Mr. HUNT. Originally this report was required annually. Then monthly. Now it is required weekly. And to furnish the information weekly, we must compile a daily worksheet.

This places a considerable burden on our small office staff.

We can understand why a monthly report might be of value. We do not believe that weekly trends can be of great importance. The additional work of compiling this information on a weekly basis in Washington must be tremendous.

We question if the result is worth the effort and the expense. My reason for contacting Congressman O'Brien was to request that more thought be given to the necessity and the value of reports required by various governmental agencies before they are requested.

This committee is only concerned with Government reports. But we are also faced with a heavy similar demand from the State of New York and the combination has created a heavy burden.

Thank you.

Mr. OLSEN. Thank you very much, Mr. Hunt.

I think you point up one item to me, that the citizen doesn't know and the businessmen don't know which of the reports are actually required to be filled out and which are just voluntary. We get the idea that they are all required and that we have no election as to how often they are to be made.

The weekly report I think is a voluntary report. We could just as well elect to only comply with it once a month, or once a quarter. But that isn't made clear to the citizen, is it?

Mr. HUNT. Congressman, if I might say in the notification we had from the Bureau of the Census, it said in one part, and I am very sorry I didn't bring the letter, this report is authorized by law. Not being a lawyer, that I won't say frightens me but I would say I think I had better do it.

Mr. OLSEN. I can understand that. Then it is confused with the fact that on some of the forms it says that this form is required by law and people get the idea that they have to meticulously take care of every single one.

Mr. HUNT. In a small organization as ours it is a question of either hiring more help or working overtime, and it is costly. It is a burden. It really is. Not just this report but some of the other reports. Mr. OLSEN. Mr. Corcoran, do we have a copy of that?

Mr. CORCORAN. I do not have a copy with me, Mr. Chairman, but I know the report.

Mr. HUNT. The census report I referred to?
Mr. CORCORAN. The weekly sales report.

Mr. HUNT. This book is sent to us by the Department of Commerce, Bureau of the Census. This we have to keep up daily. There aren't many lines but you have to look at an awful lot of places to get the figures daily. And this is returned weekly. At the end of the year, on the last form, it states that we will send "Mail the entire pad to the Census regional office along with the completed report" at the end of the year.

Mr. JOHANSEN. May I interrupt, right at this point, to ask about the language you used. You say, "We have to do it." I understand technically it is voluntary. But if you elect to cooperate, then you have to do these things in order to fulfill your cooperative intention. Is that right?

Mr. HUNT. That is right, Congressman, except when, at least when I receive a letter saying this report is authorized by law, I feel that I am required to do it, that I must do it. Perhaps it is the phraseology of the letter that I misinterpreted. That is the way it sounded to

me.

Mr. JOHANSEN. Can the witness say whether he has any knowledge as to the use of this data that is thus collected?

Mr. HUNT. I can only assume that the Department of Commerce is establishing trends in the retail automobile business in this particular

case.

Mr. OLSEN. Wouldn't the General feel that if this is a voluntary thing, then the best that Census can claim is that they are getting a fragmentary report? I hesitate to say this, but some bureaucrat will think I am advocating it be made compulsory, which I want the record to show that I am not. But if it is a voluntary thing, then isn't it by nature fragmentary?

Mr. HUNT. Yes, I would agree with you. Not only fragmentary but I don't believe that weekly trends establish very much of any thing. Monthly might. Quarterly would be even better.

Mr. JOHANSEN. Can you indicate for the record over what period of time this thing moved from an annual report to a monthly and then to a weekly? How long did it take the bureaucracy to do that? Mr. HUNT. May I ask my office manager one question?

Mr. OLSEN. Surely.

Would the gentleman identify himself for the record?

Mr. MARONEY. I am Edward Maroney, office manager for Mohawk Chevrolet Co., Inc.

I would say approximately as far as the change, about 6 years ago it was on an annual reporting basis. Then about, I would say, 4 years ago, they went to a monthly basis on this particular report, and they also at that time had another report in the Census Department based on the amount of your accounts receivable at the end of each month. And if you wrote a financial paper, how much installment contracts you would have out.

Mr. JOHANSEN. This was completely new and separate?

