Internal Controls and Political Committees 

Under the Federal Election Campaign Act (FECA) and the Commission’s regulations all 

political committees are required to file accurate and complete disclosure reports. A 

system of internal controls can contribute to the accuracy of a committee’s disclosure 

reports. While neither FECA nor the regulations require any particular set of internal 

controls, implementing effective internal controls plays an important role in meeting 

those requirements, since misappropriation of funds or unintentional error generally lead 

to the filing of inaccurate disclosure reports. Conversely, a lack of internal control and 

oversight can create an environment that contributes to misappropriation of funds, a lack 

of concern for the accuracy of committee accounting records, and misreporting to the 

Commission. With respect to misappropriations, in recent years the Commission has 

noticed an increasing number of instances where committee assets are misappropriated, 

generally by committee staff. In most of these cases, the staff person who engaged in the 

misappropriation was a trusted individual who was not properly supervised. There were 

often no systems of internal control in place that provided an independent check on the 

activity of those who process the committee’s transactions. Absent some basic checks 

and balances, some people will inevitably give in to temptation. Finally, a system of 

internal controls, including policies, procedures and budgets, can contribute to the 

efficient and effective use of committee funds. 

As a result, effective internal controls provide the triple benefit of assisting the committee 

in meeting its goals, protecting committee assets, and facilitating the filing of accurate 

disclosure reports. To that end, the Commission has prepared the following best 

practices recommendations. These are not mandatory requirements but are intended to 

assist committees in protecting their assets and complying with the requirements of the 

FECA. 

We have noted that when the issue of internal control is raised with political committees, 

often their representatives’ respond that they are small operations staffed by volunteers 

and can’t afford elaborate systems of controls. It is, however, in the interest of both the 

committee and its staff, volunteer or paid, to establish a system of internal controls that 

will prevent or quickly detect any misappropriation while getting the maximum benefit 

from the funds that are available. The amount of money involved in the political process 

has grown rapidly over the past election cycles and it appears that trend will continue. 

This trend suggests that. as with any business, as the volume of activity grows, the risks 

and the need to control those risks grow with it. 

The responsibility of establishing the necessary control procedures falls to a political 

committee’s treasurer. Internal controls need not be elaborate or expensive to provide 

reasonable assurance that funds will not be misappropriated. Most importantly, costs 

associated with recovery from misappropriations, both monetary and non-monetary, are 

likely to be greater than the cost of prevention. The cost of inefficient use of committee 

resources may not be recoverable. 

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This guide should not be the only resource that is consulted. In addition to accounting 

professionals, there are numerous resources that can be found on the Internet. For 

example the Small Business Administration offers an internal control check list that can 

be used as a starting point. A copy can be located at 

http://www.prescott.edu/faculty_staff/faculty/scorey/documents/sba_2004a.pdf. The 

Government Accountability Office has published a guide for Government Agencies titled 

Standards for Internal Control in the Federal Government that explains the components 

and principles of internal control (http://www.gao.gov/special.pubs/ai00021p.pdf). There 

are also many other organizations that have posted their control procedures on the Web 

ranging from State and local government agencies, to educational institutions, to religious 

organizations. For example, the Comptroller of the State of Connecticut 

(http://www.osc.state.ct.us/manuals/AcctDirect/contents.htm) has an Accountability 

Directive that, in Appendix B, SECTIONS APPLICABLE TO ALL AGENCY 

PROGRAMS, includes not only internal control checklists, but flow charts. Much has 

been written on internal control by experts in the field, the material in this document 

borrows from a number of those sources. 

Naturally, no one set of controls will be right for all political committees. Small 

organizations that have only a few people involved will have very different needs and 

resources than a large corporate or union Separate Segregated Fund that has a significant 

staff and access to the internal auditing resources of the connected organization. This 

document is aimed at the smaller organizations. Of course, effective internal control 

depends heavily on the separation of key functions among more than one person. 

