Interim Audit Report of the 

Audit Division on 

Latinos for America First 

(January 1, 2019 - December 31, 2020) 

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)

Latinos for America First is a non-qualified, non-connected 

political action committee headquartered in Pasadena, Texas. 

For more information, see the chart on the Committee 

Organization, p.2. 

Financial Activity (p. 2)

• Receipts

o Contributions from Individuals $ 308,783 

o Offsets to Operating Expenditures 22 

Total Receipts $ 308,805 

• Disbursements

o Other Federal Operating $ 237,540 

Expenditures 

o Contributions to Federal 5,500 

Candidates/Committees and Other 

Political Committees

Total Disbursements $ 243,040 

Findings and Recommendations (p. 3) 

• Misstatement of Financial Activity (Finding 1)

• Increased Activity (Finding 2) 

• Disclosure of Occupation and/or Name of Employer 

(Finding 3) 

1

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

Audit Division on 

Latinos for America First 

(January 1, 2019 - December 31, 2020) 
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. Summaries

Findings and Recommendations 3 

Part IV. Findings and Recommendations

Finding 1. Misstatement of Financial Activity 4

Finding 2. Increased Activity 6

Finding 3. Disclosure of Occupation and/or Name of Employer 7
1 

Part I

Background 

Authority for Audit

This report is based on an audit of Latinos for America First2 (LFAF), 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 shall 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.

2

 During the election cycle, LFAF was initially named Latinos for Trump PAC and then changed its name to 

Latinos for the President before changing its name to Latinos for America First on March 5, 2021. 
2 

Part II

Overview of Committee 

Committee Organization 

Overview of Financial Activity 

(Audited Amounts)

Cash on hand @ January 1, 2019 $ 622

Receipts

o Contributions from Individuals 308,783

o Offsets to Operating Expenditures 22

Total Receipts $ 308,805

Disbursements

o Other Federal Operating Expenditures 237,540

o Contributions to Federal 

Candidates/Committees and Other Political 

Committees

5,500

Total Disbursements $ 243,040

Cash on hand @ December 31, 2020 $ 66,387

Important Dates

• Date of Registration August 21, 2018

• Audit Coverage January 1, 2019 - December 31, 2020

Headquarters Pasadena, Texas

Bank Information

• Bank Depositories Two

• Bank Accounts Two federal checking accounts

Treasurer

• Treasurer When Audit Was Conducted Moni Casarez

• Treasurer During Period Covered by Audit Moni Casarez

Management Information

• Attended FEC Campaign Finance Seminar No

• Who Handled Accounting and 

Recordkeeping Tasks

Treasurer and Volunteer Staff
3

Part III

Summaries 

Findings and Recommendations 

Finding 1. Misstatement of Financial Activity

During audit fieldwork, a comparison of LFAF's most recent reported financial activity, 

filed prior to audit notification, with its bank records revealed a misstatement of receipts, 

disbursements, and ending cash on hand for calendar year 2020. Specifically, LFAF 

understated receipts by $75,776, disbursements by $52,650, and ending cash on hand by 

$23,037. In response to the exit conference, LFAF filed amended disclosure reports 

materially correcting the public record for receipts and disbursements. The ending cash 

on hand in calendar year 2020 remains misstated. The Audit staff discussed the 

amendments with the LFAF representatives and recommends an amendment to its most 

recently filed disclosure report to correct the cash on hand balance. (For more detail, see 

p. 4.) 

Finding 2. Increased Activity

A comparison of LFAF’s bank records with its originally filed reports revealed that 

receipts were understated by $152,815 and disbursements were understated by $183,369 

for calendar years 2019 and 2020. The Audit staff recommends that LFAF provide any 

additional comments it deems relevant to this matter. (For more detail, see p. 6.) 

Finding 3. Disclosure of Occupation and/or Name of 

Employer

During audit fieldwork, a review of all contributions from individuals requiring 

itemization indicated that 130 contributions, totaling $39,590, lacked or inadequately 

disclosed the required occupation and/or name of employer information. LFAF did not 

sufficiently demonstrate “best efforts” to obtain, maintain and submit the required 

information. In response to audit fieldwork, LFAF provided some documentation of 

“best efforts,” however, the efforts were made untimely. In response to the exit 

conference, LFAF filed amended disclosure reports that materially corrected the public 

record. (For more detail, see p. 7.) 
4

Part IV

Findings and Recommendations 

Finding 1. Misstatement of Financial Activity 

Summary 

During audit fieldwork, a comparison of LFAF's most recent reported financial activity, 

filed prior to audit notification, with its bank records revealed a misstatement of receipts, 

disbursements, and ending cash on hand for calendar year 2020. Specifically, LFAF 

understated receipts by $75,776, disbursements by $52,650, and ending cash on hand by 

$23,037. In response to the exit conference, LFAF filed amended disclosure reports 

materially correcting the public record for receipts and disbursements. The ending cash 

on hand in calendar year 2020 remains misstated. The Audit staff discussed the 

amendments with the LFAF representatives and recommends an amendment to its most 

recently filed disclosure report to correct the cash on hand balance. 

