MICHAEL B. TRISTER 

 (1941-2018) _____________________

GAIL E. ROSS

B. HOLLY SCHADLER 

LAURENCE E. GOLD 

ALLEN H. MATTISON 

DAVID M. WACHTEL

JESSICA ROBINSON

KAREN A. POST 

ELIZABETH A. GROSSMAN

PHILIP R. EAGER

Of Counsel 

JOSEPH W. STEINBERG

SARAH E. NASON 

JOHN O. SAWYKO

RENATA E. B. STRAUSE

LAW OFFICES

Trister, Ross, Schadler & Gold, PLLC

1666 CONNECTICUT AVENUE, N.W., FIFTH FLOOR 

WASHINGTON, D.C. 20009

PHONE: (202) 328-1666

FAX: (202) 204-5946

www.tristerross.com

January 25, 2023 

Danya C. Brown

Assistant Staff Director

Audit Division

Federal Election Commission

1050 First Street, NE 

Washington, DC 20463 

 Re: Interim Audit Report 

 CWA COPE PCC

Dear Ms. Brown: 

 We are writing in response to your December 8 letter and the Interim Audit Report of the Audit 

Division resulting from the audit of Communications Workers of America – COPE Political Contributions 

Committee (the “Committee”). 

The Committee will comply with the recommendation of the Audit Division staff to address 

Finding 1 by amending its reports to correct the cash on hand balance. The Committee intends to disclose 

the adjustment to the cash on hand balance and provide an explanation of the change on an amended May 

2022 Monthly Report. The Committee will also file amended monthly and pre- and post-election reports 

for the remainder of 2022 to comply with the further recommendation to identify any subsequent 

discrepancies that may affect this adjustment and to carry the corrected balance forward. The Committee 

has communicated with Audit Division staff regarding how to properly disclose the recommended 

adjustment to cash on hand balance and anticipates filing the amendments shortly after that information is 

provided. 

The Committee will also comply with the recommendation to address Finding 2 by disclosing the 

additional occupation and name of employer information that CWA has obtained for contributions made 

during the audit period. The Committee intends to comply with the recommendation by filing one or more 

Form 99 (Miscellaneous Electronic Submission) responses in the near future. The Committee anticipates 

that the response will be large enough that it may need to be broken into multiple filings. However, 

because Form 99 unfortunately cannot accommodate filing information in any format other than a text file, 

the Committee may need to submit the required information instead by filing an amended Schedule A on a 

future regularly-scheduled disclosure report or by amending its 2019-2020 disclosure reports, as provided 

in the recommendation. 
2

With respect to the contributions for which the Committee was neither able to provide the Audit 

Division with adequate occupation or employer information nor provide documentation demonstrating that 

“best efforts” were made in a timely manner, the Committee’s efforts to locate missing occupation and 

employer information for contributors are ongoing. As a result, the Committee anticipates that its filings 

in response to the recommendations may disclose information for contributors beyond those which the 

Committee provided to the Audit Division in the course of the audit. The Committee also notes that in 

addition to the modifications to its procedures for documenting “best efforts” summarized in the Interim 

Audit Report, it is in the process of reviewing its internal procedures for recording and reviewing 

occupation and employer information when payroll deduction contributions are authorized initially. The 

Committee expects that these combined efforts will yield significant improvements in the completeness of 

its contribution records in reports filed after the audit period.

Thank you for your consideration.

Yours truly,

Laurence E. Gold

Renata E. B. Strause

Counsel to CWA COPE PCC

cc: Sara Steffens, Treasurer