What are Internal Controls? 

Internal control is a process designed to ensure that an organization's goals are met with 

respect to: 

• Effective and efficient operations 

• Reliable financial reporting, 

• Compliance with laws and regulations, and 

• Protection of the organization’s assets 

The best internal control system can provide only reasonable, not absolute, assurance that 

these goals are met. Any system may be defeated either by accident or intentionally 

through collusion. However, a well-designed system will reduce the risk that errors or 

intentional acts will occur or go undetected. 

The internal control process typically includes the following elements: 

• Control Environment 

• Risk Assessment 

• Control Activities 

• Information and Communication 

• Monitoring 

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Although this may sound complicated, in a small organization it is actually very simple. 

The following describes each of the elements: 

Control Environment. At the core of any organization are its people with their 

individual attributes such as integrity and competence, and the environment in which they 

operate. There are three key aspects to controlling the environment: 1) Limiting the 

number of people who have access to any accounting function, assets or records system, 

2) Maintaining a separation of functions so that no single individual has complete control 

over financial transactions, and 3) Providing proper instruction and guidance to relevant 

staff. Ideally, a committee should utilize the smallest number of individuals needed to 

accomplish the work and still maintain a separation of duties. These individuals should 

have an understanding of the importance of control procedures and the role they play in 

ensuring accurate reporting of all financial activities. 

Risk Assessment. The committee must be aware of, and deal with, the risks it faces both 

monetary and non-monetary. Naturally some assets, such as cash, are more easily 

diverted than others and the control procedures should take into account the risk that each 

type of asset presents. Then the committee can establish cost effective ways of managing 

the related risks. 

Control Activities. Control policies and procedures must be established to ensure that 

risks are minimized. Depending on the size of the organization these procedures may be 

simple and limited, or complex and more extensive. A simple example would be to 

assign one person to record transactions and file disclosure reports, while another to 

review and reconcile them to reports and accounting records. 

Information and Communication. Information and communication systems surround 

all of these activities. They enable people to gather and share the information needed to 

conduct, manage, and control operations. 

Monitoring. The entire process must be monitored, and modifications must be made as 

necessary. In this way, the system can react dynamically, changing as conditions 

warrant. In many political committees this is a critical part of the equation. Staff and 

structures change often and sometimes radically. Therefore it is necessary to reconsider 

the procedures in place to assure they are still effective and appropriate to the current 

circumstances. 

Follow-up. Once a deficiency in internal control is identified, it is incumbent upon 

committee management to take steps to minimize the risk. After identifying a potential 

problem, it is expected that action will be taken to reasonably assure that the committee’s 

affairs will be conducted in a manner that meets the internal control and organizational 

goals discussed above. 

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Selected Procedures for Internal Controls 

As alluded to earlier, separation of duties is the key ingredient in any internal control 

system. Without that separation, it is virtually impossible to be reasonably assured that 

the organization’s internal control goals are met. In a small organization there may be as 

few as two or three individuals involved in the processing, recording and reporting of 

transactions. With careful planning and assigning of duties it is possible to establish an 

elementary internal control system with very few people. If the committee staff is very 

small maintaining some level of separation of duties and independent review is of prime 

importance. The Treasurer can provide independent review so long as he or she does not 

process transactions on a day to day basis or prepare disclosure reports. 

The controls discussed below include those over cash and non-cash assets that are readily 

convertible into cash (e.g., liabilities whose liquidation will require the use of cash, such 

as accounts payable and notes payable). The areas discussed below represent particular 

vulnerabilities the Commission has identified based on its regulatory experience. They 

do not represent an exhaustive list of assets to be safeguarded. 

Bank Accounts

A. Limit the number of bank accounts to those absolutely required to manage the 

committee’s business. It may, for example, be more convenient to have separate 

accounts for the primary and general elections and/or receipts and disbursements. 

Obviously, the fewer the accounts, the greater the control and the smaller the 

opportunity for errors or wrongdoing. 

