U.S. News & World Report: Cruz Financed 2012 Campaign With Loans from Goldman Sachs, Citibank

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But Larry Noble, general counsel at the nonpartisan Campaign Legal Center, said the failure to report the loans is illegal, and not subject to interpretation. 

"It's a failure to report. It's not a question of semantics. It's a question of law," Noble says. "You have to report all loans, that includes a loan the candidate takes out ... for his committee."

The violation is not necessarily a one-time thing, either, Noble says, since the loans needed to be continuously reported. "As long as it's outstanding, it has to be reported as debt," Noble says. 

Noble says the FEC "should investigate" that matter. Civil penalties depend on the circumstances, but could be as high as the amount of the loan itself, Noble explains. And the FEC looks less kindly on candidates who do not report such errors themselves before "it hits the news," he adds.

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