Legal Standard 

Contents of (Federal) 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, the Audit staff reconciled LFAF’s most recent reported financial 

activity, filed prior to audit notification, with its bank records for calendar years 2019 and 

2020. The reconciliation determined that LFAF misstated receipts, disbursements, and 

ending cash on hand for 2020. The following charts detail the discrepancies between 

LFAF’s disclosure reports and bank activity. The succeeding paragraphs explain why the 

discrepancies occurred.
5

2020 Committee Activity

Reported Bank Records Discrepancy

Beginning Cash on hand @ 

January 1, 2020

 ($5,656) ($5,746) $90

Understated

Receipts $216,598 $292,374 $75,776

Understated

Disbursements $167,591 $220,240 $52,650

Understated

Ending Cash on hand @ 

December 31, 2020

$43,351 $66,387 $23,037

Understated

The 2020 understatement of receipts resulted from the following:

• Contributions from individuals not reported $76,172 

• Contributions from individuals reported, not supported by bank deposits (469) 

• Contributions reported net of PayPal processing fees 34 

• Unexplained differences 39 

Net Understatement of Receipts $75,776 

 The 2020 understatement of disbursements resulted from the following:

• Disbursements not reported $54,282 

• Disbursements reported that did not clear bank (2,667) 

• Contribution to political committee not reported 1,000 

• PayPal fees not reported 35 

Net Understatement of Disbursements $52,650

LFAF provided no specific explanation for why the $76,172 in contributions from 

individuals were not reported. 

The disbursements not reported, totaling $54,282, consisted of disbursements for bank 

charges, postage, travel expenses, bookkeeping, printing, mailing list rental, direct mail, 

and a contribution refund. 

The $23,037 understatement of the ending cash on hand was a result of the reporting 

discrepancies described above.

B. Interim Audit Report & Audit Division Recommendation

The Audit staff discussed this matter with the LFAF representatives during the exit 

conference and provided schedules detailing the misstatements. In response to the exit 

conference, LFAF stated, “[t]he errors were obviously not intentional, but ... due to lack 

of experience from our volunteer treasurer.” Additionally, LFAF filed amended 

disclosure reports which materially corrected its misstated receipts and disbursements, 

however, its ending cash on hand remains misstated. 

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

amend its most recently filed disclosure report to correct the cash on hand balance with
6

an explanation that the change resulted from a prior period adjustment. Further, LFAF

should reconcile the ending cash on hand balance of its most recent report to identify any 

subsequent discrepancies that may affect the adjustment recommended by the Audit staff.

Finding 2. Increased Activity

Summary 

A comparison of LFAF’s bank records with its originally filed reports revealed that 

receipts were understated by $152,815 and disbursements were understated by $183,369 

for calendar years 2019 and 2020. The Audit staff recommends that LFAF provide any 

additional comments it deems relevant to this matter. 

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).

Facts and Analysis 

A. Facts

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

to audit notification, the Audit staff compared LFAF’s originally filed disclosure reports 

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

degree to which LFAF had misstated its original filings.

The Audit staff calculated that LFAF understated its receipts and disbursements by 

$152,815 and $183,369, respectively, on the original reports filed over the two-year 

period ending December 31, 2020. LFAF amended its disclosure reports, prior to audit 

notification, disclosing some of the receipts and disbursements not included in its original 
7

reports. The remaining $75,776 and $52,650 understatement of receipts and 

disbursements, respectively, for 2020 are included above in Finding 1, Misstatement of 

Financial Activity. 

B. Interim Audit Report & Audit Division Recommendation

The Audit staff discussed this matter with LFAF representatives during the exit 

conference and provided the relevant schedule. In response to the exit conference, a 

LFAF representative stated, “[t]he errors were obviously not intentional, but ... due to 

lack of experience from our volunteer treasurer.” 

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

provide any additional comments it deems relevant to this matter.

Finding 3. Disclosure of Occupation and/or Name of 

Employer 

Summary 

During audit fieldwork, a review of all contributions from individuals, requiring 

itemization, indicated that 130 contributions, totaling $39,590, lacked or inadequately 

disclosed the required occupation and/or name of employer information. LFAF did not 

sufficiently demonstrate “best efforts” to obtain, maintain and submit the required 

information. In response to audit fieldwork, LFAF provided some documentation of 

“best efforts,” however, the efforts were made untimely. In response to the exit 

conference, LFAF filed amended disclosure reports that materially corrected the public 

record. 