Mr. MARONEY. That is right, sir. Then they still required the annual summary, even with this monthly report on sales that we filled out each month and sent to Boston, they still at the end of the year required another report that I believe was sent to Jeffersonville, Ind. Mr. JOHANSEN. Required or requested?

Mr. MARONEY. I don't say that.

Mr. JOHANSEN. In other words if you were compiling voluntarily. in order to comply you provided it. I think the hesitation of the witness illustrates the confusion, Mr. Chairman, in the minds of the public.

Mr. OLSEN. I think you are correct.

Mr. JOHANSEN. Which is critical certainly not of the witness but of the system.

Mr. OLSEN. Let me say at this point, without objection, a copy of that form will be inserted in the record at the place where Mr. Hunt first referred to it, so we will have the record clear.

For the clarification of the witness, and not in any way critical of the witness, let me say that unless the forms of the Bureau of the

Census recite a penalty for failure to comply, unless those words are there, it actually isn't required by law.

It is a situation where this service is provided by the Bureau of the Census to industry and is only accurate if the industry cooperates. Mr. MARONEY. That is right.

Mr. HUNT. Mr. Johansen pointed out that these fragmentary reports can't be too valuable because they don't cover the entire industry. If they pick out Schenectady, and certainly I am not being picked on so much, and if they don't get it from Albany, Troy, or Utica, it doesn't mean much.

Mr. JOHANSEN. May I ask if your industry or any of your industry associations collect data of this type on a voluntary basis? Mr. HUNT. For the census?

Mr. JOHANSEN. No, for the industry?

Mr. HUNT. We file a monthly statement and we file 10-day reports as to our sales, with General Motors Corp. in our case.

Mr. JOHANSEN. The reason for asking that is whether there is by private enterprise a collection of data which could at the central point of collection then be turned over to the Government?

Mr. HUNT. I think you have a good point, there, Congressman. Mr. JOHANSEN. And thereby avoid duplication in this instance between private enterprise and Government.

Mr. HUNT. Also the various automobile dealer associations throughout the United States would have a lot of that information. Mr. JOHANSEN. Exactly the type of thing I had in mind.

Mr. MARONEY. I think, Congressman, on that question, there is an association in Washington-the National Automobile Dealers Association-which requests compiling every quarter merely of your sales in number. There is no notation as to the name of the dealership or anything of that nature-the sales, your various expenses, how much you have been paying out in wages, and your costs of sales. They use that as a basis for sending back the dealership every quarter a trend of dealerships of that size.

Mr. JOHANSEN. It would be interesting, Mr. Chairman, to determine whether NADA had promoted this activity by the Census Bureau. Mr. OLSEN. I think we will find that that is the fact when we get back to Washington and the Bureau of the Census testifies. I think your National Automobile Dealers Association probably requested that this be done.

Let me say, too, because you mentioned the fact that your NADA doesn't require the name of the dealership, there isn't any more confidential organization than the Bureau of the Census. I must say that. They have been protecting the confidentiality of reports absolutely. Do you have anything further?

Mr. HUNT. No, sir.

Mr. OLSEN. Mr. O'Brien?

Mr. O'BRIEN. I want to thank General Hunt because I know of the inconvenience involved in his coming here this morning. He cut short a trip that is very important to him.

I think, Mr. Chairman, that we have here a rather striking example of where the law-abiding citizen, anxious to do the right thing, perhaps overanxious, not a large corporation where the legal department would probably get the form and say you don't have to answer if

you don't

want to, but here it read "Authorized by law." As far as he is concerned that is the law.

Mr. JOHANSEN. That is an ominous phrase.

Mr. O'BRIEN. I don't know why the Census Bureau has to do this sort of thing. Why couldn't they say it is voluntary. That is a common English word.

Mr. JOHANSEN. Authorized by law, but voluntary.

Mr. O'BRIEN. I think perhaps we are discovering this morning that in addition to the mandate of mountains that they are creating some mountains allegedly voluntary that the public doesn't know are voluntary.

Mr. OLSEN. That is a correct observation. Thank you very much, Mr. Hunt, for coming here and helping us.

Mr. HUNT. Thank you, gentlemen, very much. Thank you, Congressmen. I appreciate it very much.

