Oregon State University Alumni Association, Inc. - Page 11

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          rather than to USNB so that he could make sure that they were               
          processed faster.  Petitioner contacted USNB to request that                
          credit limits higher than the standard be set for certain alumni.           
          In about 14 letters sent to individual alumni, Wirth suggested              
          that the alumnus contact him or petitioner if the alumnus needed            
          further assistance.                                                         
               3.   Involvement of Petitioner's Executive Director in the             
                    Affinity Credit Card Program                                      
               Wirth met with USNB and a representative from the AAUO once            
          each year to review the performance of the affinity credit card             
          program.  These meetings lasted about 1� to 2 hours.  Petitioner            
          allocated 15 percent of Wirth's salary to the affinity credit               
          card program in 1988 and 1989, and none for the years in issue.             
          Petitioner did not allocate any of its secretary's salary to the            
          affinity credit card program.                                               
               On January 14, 1991, Wirth encouraged each member of                   
          petitioner's board of directors to get 10 new cardholders.  Also            
          on January 14, 1991, Wirth urged board members to look for                  
          opportunities to give out applications for the affinity credit              
          card.                                                                       
          G.   Petitioner's Travel Program                                            
               Petitioner let travel agencies use its mailing list to                 
          arrange trips for alumni in 1988, 1990, and 1991.  Petitioner               
          received a fee for each member who went on a trip.  Petitioner              
          received $2,028 in 1988, $27,446 in 1990, and $14,105 in 1991               




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