On Thursday, a private watchdog group, Citizens for Responsibility and Ethics, filed a formal complaint with the Federal Election Commission (FEC) claiming that John McCain violated the Federal Election Campaign Act. This is just one of the newest allegations of misconduct. In particular, the group is outraged that John McCain spent over $150,000 of campaign financing to buy clothes, jewelry and outfits for Sarah Palin and her family. After Alaska Gov. Sarah Palin joined the ticket as his running mate, the RNC and McCain campaign doled out Palin's extravagant expenses, including $75,062 spent at Neiman Marcus in Minneapolis and $41,850 in St. Louis in early September. The committee also reported spending $4,100 for makeup and hair consulting. $150,000 dollars of our money for Palin's wardrobe!

Wait, there's more. Just today, the Democratic National Committee today (DNC) announced that it will file its own complaint with the FEC on Monday morning to request a thorough investigation of the McCain campaign's most recent attempt to skirt campaign finance laws. According to the DNC complaint, an analysis of the information provided by the McCain Campaign on its website shows that the campaign received 6,653 contributions that were at least $1,000 in excess of legal limit of $2,300 -- including one donor who contributed $56,047.

The complaint (pdf) also cites the McCain campaign's pattern of ignoring federal election laws including violating the Presidential Matching Payment Account Act, the campaign's refund of approximately $50,000 in donations solicited by a foreign national, its continuing pattern of soliciting foreign nationals including the Russian Ambassador to the U.N.

If these allegations prove to be true, then McCain's gaming of campaign finance laws also signals that John McCain is part of the corrupt era we are trying to put behind us - and not representative of the new, fairer world we want to create.

Once upon a time, John McCain made a name for himself by fighting for "campaign finance reform." If these allegations have any morsel of truth, the man we see running for the White House today may indeed bear little resemblance anymore to that reformer of long ago. In fact, it might be rightly said that this new McCain we are learning about may have been the real McCain all along.

Some are suggesting that McCain appeared to be in favor of stricter campaign finance laws (pdf) only when he was fighting hard to gain traction in his rise to power. And, that, indeed his complaint was that he did not have as much access to cash as powerhouse candidates like George Bush did. Some say that now that McCain is no longer fighting for power, but is in fact head of the Republican Party - he's no longer concerned about the spirit of the FEC rules. His detractors have pointed to these allegations as proof that McCain seems all too willing to flaunt his disregard for campaign finance rules, as if McCain believes those laws were written for others, but just not him.

I'm not a campaign finance law expert. Nor have I thoroughly examined all the facts. Therefore, I'm not prepared to state that I know that McCain broke the law. Given the corruption in some of the systems, we may never know for sure if McCain is an actual law-breaker.

However, I am prepared to say this - where there's this much smoke, there's usually fire. It's highly likely, given the frequency and details of these reports, that at least some of McCain's "books have been cooked."

In my experience in corporate finance, over the years, I've run across many canny individuals who found ingenious ways to cook their company's books while remaining technically just within a hair of being on the legal side of things. Those kind of people always gave me the creeps. Why?

What's really wrong with book cookers?

First of all, that crawl space of legality may not actually exist. It may be an illusion. When you are operating just one hair away from breaking the law, it's very easy to misjudge the distance between legal and illegal, ethical or unethical, or right and wrong. More often than not, "book cookers" get caught on the wrong side of the thin line.

It's all about gaming the system. To make gain in a less than obvious way, to get away with something. Ultimately, book cookers look for ways to win without following the rules that everybody else expects them to play by.

Booking cooking is destructive. It is a corrosive act that unravels trust. What if everyone on the Interstate Highway system just started driving by their own rules - stopping, turning, driving the opposite way or parking in the middle of the road? That system, just like accounting, only works because everybody knows the rules and everybody is expected to follow the same rules. If each person can make up his or her own set of rules, the system breaks down. People get hurt.

Book cookers are people who pride themselves in their abilities to skirt or outfox regulations. In most cases, book cooking allows the cooks to gain at other innocent parties unknowing expense. Often the stakes are high. That's the driving incentive behind the cooking of books.

That sort of slippery slyness may pay off for the cooks, but, in the end, their actions corrupt our trust and our societal understanding of justice and fairness.

Many times, book cookers avoid any trouble to their consciences by inventing rationalizations about the goodness of their missions. That rationale can go something like this, "Our company does so much good by providing so many widgets to people who have never owned widgets before that it's OK if we hoodwink a few investors and hide a little of our income because we are serving mankind. Just look at all the new widget owners whose lives will be improved." Yet, was this an honest and straightforward rationale of why gaming the system is justifiable? Not hardly. Corporate gamers are usually hot on the trail of power, profits, bonuses or other symbols of victory.

A book cooker in a political campaign might try to float this higher purpose, "It's OK if we slide around these rules and hide this huge contribution or rename those expenditures. The goal here is to get elected because it's good for the people if we are elected! We will accomplish big things like world peace and the spreading of capitalism when we win. Therefore, the semi-sneaky way we slip around the regulations will pale in comparison to all the tremendous good we will do for mankind after the election." All ethical rationalization aside, what's the real truth here? The political gamers, too, are often seeking personal power, greater influence, perks and other symbols of victory. There's nothing wrong with that. Their goals are reasonable. Their methods aren't.