B. A political committee should obtain from the Internal Revenue Service an 

employer identification number (“EIN”) in the name of the committee and all 

committee bank accounts should be in the name of the committee and utilize the 

committee EIN. Never approve the opening of an account in the name of an 

individual or using an individuals Social Security Number. The mailing address 

should be a committee address and the statements should be delivered unopened 

to a person not charged with processing transactions. Only the treasurer or his 

designee should be permitted to open and close bank accounts. Those with such 

authority should be specifically named in writing. 

C. Limit the number of persons authorized to sign checks. In addition, checks in 

excess of a certain dollar amount should require the signature of two responsible 

individuals. The recommended threshold is $1,000. Facsimile signatures should 

be prohibited unless controlled by a check-signing machine with a numerical 

sequence counter. No signature stamps should be allowed. 

D. Debit and credit cards must be carefully controlled since they represent easy 

access to committee assets. The committee’s bank or credit card issuer may be 

helpful in this regard. It may be possible to place dollar restrictions on cards, both 

on a per transaction basis and a cumulative limit. Once expenditures are 

approved, the limit can be re-established. Limits or prohibitions can also be 

placed on cash withdrawals. 

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E. Review the transactions on bank statements and reconcile the statements to the 

accounting records each month in a timely manner. Many committees find that 

the use of one of the commercially available small business accounting software 

packages is useful in this process. They often include a simplified preprogrammed process for reconciling the accounts and locating differences. The 

review and reconciliation are essential to determining if any errors occurred, 

unauthorized checks were issued or receipts were stolen. Someone should 

reconcile the bank statement other than the check signers and those controlling the 

checking account and processing transactions. The individual responsible for 

reconciling the account should receive the bank statement unopened. This one 

step of segregating the processing of transactions and the reconciliation of 

accounts would have prevented or quickly revealed a number of the 

misappropriations and the associated false reporting that the Commission has 

observed in recent years. It is also an excellent technique for discovering errors 

and omissions that occur accidentally. 

F. Prior to filing each report, a reconciliation between bank and accounting records 

and the disclosure reports should be undertaken. The use of electronic banking 

can contribute to the timely reconciliation process and allow reconciliations to be 

easily done when reports do not coincide with bank statement dates. Access to 

the electronic banking system should be limited. 

G. Require all wire transfers to be pre-authorized by two responsible individuals and 

immediately recorded in the accounting records. A committee sequential 

identification number (similar to a check number) is often helpful in recording 

and controlling wire transfers. A gap in the sequence number indicates a wire 

transfer that was not recorded. The Commission has encountered situations where 

the failure to record wire transfers has resulted in substantial misstatements in 

disclosure reports. Naturally, the reconciliation of the checking accounts to the 

accounting records and the disclosure reports will help prevent the filing of 

erroneous reports. 

H. Finally, investigate other control related services that the committee’s bank may 

be able to provide. With electronic banking, information is available instantly 

that can contribute to a more secure control environment. Also banks may be able 

to screen checks that are drawn on committee accounts during their processing for 

compliance with agreed upon criteria. 

Receipts 

A. Make a list of receipts when the mail is opened. Ideally, the person opening the 

mail and preparing the list should be independent of the accounting function. A 

responsible official should periodically (during the monthly bank reconciliation if 

not more often) compare the list with the recorded amount for the deposit and the 

deposit amount on the bank statement. Some committee’s have found using a 

lockbox service (to independently open mail, record the contributions, and make 

bank deposits) to perform this part of receipt processing beneficial. Such services 

may be available through the bank.

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B. The employee responsible for opening the mail should complete to following: 

— Place restrictive endorsements, such as For Deposit Only to the Account 

of the Payee, on all checks received. Account number can be added but 

that addition may cause a security concern by providing each contributor 

the committee’s account number..

— Prepare a list of the money, checks, and other receipts.

