Interim Audit Report of the 

Audit Division on the Jim Risch 

for U.S. Senate Committee 

(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 Campaign (p. 2) 

Jim Risch for U.S. Senate Committee is the principal campaign 

committee for James E. Risch, Republican candidate for the United 

States Senate from the state of Idaho, and is headquartered in Boise, 

Idaho. For more information, see the Campaign Organization Chart, 

p.2 

Financial Activity (p. 2) 

• Receipts 

o Contributions from Individuals $ 1,672,568 

o Contributions from Other 

Political Committees 1,179,720 

o Transfers from Other Authorized 

Committees 76,838 

o Offsets to Operating 

Expenditures 8,757 

o Other Receipts 31,206 

Total Receipts $ 2,969,089 

• Disbursements 

o Operating Expenditures $ 1,809,619 

o Contribution Refunds 12,227 

o Other Disbursements 3,547 

Total Disbursements $ 1,825,393 

Findings and Recommendations (p. 3) 

• Misstatement of Financial Activity (Finding 1) 

• Receipt of Contributions in Excess of the Limit (Finding 2) 

• Failure to File 48-Hour Notices (Finding 3) 

1

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

Division on the Jim Risch for U.S. 

Senate Committee 

(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 Campaign 

 Campaign 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. Receipt of Contributions in Excess of the Limit 6 

Finding 3. Failure to File 48-Hour Notices 9 
 1 

Part I 

Background 

Authority for Audit 

This report is based on an audit of the Jim Risch for U.S. Senate Committee (JRUSC), 

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 receipt of excessive contributions; 

2. the receipt of contributions from prohibited sources; 

3. the disclosure of contributions received; 

4. the review of 48-hour notices; 

5. the disclosure of individual contributors’ occupation and name of employer; 

6. the evaluation of a daily cash analysis; 

7. the review of political party contribution discrepancies; 

8. the consistency between reported figures and bank records; 

9. the completeness of records; and 

10. other committee operations necessary to the review. 
 

 

2 

Part II 

Overview of Campaign 

Campaign Organization 

Important Dates 

• Date of Registration October 19, 2007 

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

Headquarters Boise, Idaho 

Bank Information 

• Bank Depositories Five 

• Bank Accounts Five checking accounts, Three CDs 

Treasurer 

• Treasurer When Audit Was Conducted R. John Insinger 

• Treasurer During Period Covered by Audit R. John Insinger 

Management Information 

• Attended FEC Campaign Finance Seminar Yes 

• Who Handled Accounting and 

Recordkeeping Tasks 

Paid and Volunteer Staff 

Overview of Financial Activity

(Audited Amounts) 

Cash on hand @ January 1, 2019 $ 1,153,396 

Receipts 

o Contributions from Individuals 1,672,568 

o Contributions from Other Political 

Committees 

1,179,720 

o Transfers from Other Authorized 

Committees 

76,838 

o Offsets to Operating Expenditures 8,757 

o Other Receipts 31,206 

Total Receipts $ 2,969,089 

Disbursements 

o Operating Expenditures 1,809,619 

o Contribution Refunds 12,227 

o Other Disbursements 3,547 

Total Disbursements $ 1,825,393 

Cash on hand @ December 31, 2020 $ 2,297,092 
 3 

Part III 

Summaries 

Findings and Recommendations 

Finding 1. Misstatement of Financial Activity

During audit fieldwork, a comparison of JRUSC’s reported financial activity with its 

bank records revealed a misstatement of beginning and ending cash on hand for calendar 

year 2019, as well as a misstatement of beginning cash on hand, receipts, and ending cash 

on hand for calendar year 2020. Specifically, for 2019, JRUSC understated beginning 

cash on hand by $68,101 and ending cash by $56,935. For 2020, JRUSC understated 

beginning cash on hand, receipts and ending cash on hand by $56,935, $44,412, and 

$109,547, respectively. The Audit staff recommends that JRUSC amend its disclosure 

reports or file a Form 99 (Miscellaneous Electronic Submission) to correct the 

misstatements. 

(For more detail, see p. 4) 

Finding 2. Receipt of Contributions in Excess of the Limit 

During audit fieldwork, the Audit staff reviewed contributions from individuals to 

determine if any exceeded the contribution limit. This review indicated that JRUSC 

received apparent excessive contributions totaling $74,400. These errors occurred as a 

result of JRUSC not resolving the excessive portions of contributions by forwarding 

presumptive redesignation or reattribution letters to its contributors or issuing refunds of 

the excessive portions of contributions in a timely manner. The Audit staff recommends 

that JRUSC provide documentation demonstrating that the contributions were not 

excessive, or if excessive, that the contributions were resolved in a timely manner. 

