After Jan. 1, 2012, candidates can pay campaign treasurers up to $1,000 from surplus campaign funds, as opposed to returning the surplus funds to the Citizens' Election Fund. The State Elections Enforcement Commission investigated the candidate committee of Brenda Kupchik, a 2010 candidate for the 132nd General Assembly district. Bank statements indicated that $459 in surplus funds that remained in the candidate committee's bank account on March 1, 2011 were withdrawn on July 12, 2011. The candidate indicated that after the election she orally agreed to pay the respondent campaign treasurer, Michael Hahn, $450 for his work as campaign treasurer. The State Elections Enforcement Commission found that the treasurer was required to distribute any surplus on or before Jan. 31, 2011, pursuant to the then effective requirements in Connecticut General Statutes §9-608(e)(1). In a previous decision, the State Elections Enforcement Commission found that absent a written contract a treasurer is not entitled to payment from the candidate committee, after the election. In response, the legislature amended the statute, effective Jan. 1, 2012, to permit a treasurer to receive up to $1,000 for the treasurer's services. "Because the underlying election here occurred in November 2010," wrote the State Elections Enforcement Commission, "the statutory change allowing such payments in 2012 elections would not apply to this payment." The State Elections Enforcement Commission ordered the treasurer to forward the surplus funds of $459 to the Citizen's Election Fund and to comply with requirements in C.G.S. §9-608(e) in the future.