Interim Audit Report of the 

Audit Division on the Grassroots 

Victory PAC 

(January 1, 2017 - December 31, 2018) 

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 

matters discussed in this 

report.

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 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 

Finding and Recommendation (p. 3)

• Misstatement of Financial Activity – Increased Activity

 

1

 52 U.S.C. §30111(b).
Interim Audit Report of the Audit 

Division 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 

Part II. Overview of Committee

Committee Organization 2 

Overview of Financial Activity 2 

Part III. Summary 

Finding and Recommendation 3 

Part IV. Finding and Recommendation

Misstatement of Financial Activity – Increased Activity 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.
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Part II

Overview of Committee 

Committee Organization 

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

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 
3 

Part III

Summary

Finding and Recommendation 

Misstatement of Financial Activity – Increased Activity 

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

revealed that disbursements were understated by $106,674 for calendar years 2017 and 

2018. The Audit staff recommends that GVP provide any additional comments it deems 

necessary with respect to this matter. (For more detail, see p. 4.) 
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Part IV

Finding and Recommendation

Misstatement of Financial Activity – Increased Activity

Summary 

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

revealed that disbursements were understated by $106,674 for calendar years 2017 and 

2018. The Audit staff recommends that GVP provide any additional comments it deems 

necessary with respect to this matter. 

Legal Standard 

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).

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 
5 

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 Audit staff recommends that, within 30 calendar days of service of this report, GVP 

provide any additional comments it deems necessary with respect to this matter.