Absent such a demonstration, JRUSC should send letters to those contributors whose 

contributions are eligible for presumptive redesignation and/or reattribution or refund any 

remaining excessive amounts. 

(For more detail, see p.6) 

Finding 3. Failure to File 48-Hour Notices 

During audit fieldwork, the Audit staff identified that JRUSC failed to file or untimely 

filed 48-hour notices for 31 contributions totaling $72,300, that were received prior to the 

primary and general election. The Audit staff recommends that JRUSC submit 

documentation to demonstrate that the notices for the contributions in question were filed 

timely, that the contributions were received outside of the 48-hour notice reporting period 

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

(For more detail, see p. 9) 
 4 

Part IV 

Findings and Recommendations 

Finding 1. Misstatement of Financial Activity 

Summary 

During audit fieldwork, a comparison of JRUSC’s reported financial activity with its 

bank records revealed a misstatement of beginning cash on hand and ending cash on hand 

for calendar year 2019, as well as a misstatement of beginning cash on hand, receipts, and 

ending cash on hand for calendar year 2020. Specifically, for 2019, JRUSC understated 

beginning cash on hand by $68,101 and ending cash by $56,935. For 2020, JRUSC 

understated beginning cash on hand, receipts and ending cash on hand by $56,935, 

$44,412, and $109,547, respectively. The Audit staff recommends that JRUSC amend its 

disclosure reports or file a Form 99 (Miscellaneous Electronic Submission) to correct the 

misstatements. 

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 election cycle; 

• The total amount of disbursements for the reporting period and for the election 

cycle; and 

• Transactions that require itemization on Schedule A (Itemized Receipts) or 

Schedule B (Itemized Disbursements). 52 U.S.C. §30104(b)(l), (2), (3), (4), and 

(5). 

Facts and Analysis 

A. Facts 

During audit fieldwork, the Audit staff reconciled JRUSC’s reported financial activity 

with its bank records for calendar years 2019 and 2020. The reconciliation determined 

that JRUSC’s 2019 beginning and ending cash on hand was understated by $68,101 and 

$56,935, respectively. The cash on hand discrepancies resulted primarily from prior 

period adjustments, as well as non-material misstatements of both receipts and 

disbursements during calendar year 2019. The following chart details the 2020 

discrepancies between JRUSC’s disclosure reports and its bank activity. 
 5 

2020 Campaign Activity 

Reported Bank Records Discrepancy 

Beginning Cash on hand @ 

January 1, 2020 

$1,975,388 $2,032,323 $56,935 

Understated 

Receipts $1,660,227 $1,704,639 $44,412 

Understated 

Disbursements $1,448,070 $1,439,869 $8,201 

Overstated 

Ending Cash on hand @ 

December 31, 2020 

$2,187,545 $2,297,093 $109,548 

Understated 

The 2020 understatement of receipts resulted from the following: 

• Contributions from individuals not reported + $20,950 

• Contributions from political committees not reported + 1,000 

• Contributions from political committees under-reported + 2,500 

• Contributions from individuals over-reported - 1,600 

• Transfers from authorized committees over-reported - 6,419 

• Transfers from authorized committees not reported + 3,383 

• Interest/Investment income not reported + 795 

• Vendor refund not reported + 8,757 

• Unexplained differences + 15,046

Net Understatement of Receipts $44,412 

The 2020 overstatement of disbursements resulted from the following: 

• Disbursements not reported + $11,167 

• Transfer to unauthorized committee not reported + 2,500 

• Disbursements reported twice - 22,514 

• Disbursement reported that did not clear the bank - 1,243 

• Unexplained differences + 1,889

Net Overstatement of Disbursements ($8,201) 

The $109,548 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 during the exit conference with JRUSC 

representatives and provided schedules detailing the misstatement of financial activity. 

JRUSC representatives did not provide any comments. 

JRUSC representatives did not provide an exit conference response. 

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

JRUSC amend its disclosure reports or file a Form 99 (Miscellaneous Electronic 
 6 

Submission)2

 to correct the misstatements noted above. In addition, the Audit staff 

recommends that JRUSC reconcile the cash balance on its most recently filed report to 

include these adjustments and correct any subsequent discrepancies. 

Finding 2. Receipt of Contributions in Excess of the Limit 

Summary 

During audit fieldwork, the Audit staff reviewed contributions from individuals to 

determine if any exceeded the contribution limit. This review indicated that JRUSC 

received apparent excessive contributions totaling $74,400. These errors occurred as a 

result of JRUSC not resolving the excessive portions of contributions by forwarding 

presumptive redesignation or reattribution letters to its contributors or issuing refunds of 

the excessive portions of contributions in a timely manner. The Audit staff recommends 

that JRUSC provide documentation demonstrating that the contributions were not 

excessive, or if excessive were resolved in a timely manner. Absent such a 

demonstration, JRUSC should send letters to those contributors whose contributions are 

eligible for presumptive redesignation and/or reattribution or refund any remaining 

excessive amounts. 

