SANDLER REIFF 1090 Vermont Ave NW, Suite 750

Washington, DC 20005

www.sandlerreiff.com

T: 202-479-1111

F: 202-479-1115

SANDLER REIFF LAMB

ROSENSTEIN & BIRKENSTOCK, P.C.

June 22, 2021

Ms. Dayna C. Brown

Acting Assistant Staff Director 

Audit Division

Federal Election Commission

1050 First Street, N.E.

Washington, D.C. 20463

Dear Ms. Brown:

 This letter will serve as the response of the Connecticut Democratic State Central 

Committee (“CDSCC”) to the Interim Audit Report ("IAR") of the Federal Election Commission’s 

Audit Division ("the Audit Division") for the period covering the CDSCC’s financial activities for 

2017 and 2018. 

The response to each of the Audit Division’s four findings is as follows:

Finding #1

The IAR’s first finding involved the possible finding that certain receipts for both 

contribution and reimbursements received by the CDSCC were from impermissible sources. It is 

our understanding that, based upon information provided to the Audit Division, this finding has 

been resolved.

Finding #2

The IAR’s second finding involved recordkeeping for payroll. In response to the Audit 

Division’s inquiries regarding this issue, the CDSCC has instituted procedures to ensure that time 

records are maintained for all employees who are paid in part with non-federal funds. The CDSCC 

will note that the finding’s inclusion of payroll records for those employees who are paid with nonfederal funds are outside the scope of the Commission’s jurisdiction and should not have been 

included in the finding. See e.g Final Audit Report of the Commission on the Democratic Party of 

Wisconsin (2012 Cycle) at p.p. 13-16; Final Audit Report of the Commission on the Kentucky 

State Democratic Central Executive Committee (2012 Cycle), p. 9.; Final Audit Report of the 

Commission on the Utah Republican Party (2012) Cycle, p. 26-27.
2

Finding #3

The IAR’s third finding involves the disclosure of certain debts by the CDSCC. The 

CDSCC has filed a Form 99 to provide the requested information regarding undisclosed debts.

Finding #4

The IAR’s fourth finding involves the apparent failure to file 24/48 hour reports for 

transactions totaling $140,259.39 that were made in connection with the general election for United 

States Senate in 2018. As a threshold matter, the CDSCC objects to the characterization of these 

expenditures as independent expenditures. These expenditures were properly made as exempt 

activities and were fully coordinated with the Senate candidate. With respect to the door hanger, it 

is our understanding that since these activities were not public communications, they cannot be 

considered coordinated communications and no further action would be necessary regarding these 

expenditures. Notwithstanding, it should be noted that the door hanger was distributed by 

volunteers. 

With respect to the mailing activities, the committee contends that these mailings were 

undertaken in accordance with the volunteer activity exemption in accordance with 11 C.F.R. §§ 

100.87 & 100.147. In that regard, the CDSCC is providing a sworn declaration by Paul Vaitkus. 

Mr. Vaitkus was the production manager at the mail house that produced all volunteer exempt mail

for the CDSCC. Mr. Vaitkus’s declaration confirms that volunteers were present during the 

production of all mailings in connection with the CDSCC’s exempt mailings on behalf of its 

nominee for United States Senate and performed adequate volunteer activities consistent with prior 

Commission precedent.

Please note that Mr. Vaitkus’s declaration complies with the formatting requirements of 28 

U.S.C. § 1746. Thus, the Commission cannot characterize Mr. Vaitkus’s statements as “unsworn.” 

As the IAR acknowledges, there is considerable uncertainty of the amount of volunteer 

involvement required to satisfy the exemption and based upon the information provided to the 

Audit Division by the CDSCC, the Audit Division should consider this matter resolved.

If you require any further information, or have any other questions, please call me at (202)

479-1111.

Sincerely,

Neil Reiff

Counsel to the Connecticut Democratic State 

Central Committee