Mr. OLSEN. The next witnesses is Mr. Henry Miller and Mrs. Dorothy DiPace of the Capital District Retail Grocers Association.

Will you please step forward and proceed in your own fashion?

STATEMENT OF HENRY MILLER AND MRS. DOROTHY DiPACE, CAPITAL DISTRICT RETAIL GROCERS ASSOCIATION, ALBANY, N.Y.

Mr. MILLER. Mr. Chairman, I don't have a prepared statement. Mr. OLSEN. That is all right. We will hear you any way you want to testify.

Mr. MILLER. I am not representing the association, as such. We do our own paperwork. This is the Grocers Association. I don't think our paperwork is as heavy now as some of the other industries, but the only thought that I have in mind this morning would be that instead of requiring quarterly reports, they could be converted to an annual basis.

I am thinking of the withholding taxes and all the other social security matters. I think it would save the Government a lot of money. time, and effort, if they got the information at the end of the year. can't see the magic of the quarterly report as opposed to the weekly or monthly.

If you had one report to make out at the end of the year, it would simplify our job, and certainly the Government's. I am not suggest ing that the payments not be made on the same basis as they are now. But the preparation of the entire report could be made annually and it would reduce our paperwork quite a bit.

Mr. OLSEN. You have made a very interesting and correct observation, Mr. Miller. We have already had some contact with the Internal Revenue Service to the effect that form 941 should be annual. We will be talking with them further in Washington this month and next month.

Mr. MILLER. That is the only observation I have at this time. Mr. OLSEN. Thank you very much. Any questions, Mr. Johansen! Mr. JOHANSEN. I have none.

Mr. OLSEN. Mr. O'Brien?

Mr. O'BRIEN. I have none.

Mr. OLSEN. Thank you very much, Mr. Miller.

The next witness is Mr. Clifford Allanson.

STATEMENT OF CLIFFORD A. ALLANSON, EXECUTIVE DIRECTOR OF
THE NEW YORK STATE COUNCIL OF RETAIL MERCHANTS

Mr. ALLANSON. My name is Clifford A. Allanson. I am executive director of the New York State Council of Retail Merchants, a voluntary membership association of retail stores, with members operating approximately 5,000 stores in some 400 communities in New York ing State.

Mr. JOHANSEN. Do you have any objection to stating how many members you have?

Mr. ALLANSON. I wouldn't have any objection except I am never quite sure. This varies from day to day. The dues checks which I receive cover as near an estimate as possible as I gave you in terms of numbers of stores. The numbers of dues checks would be a little less than half of that number, individual checks.

Mr. JOHANSEN. The memberships are stores rather than individuals?

Mr. ALLANSON. The memberships are stores, or groups of stores. I am not going to make a detailed statement to the committee this morning because we are just engaging in a study in depth in cooperation with the committee that has been appointed by Governor Rockefeller from among the State agencies and which will include this entire subject matter of paperwork and of inspections and duplications at both the State and Federal levels.

Rather than attempt to give you a partial statement of this sort, when we expect to have a comprehensive report in a matter of a month to 6 weeks and I am quite sure your committee will still be involved in this subject for a longer period than that-we will supply you a complete copy of our reports as soon as they become available, which I trust will be helpful.

I would like to comment on a couple of items. One is that I think in this matter of becoming involved in paperwork, you also necessarily become involved in the problems of interlocking and overlapping programs between Federal and State jurisdictions.

I would suggest, for example, the work of the Federal Trade Commission, which is steadily broadened and which reaches into many areas, and, specifically, we have this matter of advertising with relation to fraud, misstatements, and so on, where we have, by State law and by Federal law, many of our stores subject to both jurisdictions. There is no way of determining in advance what is considered legal, but after an advertisement has been inserted, the store advertising may very well be attacked by either State, or Federal jurisdictions, or both. You run into similar problems in this matter of wage jurisdictions because under present laws many of our stores, basically the stores of a million dollars or more in volume are under Federal jurisdiction.

Other stores are under State jurisdiction. Actually, at the present time, some of our larger institutions have a number of areas of employment which are under State jurisdiction, although, in total, they are Federal jurisdiction.

They also, of course, have branch stores which may be under State jurisdiction as opposed to an overall determination under Federal jurisdiction.