Why the Audit 

Was Done 

Federal law permits the 

Commission to conduct 

audits and field 

investigations of any 

political committee that 

is required to file reports 

under the Federal 

Election Campaign Act 

(the Act). The 

Commission generally 

conducts such audits 

when a committee 

appears not to have met 

the threshold 

requirements for 

substantial compliance 

with the Act.1 The audit 

determines whether the 

committee complied with 

the limitations, 

prohibitions and 

disclosure requirements 

of the Act. 

Future Action 

The Commission may 

initiate an enforcement 

action, at a later time, 

with respect to any of the 

matter discussed in this 

report. 

Final Audit Report of the 

Commission on the Grassroots 

Victory PAC 

(January 1, 2017 - December 31, 2018) 

About the Committee (p. 2) 

The Grassroots Victory PAC is a non-qualified, non-connected 

political action committee headquartered in Washington, DC. For 

more information, see the chart on the Committee Organization p. 

2. 

Financial Activity (p. 2) 

• Receipts 

o Contributions from Individuals $ 612,987 

o Contributions from Other 

Political Committees 5,000 

o Offset to Operating 

Expenditures 26 

Total Receipts $ 618,013 

• Disbursements 

o Operating Expenditures $ 36,852 

o Contributions to Federal 

Committees 110,000 

o Independent Expenditures 8,974 

o Contribution Refunds 8,129 

o Other Disbursements 334,999 

Total Disbursements $ 498,954 

Commission Finding (p. 3) 

• Increased Activity (Corrected) 

1 52 U.S.C. §30111(b). 
 

 

Final Audit Report of the 

Commission on the Grassroots 

Victory PAC 

(January 1, 2017 - December 31, 2018) 
Table of Contents 

Page 

Part I. Background 

Authority for Audit 1 

Scope of Audit 1 

Audit Hearing 1 

Part II. Overview of Committee 

Committee Organization 2 

Overview of Financial Activity 2 

Part III. Summary 

Commission Finding 3 

Part IV. Commission Finding 

Increased Activity (Corrected) 4 
 

 

 

 

 

1 

Part I 

Background 

Authority for Audit 

This report is based on an audit of the Grassroots Victory PAC (GVP), undertaken by the Audit 

Division of the Federal Election Commission (the Commission) in accordance with the Federal 

Election Campaign Act of 1971, as amended (the Act). The Audit Division conducted the audit 

pursuant to 52 U.S.C. §30111(b), which permits the Commission to conduct audits and field 

investigations of any political committee that is required to file a report under 52 U.S.C. §30104. 

Prior to conducting any audit under this subsection, the Commission must perform an internal 

review of reports filed by selected committees to determine if the reports filed by a particular 

committee meet the threshold requirements for substantial compliance with the Act. 52 U.S.C. 

§30111(b). 

Scope of Audit 

Following Commission-approved procedures, the Audit staff evaluated various risk factors and 

as a result, this audit examined 

1. the disclosure of individual contributors’ occupation and name of employer; 

2. the consistency between reported figures and bank records; 

3. the completeness of records; and 

4. other committee operations necessary to the review. 

Audit Hearing 

GVP requested a hearing before the Commission. The request was granted and the hearing was 

held on January 28, 2021. At the hearing, GVP requested that the title of the finding be changed 

to remove “Misstatement of Financial Activity.” (For more detail, see Audit Hearing at 

Increased Activity (Corrected) p. 6) 
 

2 

Part II 

Overview of Committee 

Committee Organization 

Important Dates 

• Date of Registration February 8, 2016 

• Audit Coverage January 1, 2017 - December 31, 2018 

Headquarters Washington, DC 

Bank Information 

• Bank Depositories One 

• Bank Accounts One checking account 

Treasurer 

• Treasurer When Audit Was Conducted Eleanor Collinson 

• Treasurer During Period Covered by Audit Eleanor Collinson (5/17/18-Present), 

Shelbi Warner (2/8/16-5/16/18) 

Management Information 

• Attended FEC Campaign Finance Seminar Yes 

• Who Handled Accounting and 

Recordkeeping Tasks 

Paid Staff 

Overview of Financial Activity 

(Audited Amounts) 