— Forward all receipts to the person responsible for preparing and making 

the daily bank deposits. Cash and check receipts should be deposited 

intact daily.

C. If the committee receives contributions via debit and credit card, the same type of 

information described above for checks and cash should be assembled for those 

contributions1

. The same verification to bank deposits should also be performed. 

The procedure will depend on the system that the credit card processor has in 

place. These control issues should be taken into account before selecting a firm to 

process the committee’s credit card contributions. Commission Advisory Opinion 

1999-9 (available on the Commission’s Web Site) provides guidance concerning 

the solicitation and receipt of credit card contributions. Although the Opinion 

was issued in the context of the Presidential Primary Matching Fund program, it is 

useful guidance for credit card contributions in non-pubicliy funded campaigns as 

well.

D. Prohibit delivery of unopened business mail to employees having access to the 

accounting records.

E. Contributions that are received by committee personnel at events and in person 

should be subject to the same procedures as those received via mail. Lists should 

be made and the checks submitted to the person(s) doing other contribution 

processing.

F. Secure undeposited receipts in a locked cabinet at all times.

G. Cash refunds should require approval.

H. Locations where the physical handling of cash takes place should be reasonably 

safeguarded.

Disbursements

A. Generally, disbursements should be made with pre-numbered checks, with the 

exception of petty cash. Using checks for all major cash payments ensures that 

there is a permanent record of the disbursement. The check should be prenumbered so that it is accounted for properly. This procedure helps to prevent the 

issuance of a check that is not recorded in the cash disbursement records. As 

noted above, it is good practice to require checks in amounts greater than a 

specified amount to require two signatures. Additionally, pre-signed checks 

should not be allowed. The use of credit and debit cards should be very carefully 

controlled and detailed records of the transactions should be required of all users. 

Avoid using credit and debit cards to withdraw cash. Wire transfers should 

 

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 Be aware that credit card processing fees may be netted against the contribution amounts when deposited 

into the committee’s accounts. If so, the gross amount of the contributions must be recorded with the 

processing fees shown as an expense. 

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require dual authorization and each wire should be assigned a sequential number 

to help assure that all such payments have been recorded. Wire transfers should 

be recorded in the accounting records immediately. 

B. If a mistake is made when preparing a check, void the check before preparing a 

new one. The voided check should then be altered to prevent its use, retained to 

make sure all pre-numbered checks are accounted for, and filed with other checks 

for a permanent record. The stock of unused checks should be safeguarded and 

regularly inventoried. 

C. If possible, check signing should be the responsibility of individuals having no 

access to the accounting records. 

D. Draw checks according to procedures prescribing adequate supporting 

documentation and authorization. It is in a committee’s best interest to ensure 

that invoices that have been properly authorized support disbursements. This 

documentation should include (1) a proper original invoice; (2) evidence that the 

goods or services were received; and (3) evidence that the purchase transaction 

was properly authorized. Some committees find the use of a check authorization 

form to be useful. The signatures required for such authorizations can vary based 

on the size and nature of the transaction. 

E. All supporting documents should be canceled or marked "paid" once a 

disbursement is made to avoid double payments. In the past the Commission has 

observed instances where failure to take these steps has resulted in many costly 

duplicate payments. Payments should not be made on statements or balance-due 

billings unless underlying invoices are included. 

F. Mail all checks promptly and directly to the payee or if they are to be delivered by 

committee staff, require that the person taking control of the checks signs for 

them. The person mailing the check should be independent of those requesting, 

writing, and signing it. 

Petty Cash.

Use an imprest petty cash fund with one custodian. The imprest fund involves 

replenishing petty cash only when properly approved vouchers and/or petty cash log 

entries are presented justifying all expenditures. The amount of the replenishment is 

equal to the difference between the stated amount of the fund and the remaining balance. 

