in order to cover the\npayment of $7,322.42 on the Clinton loan, a deposit is\nrecorded on November 8, 1985 in the amount of $7,500.00.\nThe deposit is listed as coming from \"Madison Marketing.\"\nA 1986 Federal Home Loan Bank Board exam gives the\nimpression that Madison Marketing was largely a sham\ncorporation used to divert federally insured resources to\ninsiders. The exam notes that \"Until 1986, Susan McDougal\nowned Madison Marketing.\" The report also states the\nfollowing:\n\"Madison Marketing is paid for doing all the general\nadvertising for Madison Guaranty and most of the\nadvertising for Madison Financial's land development\nprojects. All of Madison Marketing's business is\nderived from Madison Guaranty or its subsidiaries.\nSince 1983 these payments total $1,532,000.\"\n\"Given the evidence of Madison Marketing's invoices, it\nis questionable how much of these advertising services\nare actually performed by the firm. The actual work\n...\nappears to be performed by others. It would appear\nthat Madison Guaranty could have an employee perform\nsimilar work for much less money.\"\n\"Mr. Latham [an officer of Madison] stated that Madison\nMarketing made no payments to any stockholders. This\nstatement is false. As part of a test for such\npayments, the examiners discovered two remittances from\nMadison Marketing to Susan McDougal [a large\nstockholder of Madison] which total $50,000. This was\na test, and there may be additional payments.\"\nCONCLUSION\nGiven the above circumstances, it would appear that federally\ninsured deposits (i.e., funds from Madison Guaranty through\nMadison Marketing), which, with the later failure of Madison\nbecame, in effect, taxpayer obligations, were transferred for the\ndirect personal benefit of the former Governor.\nThe above payment also raises the question of whether Whitewater"
}