Cash on hand @ January 1, 2017 $ 28,409 

Receipts 

o Contributions from Individuals 612,987 

o Contributions from Other Political 

Committees 5,000 

o Offsets to Operating Expenditures 26 

Total Receipts $ 618,013 

Disbursements 

o Operating Expenditures 36,852 

o Contributions to Federal Committees 110,000 

o Independent Expenditures 8,974 

o Contribution Refunds 8,129 

o Other Disbursements 334,999 

Total Disbursements $ 498,954 

Cash on hand @ December 31, 2018 $ 147,468 
 

 

 

 

 

 

 

 

 

 

3 

Part III 

Summary 

Commission Finding 

Increased Activity (Corrected) 

A comparison of GVP’s bank activity with its original disclosure reports filed with the 

Commission revealed that disbursements were understated by $106,674 for calendar 

years 2017 and 2018. In response to the Interim Audit Report recommendation, GVP 

stated that the audit report should be modified to reflect that the disclosure reports on file 

when the audit began accurately presented its financial activity. 

In response to the Draft Final Audit Report, GVP reiterated that it identified undisclosed 

disbursements and amended its disclosure reports in August 2018, and indicated that the 

finding was unwarranted since GVP corrected its disclosure reports prior to the audit 

notification letter. GVP requested a hearing before the Commission to discuss this 

matter. (For more detail, see Audit Hearing, p. 6.) 

The Commission approved a finding that GVP understated disbursements by $106,674 on 

the original disclosure reports filed over the two-year period ending on December 31, 

2018, and changed the finding title from “Misstatement of Financial Activity – Increased 

Activity” to “Increased Activity (Corrected).” (For more detail, see p. 4) 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

4 

Part IV 

Commission Finding 

Increased Activity (Corrected) 

Summary 

A comparison of GVP’s bank activity with its original disclosure reports filed with the 

Commission revealed that disbursements were understated by $106,674 for calendar 

years 2017 and 2018. In response to the Interim Audit Report recommendation, GVP 

stated that the audit report should be modified to reflect that the disclosure reports on file 

when the audit began accurately presented its financial activity. 

In response to the Draft Final Audit Report, GVP reiterated that it identified undisclosed 

disbursements and amended its disclosure reports in August 2018, and indicated that the 

finding was unwarranted since GVP corrected its disclosure reports prior to the audit 

notification letter. GVP requested a hearing before the Commission to discuss this 

matter. 

The Commission approved a finding that GVP understated disbursements by $106,674 on 

the original disclosure reports filed over the two-year period ending on December 31, 

2018, and changed the finding title from “Misstatement of Financial Activity – Increased 

Activity” to “Increased Activity (Corrected).” 

Legal Standard 

A. Reporting Requirements. All political committees other than authorized 

committees of a candidate shall file either: 

• Quarterly reports. 52 U.S.C. § 30104(a)(4)(A); or 

• Monthly reports in all calendar years shall be filed no later than the 20th day after 

the last day of the month and shall be complete as of the last day of the month, 

except that, in lieu of filing the reports otherwise due in November and December 

of any year in which a regularly scheduled general election is held, a pre-general 

election report shall be filed in accordance with 52 U.S.C. § 30104(2)(A)(i), a 

post-general election report shall be filed in accordance with 52 U.S.C. § 

30104(2)(A)(ii), and a year-end report shall be filed no later than January 31 of 

the following calendar year. 52 U.S.C. §30104(a)(4)(B). 

B. Contents of Reports. Each report must disclose: 

• The amount of cash on hand at the beginning and end of the reporting period; 

• The total amount of receipts for the reporting period and for the calendar year; 

• The total amount of disbursements for the reporting period and for the calendar 

year; and 

• Certain transactions that require itemization on Schedule A (Itemized Receipts) or 

Schedule B (Itemized Disbursements). 52 U.S.C. §30104 (b)(1),(2),(3),(4) and 

(5). 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

5 

Facts and Analysis 

A. Facts 

During audit fieldwork, in addition to examining GVP’s most recent reports filed prior to 

the audit notification, the Audit staff compared GVP’s originally filed reports with its 

bank records. The purpose of this additional reconciliation was to identify the degree to 

which GVP had misstated its original filings. 