Legal Standard 

A. Itemization Required for Contributions from Individuals. A political committee 

other than an authorized committee must itemize any contribution from an individual 

if it exceeds $200 per calendar year, either by itself or when combined with other 

contributions from the same contributor. 52 U.S.C. §30104(b)(3)(A). 

B. Required Information for Contributions from Individuals. For each itemized 

contribution from an individual, the committee must provide the following 

information: 

• The contributor’s full name and address (including zip code); 

• The contributor’s occupation and the name of his or her employer; 

• The date of receipt (the date the committee received the contribution);

• The amount of the contribution; and 

• The calendar year-to-date total of all contributions from the same individual. 

52 U.S.C. §30104(b)(3)(A) and 11 CFR §§100.12 and 104.3(a)(4). 

C. Best Efforts Ensures Compliance. When the treasurer of a political committee 

shows that the committee used best efforts (see below) to obtain, maintain, and 

submit the information required by the Act, the committee’s reports and records will 
8

be considered in compliance with the Act. 52 U.S.C. §30102(i) and 11 CFR 

§104.7(a). 

D. Definition of Best Efforts. The treasurer and the committee will be considered to 

have used “best efforts” if the committee satisfied all of the following criteria:

• All written solicitations for contributions included: 

 A clear request for the contributor's full name, mailing address, 

occupation, and name of employer; and 

 The statement that such reporting is required by Federal law. 

• Within 30 days after the receipt of the contribution, the treasurer made at least one 

effort to obtain the missing information, in either a written request or a 

documented oral request. 

• The treasurer reported any contributor information that, although not initially 

provided by the contributor, was obtained in a follow-up communication or was 

contained in the committee’s records or in prior reports that the committee filed 

during the same two-year election cycle. 11 CFR §104.7(b). 

E. Reporting Missing Information. If any of the contributor information is received 

after the contribution has been disclosed on a regularly scheduled report, the political 

committee shall either:

• File with its next regularly scheduled report, an amended memo Schedule A 

listing all contributions for which contributor identifications have been received 

and an indication of the previous report(s) to which the memo Schedule A relates; 

or 

• File amendments which include the contributor identifications together with the 

dates and amounts of the contributions. 11 CFR §104.7(b)(4)(i). 

Facts and Analysis 

A. Facts

LFAF did not disclose or inadequately disclosed the required occupation and/or name of 

employer information for contributions requiring itemization on its FEC reports, as of the 

date of the audit notification letter. 

Contributions Requiring Itemization –

Missing or Inadequate Occupation and/or Name of Employer 

Number of Contributions 130

Dollar Value of Contributions $39,590

Percent of Contributions 73%
9

1. Contributor Information Obtained but Not Disclosed: 

During audit fieldwork, LFAF provided the Audit staff with the required occupation 

and/or name of employer information for some of its contributors; however, LFAF did 

not disclose the information on its reports as required for the following:

2. Best Efforts Not Demonstrated: 

LFAF did not provide the Audit staff with records to demonstrate timely “best efforts”

for the following: 

3. Additional Information:

LFAF disclosed the following unacceptable entries on Schedule A (Itemized Receipts):

• “NA” or no occupation and/or name of employer information for 127 

contributions totaling $38,990, and 

• Inadequate occupation and/or name of employer for three contributions totaling 

$600. 

B. Interim Audit Report & Audit Division Recommendation

The Audit staff discussed this matter with LFAF representatives during audit fieldwork 

and at the exit conference and provided the schedule detailing these disclosure errors. In 

response to the exit conference, LFAF filed amended disclosure reports that materially

corrected the public record. LFAF’s amended disclosure reports included the occupation 

and name of employer information for 12 contributions, totaling $4,760, included in the 

Contributor Information Received but Not Disclosed chart above. In addition, of the 117 

contributions included in the Best Efforts Not Demonstrated chart above, LFAF included 

the occupation and name of employer information for 98 contributions, totaling $28,680, 

in its amended reports.

Contributor Information Obtained but Not Disclosed

Contributor Information Obtained from Untimely “Best Efforts” Letters

Dollar Value of Contributions

7

$4,235

Contributor Information in LFAF’s records

(no record of when the information was obtained) 

Dollar Value of Contributions

6

$775 

Total Number of Contributions

Dollar Value of Contributions

13

$5,010

Best Efforts Not Demonstrated

Best Efforts Letters Sent to Contributors Untimely

(contributor information NOT obtained) 

Dollar Value of Contributions

52

$16,700

Best Efforts Documentation Not Provided by LFAF

Dollar Value of Contributions

65

$17,880

Total Number of Contributions

Dollar Value of Contributions

117

$34,580
10

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

provide any additional comments it deems relevant to this matter.