Book cooking often surfaces when organizations are looking for competitive advantage. At those times, when playing by the rules on a flat playing field seems like a no-win proposition, leaders may listen more intently as the book cookers describe accounting methods that might just help the home team score points. When all other methods for winning fairly have been tried, companies and campaigns may resort to questionable and possible illegal accounting designs in desperate attempts to stay in the game.

I've personally known many book cookers. They will often describe their exploits and maneuvers with great detail, hoping to inspire your awe. Book cookers can almost always give interesting and well-reasoned arguments. (Who said all accountants were boring or uncreative?) Indeed, when book cooking game plans are first presented to decision-makers, the pitches can be quite entertaining to watch as the smartest human beings twirl like gymnasts in their own circular but agile arguments and home-cooked rationalizations.

When pressed to do so, book cookers usually point out that while their actions are perhaps technically not within the spirit of the law, they believe their actions might slide in semi-safely under the letter of the law if they are lucky and the stars align just right. And, as a footnote, they'll remind you that it is only the letter of the law that possesses enforcement power. Nothing else need be a concern.

They often are very smart and impressively intelligent people. So clever in fact that they sometimes even outmaneuver themselves. Most people find it fascinating to listen to confident book cookers pitch their designer accounting ideas - especially when they insist that they have airtight understandings of the pertinent regulations, the relevant case law, and prior administrative judgments.

Book cookers expect naysayers to investigate or lob accusations. They've thought about that already. Any well-presented book cooking scheme will include preplanned strategies about how the questionable procedures can be justified to the regulators, inspectors or judges, when the books come under legal scrutiny.

In fact, planning for the eventual legal hurdles is half of the fun for the best book cooking schemers. The close calls of "getting away with it" are the very adrenalin rushes they welcome.

Of course, there's the ever present dark side. Book cookers routinely downplay the magnitude of risks and negative consequences that could be visited upon countless victims, if the schemes were to go awry.

Even when a set of cooked books may not have obvious or direct individual victims, at least some damage to systems or some breakdown of public trust is inevitable.

It is unsettling, disconcerting and jarring to notice that while many book cookers are so full of delight about their own inventiveness, they often also exhibit little to no regard for the possible negative impacts their deceits and deceptions may have on the rights, properties or freedoms of others. It's mainly the smartness of their own rationalizations and the reaching for their coveted gold rings that the cookers impress themselves with, not the long term degradations to our social fabric.

Without any doubt, the book cookers' semi-legal or very-illegal-but-unchallenged actions are essentially destructive as they tear away at and weaken our willingness to work together for common good.

Book cooking has consequences. The violations of trust are often unrepairable. The results can be sometimes be devastating.

That's when the entertaining antics of book cookers cease being fascinating.

Whether it's Enron executives inventing recipes for imaginary contracts and non-existent assets, or Wall Street billionaires passing around half-baked unregulated default swaps, or when it involves presidential candidates creatively concocting campaign finance workarounds - all of these actions are essentially the same.

These are just cunning methods of outsmarting our laws for personal gain. The goals are to avoid scrutiny and just not get caught in wrongdoing - to win the battles, to be the victors, to have more toys, to exercise the greatest power. These are acts fueled by greed or selfishness, carried out with willful disregard for ill effects on others.

If the book cookers are everywhere, what's stopping us from cooking all books, all the time?

Regulators, inspectors and judges will step in from time to time, but their combined reach is inadequate to stop all book cooking that potentially occurs in organizations. Undoubtedly, we need to empower our legal system to make more substantial interventions.

Eventually, the bucks must always stop with the decision-makers at the helms of the companies and organizations. If those decision-makers are paying attention, they can detect improper gaminess and disallow it across the board in their organizations. Alert and ethical leaders can, and will, reject book cooking.

When the system breaks down, it's up to us to hold the errant CEOs and directors (and candidates in charge of campaigns) accountable for their wrong-headed decisions.

Is it more reprehensible for a presidential candidate to cook books than it is a CEO on Wall Street?

Absolutely. Our nation depends on our federal executive branch to enforce laws and rules. Even more so now, we need our president to enforce regulations for Wall Street and to stop the harmful book cooking and risky gaming that has brought our economy to its knees. It's absolutely necessary that we elect the kind of individuals that will stop the fraud and reinstate transparency and trust in our financial systems.

So, if any presidential candidate has shown any willingness to cook his own campaign books, that's a very strong signal to the rest of us. We should read its meaning straightforwardly. Any candidate that can be seduced by cook bookers' rationalizations is also a candidate likely to allow Wall Street to continue running a muck, once he's elected president.

Although McCain has not yet been convicted of a crime and there may not be sufficient political will to conduct a thorough investigation of the facts, I have come to my own conclusions about a couple of things.

First, while I may not know how much free reign McCain has given them or the extent of power McCain lets them wield, I am sure that within McCain's campaign staff, some highly skilled book cookers have his ear.

Second, by watching McCain's campaign frequently operate so close to this unseemly edge between right and wrong, I have become convinced that McCain himself has at least been introduced to the clever ideas of his book cookers even if he may not yet have been thoroughly schooled in their book cooking logic.

John McCain and his campaign finance strategists have traveled along far too close to that edge for my comfort.

Consistently risky and ethically questionable behavior does not qualify as trustworthy.

Not in my book.

Not now, not ever.