The Audit staff calculated that GVP understated its disbursements by $106,674 on the 

original reports filed over the two-year period ending December 31, 2018. Most of the 

understatement ($98,342) was due to GVP not reporting any disbursements from May 

2017 through November 2017. GVP subsequently amended its reports to disclose the 

disbursements that took place during this time. 

B. Interim Audit Report & Audit Division Recommendation 

The Audit staff discussed this matter with GVP representatives during the exit conference 

and provided the relevant schedule. In response to the exit conference, GVP stated that 

the finding confirms that it had unreported disbursements for calendar years 2017 and 

2018. GVP further stated that it made proactive efforts, prior to Commission action, to 

correct the public record by amending its reports in August 2018 to disclose the 

unreported disbursements. GVP also stated that it is unclear why the Audit staff 

compared its bank activity to its original reports given that GVP amended its reports in 

August 2018. As noted above, the Audit staff compared GVP’s original reports to its 

bank records to identify the degree to which GVP misstated the activity disclosed on its 

original filings. GVP underreported its disbursements by $106,674 between the time the 

original reports were filed on or near their respective due dates and when the amendments 

were filed in August 2018. 

The Interim Audit Report recommended that GVP provide any additional comments it 

deemed necessary with respect to this matter. 

C. Committee Response to Interim Audit Report 

In response to the Interim Audit Report recommendation, GVP stated the auditors found 

no new information that it had not already disclosed to the Commission. According to 

GVP, it was not the audit that “revealed” GVP understated its disbursements by 

$106,674, it was GVP’s proactive response in August 2018. GVP explained that, in early 

2018 it discovered unreported disbursements for its September, October, and November 

2017 Monthly reports and amended those reports. To discover the source of these 

discrepancies GVP hired a compliance firm to review its past reports and financial 

activities. This review identified additional undisclosed disbursements as well as some 

previously reported contributions and disbursements that required amendment and 

resulted in GVP amending its reports in August 2018. GVP stated that the Interim Audit 

Report did not explain why the Audit staff worked from its original reports rather than its 

amended reports that were on the public record before the audit began. Further, GVP 

stated the Interim Audit Report should be modified to reflect that GVP accurately 
 

 

 

 

 

 

 

 

 

 

6 

disclosed its financial activity on its own volition, through amended reports that preceded 

the audit. 

The Audit staff noted that, as highlighted in the Facts section above, it reviewed GVP’s 

original reports and amended reports during the course of the audit. GVP was correct in 

stating that in August 2018, prior to the October 2019 audit notification, it amended its 

disclosure reports to accurately disclose missing financial activity. However, it was 

GVP’s responsibility to accurately and timely disclose all financial activity on the 

respective due date of the required report. As such, the Audit staff maintained that 

GVP’s original reports understated its disbursements by $106,674. 

D. Draft Final Audit Report 

The Draft Final Audit Report reiterated that GVP’s original disclosure reports materially 

understated its disbursements for 2017 and 2018 by $106,674. 

E. Committee Response to the Draft Final Audit Report 

GVP responded to the Draft Final Audit Report by requesting a hearing on this matter. 

GVP stated it twice asked the Audit staff to explain their choice to work from the original 

reports rather than the amended reports that were on the public record before the audit 

began. GVP stated that it identified undisclosed disbursements and amended its 

disclosure reports in August 2018 and indicated that the finding is unwarranted since 

GVP corrected its disclosure reports prior to the audit notification letter. 

F. Audit Hearing 

During the Audit Hearing, GVP counsel stated that at the time the audit notification letter 

was sent in October 2019, there was no misstatement of its financial activity within its 

filings on the public record because it had corrected its reports on its own volition in 

August 2018. GVP counsel further stated that the title “Misstatement of Financial 

Activity” is misleading because the committee corrected its reported activity. GVP 

counsel requested that the Commission remove “Misstatement of Financial Activity” 

from the title of the finding. 

Commission Conclusion 

On March 11, 2021, the Commission considered the Audit Division Recommendation 

Memorandum finding of “Misstatement of Financial Activity – Increased Activity,” in 

which the Audit Division recommended that the Commission find that GVP understated 

disbursements by $106,674 on the original reports filed over the two-year period ending 

December 31, 2018. 

The Commission approved the Audit staff’s recommendation and changed the title of the 

finding to “Increased Activity (Corrected).”