For accountability, only one person should be in charge of the fund. The amount to be 

placed in the petty cash fund will need to be determined by the committee based on its 

operating needs, but should be kept to the minimum amount needed to make small 

disbursements. A petty cash fund of not more than $500 should be adequate in most 

cases. If that proves not to be the case, the committee should review its policies 

concerning which disbursements may be paid from petty cash. No cash disbursement in 

excess of $100 is permitted 

Payroll 

Many committees use a payroll service for much of the payroll function. Where there are 

more than a few employees; a service can be a very effective way of handling payroll and 

maintaining a separation of duties within the payroll operation. As an additional benefit, 

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the service will often take care of the preparation and filing of the necessary tax returns, 

and thereby help avoid errors and associated penalties. 

If the committee chooses to handle payroll in-house, the signing and distribution of the 

checks must be properly handled to prevent their theft. The controls should include 

limiting the authorization for signing the checks to a responsible person who does not 

have access to timekeeping or the preparation of the payroll, the distribution of the 

payroll by someone who is not involved in the other payroll functions, and the immediate 

return of unclaimed checks for redeposit 

If the committee has more than a few employees, it is advisable that it use an imprest 

payroll account to help prevent the payment of unrecorded payroll transactions. An 

imprest payroll account is a separate checking account in which a small balance is 

maintained. A check for the exact amount of each net payroll is transferred from the 

general account to the payroll checking account immediately prior to the distribution of 

the payroll. The advantages of an imprest account are that it limits the organization's 

exposure to payroll fraud, allows the delegation of payroll check-signing duties, separates 

routine payroll expenditures from other expenditures, and facilitates cash management. 

Payables

The accounts payable/notes payable procedures are clearly related to the procedures for 

cash disbursements and payroll. The control concern is to make certain that all liabilities 

are properly recorded and ultimately paid. There should be a proper segregation of duties 

over the performance of the functions of comparing receiving reports, purchase orders 

and invoices and the handling of the actual disbursement functions. As noted previously, 

invoices should be stamped “paid” and payments should not be made from statements of 

account unless accompanied by the related bills and invoices. These procedures prevent 

accidentally paying the same charges more than once. For disbursements that are not 

normally accompanied by an invoice (e.g., payment on a note or office rent), the 

authorization should come from a responsible official. 

Computerized Systems 

Most political committees are required to file their reports electronically and therefore 

many of their accounting records are automated. All of the same control considerations 

that apply to a manual transaction system apply to an automated system. In particular, 

separating functions so that data files are reconciled to other records by someone 

independent of the transaction processing and reporting functions is critical. In addition, 

in electronic systems the selection of software, the training of staff in the use of that 

software, limiting access to the system, and security of the data are important 

considerations. 

In many cases, the electronic filing software is separate from accounting software. If this 

is the situation, determine if data can be exported from the accounting software to the 

filing software. Not only is it more efficient than entering the data twice, it reduces the 

opportunity for error. 

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There is an additional safeguard that is important and sometimes overlooked. The 

electronic data must be regularly backed up to avoid a loss of data that can interfere with 

a committee’s ability to file timely and accurate disclosure reports. Regardless of 

whether such a data loss stems from a hardware failure, a software failure, human error, 

or a disaster such as a fire or flood, the result is the same. There are several ways to 

accomplish a data back up. In some instances the software supplier will “host” the data 

meaning that it resides on the supplier’s server and is backed up by the supplier. If back 

up is to be done locally, it can be accomplished by copying the data to a tape or CD and 

storing the back up off site. Ideally the back up should be done daily. 

Conclusion 

While no system of internal controls can ever be foolproof and one set of controls is not a 

good fit for all types of committees, the elements identified above can significantly 

reduce the opportunity for intentional misappropriation of funds and any related false 

reporting. Furthermore, many of these internal controls can also reduce the likelihood of 

inadvertent errors that can result in reporting problems. This discussion of internal 

controls is not intended to be exhaustive or to prescribe any one set of controls. It is up to 

each political committee to carefully consider what internal controls are valuable and 

feasible. 

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