Republican Party of Minnesota

 

 7400 Metro BLVD, Suite 424 · Edina, MN 55439

 Office: 651-222-0022 · Fax: 651-224-4122 · Web: www.mngop.com

 

Paid for by the Republican Party of Minnesota. Not authorized by any candidate or candidate’s 

committee. www.mngop.com

6-24-21

RPM response to the FEC audit of the 2017-2018 election cycle:

1. Finding 1-Recordkeeping for Employees-11 C.F.R sec 106.7(d)(1)

The Republican Party of Minnesota (RPM) is in the process of implementing a payroll log which will 

document for each payroll period (currently bi-weekly) the major tasks/projects (in hours) performed by 

RPM employees spending time on both federal and/or non-federal (Minnesota Campaign Finance and 

Public Disclosure Board) activities. The RPM job descriptions with respect to the $297,945 in payroll 

costs reported by FEC audit staff do clearly state that such are involved principally in non-federal 

activities, have been reported as such and in fact are non-federal activities.

2. Finding 2-Recordkeeping for Communications – 52 U.S.C 30102(d) and 11 C.F.R. 104.14(b)(I)

The RPM relies on third party entities for the production and dissemination of the referenced media 

pieces, web advertisements, etc... Unfortunately, they were not able to provide all the media requested. 

The RPM also relies on affiliated committees for the approval and production of some of these media 

pieces. The RPM located many of the missing media pieces and were submitted to the audit team in a 

previous response.

3. Finding 3-Reporting of Apparent Independent Expenditures – 52 U.S.C. 3014(b) and 11 C.F.R. 

100.87(a), (b), (c), (d), (e) and (g)

Apparent Independent Expenditures – the Direct Mail, Telemarketing and Email expenditures 

referenced were all general party building fundraising for the committee’s general fund. The letters and 

scripts contained multi-candidate references and did not advocate or oppose one single candidate. The 

RPM’s response and copies of the letters and scripts were submitted to the audit team in a previous 

response.

Exempt activity volunteer material exemption – With the exception of four Targeted Creative invoices 

referenced where we unable to locate related media, the other items were either general party 

fundraising, voter list purchase, a candidate reimbursement, a non-candidate printed fan or paid GOTV 

calls. The RPM’s response and copies of the letters and media were submitted to the audit team in a 

previous response.

4. Finding 4-Disclosure of Transfers and Allocation Ratios 11 C.F.R. Sec 102,5(1)(1)(i) and 106.7 (d) (2)-(4)

Disclosure of transfers to affiliated and other party committees – the two transfers referenced were 

inadvertently disclosed incorrectly on Schedule H4. They should have each been disclosed on Schedule 

B, Line 22 as these transfers did not qualify as allocable activity. 

Disclosure of allocation ratios – the ratios for the two fundraisers referenced were incorrectly reported 

with the administration allocation applied on Schedule H4. These two fundraisers should have been 

disclosed on Schedule H2 with the funds raised allocation applied. For the March 23, 2017 Lincoln 

Reagan dinner, the allocation ratios should have been 60% federal and 40% state. For the April 13, 2018 
 

 Republican Party of Minnesota

 

 7400 Metro BLVD, Suite 424 · Edina, MN 55439

 Office: 651-222-0022 · Fax: 651-224-4122 · Web: www.mngop.com

 

Paid for by the Republican Party of Minnesota. Not authorized by any candidate or candidate’s 

committee. www.mngop.com

Lincoln Reagan dinner, the allocation ratios should have been 85% federal and 15% state. Both should 

have been disclosed on Schedule H2. A form 99 response and a corrected Schedule H2 has been filed to 

clarify and correct it.

5. Finding 5-Excessive coordinated party expenditures 11 C.F.R 109.32(b)

The media pieces referenced were non-allocable volunteer driven mail. It is the RPM’s understanding if 

there is a volunteer component, the expenditure does not count as a contribution to the candidate. The 

volunteer documentation was submitted to the audit team in a previous response.

6. Finding 6-Disclosure of Loans and Loan Repayments 52 U.S.C Sec 20104(b)

Regarding the incorrect reporting of RPM bank note (loan) details in terms of: maturity date of notes, 

interest rates, collateral, note date, the RPM as noted in correspondence to the FEC and in various 

memoranda to the RPM’s FEC analyst, the RPM’s FEC reporting software had a significant, and at the 

time, unsolved issue in this area. While we knew on each monthly filing as indicated to the FEC auditors 

that certain loan disclosures were not accurate and despite attempting to obtain corrected fields from 

our FEC filing software package, we were not successful from approximately May of 2017 through 

November of 2018. It should be noted that all loan dollar activity in terms of loan advances, loan 

payments, interest expense paid, and end of the reporting period loan balances were accurate in our 

filed FEC reports. Miscellaneous form 99 responses have been filed stating the correct interest rate, 

incur date, due date, period beginning and ending note balances and the secured checked box as well as 

a digital Schedule C-1 with the bank address and authorized bank representative’s name and electronic 

signature.