Legal Standard 

A. Authorized Committee Limits. For the 2020 election, an authorized committee may 

not receive more than a total of $2,800 per election from any one person or $5,000 

per election from a multicandidate political committee. 52 U.S.C. §§30116(a)(1)(A) 

and (a)(2)(A); 11 CFR §§110.1(a) and (b) and 110.9. 

B. Handling Contributions That Appear Excessive. If a committee receives a 

contribution that appears to be excessive, the committee must either: 

• Return the questionable check to the donor; or 

• Deposit the check into its federal account and: 

• Keep enough money in the account to cover all potential refunds; 

• Keep a written record explaining why the contribution may be illegal; 

• Include this explanation on Schedule A if the contribution has to be itemized 

before its legality is established; 

• Seek a reattribution or a redesignation of the excessive portion, following the 

instructions provided in the Commission regulations (see below for 

explanations of reattribution and redesignation); and 

• If the committee does not receive a proper reattribution or redesignation 

within 60 days after receiving the excessive contribution, refund the excessive 

portion to the donor. 11 CFR §§103.3(b)(3), (4) and (5) and 110.1(k)(3)(ii) 

(B). 

C. Joint Contributions. Any contribution made by more than one person (except for a 

contribution made by a partnership) must include the signature of each contributor on 

2 See supra footnote 2. 
 7 

the check, money order, or other negotiable instrument or in a separate writing. A 

joint contribution is attributed equally to each donor unless a statement indicates that 

the funds should be divided differently. 11 CFR §110.1(k)(1) and (2). 

D. Reattribution of Excessive Contributions. The Commission regulations permit 

committees to ask donors of excessive contributions (or contributions that exceed the 

committee’s net debts outstanding) whether they had intended their contribution to be 

a joint contribution from more than one person and whether they would like to 

reattribute the excess amount to the other contributor. The committee must inform 

the contributor that: 

• The reattribution must be signed by both contributors; 

• The reattribution must be received by the committee within 60 days after the 

committee received the original contribution; and 

• The contributor may instead request a refund of the excessive amount. 11 CFR 

§110.1(k)(3). 

Within 60 days after receiving the excessive contribution, the committee must either 

receive the proper reattribution or refund the excessive portion to the donor. 11 CFR 

§§103.3(b) (3) and 110.1(k)(3)(ii)(B). Further, a political committee must retain 

written records concerning the reattribution in order for it to be effective. 11 CFR 

§110.1(l)(5). 

Notwithstanding the above, any excessive contribution that was made on a written 

instrument that is imprinted with the names of more than one individual may be 

attributed among the individuals listed unless instructed otherwise by the 

contributor(s). The committee must inform each contributor: 

• How the contribution was attributed; and 

• The contributor may instead request a refund of the excessive amount. 11 CFR 

§110.1(k)(3)(ii)(B). 

E. Redesignation of Excessive Contributions. When an authorized candidate 

committee receives an excessive contribution (or a contribution that exceeds the 

committee’s net debts outstanding), the committee may ask the contributor to 

redesignate the excess portion of the contribution for use in another election. The 

committee must inform the contributor that: 

• The redesignation must be signed by the contributor; 

• The redesignation must be received by the committee within 60 days after the 

committee received the original contribution; and 

• The contributor may instead request a refund of the excessive amount. 11 CFR 

§110.1(b)(5). 

Within 60 days after receiving the excessive contribution, the committee must either 

receive the proper redesignation or refund the excessive portion to the donor. 11 CFR 

§§103.3(b) (3) and 110.1(b) (5) (ii) (A). Further, a political committee must retain 

written records concerning the redesignation in order for it to be effective. 11 CFR 

§110.1(l)(5). 
 

 

Facts and Analysis 

A. Facts 

1. Facts 

During audit fieldwork, the Audit staff conducted a review of contributions to 

identify apparent excessive contributions from individuals, as noted below. 

8 

When an individual makes an excessive contribution to a candidate’s authorized 

committee, the campaign may presumptively redesignate the excessive portion to the 

general election if the contribution: 

• Is made before that candidate’s primary election; 

• Is not designated in writing for a particular election; 

• Would be excessive if treated as a primary election contribution; and 

• As redesignated, does not cause the contributor to exceed any other contribution 

limit. 11 CFR §110.1(b)(5)(ii)(B)(1)-(4). 

The committee is required to notify the contributor of the redesignation within 60 

days of the treasurer’s receipt of the contribution and must offer the contributor the 

option to receive a refund instead. 

Excessive Contributions - Testing Method 

High Dollar Review Contribution Error 

Amount $74,400 

Total Amount of Excessive Contributions $74,400 

Reason for Excessive Contributions 

Contributions not resolved via presumptive 

letter or refund $74,400 

Total Amount of Excessive Contributions $74,400 

2. Additional Information 

JRUSC did not maintain a separate account for questionable contributions. However, 

based on its cash on hand at the end of the audit period, it appears that JRUSC did 

maintain sufficient funds to refund the apparent excessive contributions. 

B. Interim Audit Report & Audit Division Recommendation 

The Audit staff discussed this matter during the exit conference with JRUSC 

representatives. and provided a schedule of the apparent excessive contributions. JRUSC 

representatives asked for clarification regarding the timing of the presumptive 

redesignation and/or reattribution letters. The Audit staff explained that presumptive 

letters sent to contributors in response to the exit conference would untimely resolve any 

excessive contributions. 
 9 

JRUSC representative did not provide an exit conference response. 

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

JRUSC: 

• Provide evidence demonstrating that the contributions in question were not 

excessive, or if excessive, were resolved in a timely manner. This evidence 

should include documentation that was not made available to the Audit staff 

during the audit, including copies of solicitation cards completed by the 

contributors at the time of their contribution that clearly inform the contributors of 

the limitations; timely letters sent to contributors eligible for presumptive 

redesignation and/or reattribution; or timely refunds (copies of the front and back 

of negotiated refund checks), redesignations, or reattributions for excessive 

contributions. 

• Absent such demonstration, for any excessive contributions that JRUSC could 

have resolved by sending presumptive redesignation and/or reattribution letters, it 

may now send letters to inform the contributors how the committee redesignated 

and/or reattributed the contribution and offer a refund. JRUSC must provide 

evidence of such refunds (copies of front and back of negotiated checks). For a 

reattribution, both the contributor and the individual to whom a contribution was 

reattributed must be notified. Absent the contributor’s request for a refund, these 

letters will obviate the need to refund the contributions. 

• If funds are not available to make such refunds, JRUSC should report the 

excessive contributions as debts owed on Schedule D (Debts and Obligations) 

until funds become available to make the refunds. 

Finding 3. Failure to File 48-Hour Notices 

Summary 

During audit fieldwork, the Audit staff identified that JRUSC failed to file or untimely 

filed 48-hour notices for 31contributions totaling $72,300, that were received prior to the 

primary and general election. The Audit staff recommends that JRUSC submit 

documentation demonstrating that the notices for the contributions in question were filed 

timely, that the contributions were received outside of the 48- hour notice reporting 

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

Legal Standard 

Last-Minute Contributions (48-Hour Notice). Campaign committees must file special 

notices regarding contributions of $1,000 or more received less than 20 days but more 

than 48-hours before any election in which the candidate is running. This rule applies to 

all types of contributions to any authorized committee of the candidate, including: 

• Contributions from the candidate; 

• Loans from the candidate and other non-bank sources; and 

• Endorsements or guarantees of loans from the banks. 11 CFR §104.5(f). 
 

Facts and Analysis 

A. Facts 

During audit fieldwork, the Audit staff identified 78 contributions totaling $205,300 that 

equaled or exceeded $1,000 and were received during the 48-hour notice reporting period 

for the primary and general election. A review of these contributions indicated that 

JRUSC did not file 48-hour notices for 18 contributions totaling $31,700 and untimely 

filed 48-hour notices for 13 contributions totaling $40,600. These contributions are 

summarized below. 

10 

Primary General Total 

48-Hour Notices - Not Filed $9,600 $22,100 $31,700 

48-Hour Notices - Filed Untimely $35,600 $5,000 $40,600 

TOTAL $45,200 $27,100 $72,300 

B. Interim Audit Report & Audit Division Recommendation 

The Audit staff discussed this matter during the exit conference with the JRUSC 

representatives and provided a schedule of the contributions for which 48-hour notices 

were not filed or filed untimely. JRUSC representatives asked questions regarding 

whether the change in the date of the primary election was considered. The Audit staff 

explained that this change was taken into consideration. 3 

 

JRUSC representatives did not provide an exit conference response. 

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

JRUSC submit documentation demonstrating that the 48-hour notices for the 

contributions in question were timely filed, the contributions were received outside of the 

48-hour notice reporting period or provide any comments it deems necessary with respect 

to this matter. 

3

 On April 1, 2020, the Idaho Governor effectively changed the date of the May 19, 2020, congressional 

primary election by setting June 2, 2020, as the deadline for absentee ballots. The change was in response 

to the COVID-19 pandemic. The updated 48-Hour Notice period was May 14 – May 30, 2020. FEC | 

Dates and deadlines | Idaho primary election report notice (2020)