1050 First Street NE Washington, DC 20463 | www.fec.gov/oig

MEMORANDUM

TO: The Commission 

 Lisa Stevenson

Acting General Counsel 

THROUGH: Christopher Skinner

Inspector General

FROM: Carla Smith

 Senior Counsel 

SUBJECT: OIG Review of Commission Directive 06, Handling of Internally Generated 

Matters 

REF: FEC Directive 06, Handling of Internally Generated Matters 

DATE October 5, 2022 

Summary. This memorandum transmits the results of the Office of Inspector General’s

(OIG) review of Federal Election Commission (FEC) Directive 06. This review was selected 

based on activity the OIG receives from its hotline. Specifically, the OIG often receives 

hotline complaints that fall outside of its authority and at times allege campaign finance 

violations. OIG review of FEC policy (i.e., Directive 06) identified ambiguity concerning 

the referral of such matters from the OIG to the Office of General Counsel (OGC) and, 

further, that Directive 06 has not been updated since 1978 despite significant statutory 

amendments. Accordingly, the OIG recommends that the Commission review and update 

Directive 06, as appropriate, to comport with current law and policy. 

Authority. Section 4 of the Inspector General Act of 1978, as amended (IG Act),1 provides 

in pertinent part, that each Inspector General, with respect to the establishment within which 

his Office is established: 

1 See Inspector General Act of 1978 §4. Duties and responsibilities; report of criminal violations to 

Attorney General.
(3) to recommend policies for, and to conduct, supervise, or 

coordinate other activities carried out or financed by such 

establishment for the purpose of promoting economy and efficiency 

in the administration of, or preventing and detecting fraud and abuse 

in, its programs and operations; 

(4) to recommend policies for, and to conduct, supervise, or 

coordinate relationships between such establishment and other 

Federal agencies, State and local governmental agencies, and 

nongovernmental entities with respect to (A) all matters relating to 

the promotion of economy and efficiency in the administration of, 

or the prevention and detection of fraud and abuse in, programs and 

operations administered or financed by such establishment, or (B) 

the identification and prosecution of participants in such fraud or 

abuse[.] 

Background. The OIG hotline provides a means for FEC employees, FEC contractors, and 

the public to communicate directly and confidentially with the OIG regarding allegations of 

fraud, waste, abuse, mismanagement, and other misconduct. Complainants frequently submit 

allegations of Federal Election Campaign Act (FECA) violations via the OIG hotline. FEC 

Directive 06 provides a means for internal and external referrals of FECA complaints, but it 

is silent regarding whether referrals by the OIG are internal or external. 

Observations. Our review of Directive 06 identified the following observations: 

1. Directive 06 references outdated FECA citations. 

The OIG reviewed Directive 06 and found that it has not been revised since it was issued on

April 21, 1978. As a result, Directive 06 does not reference the current FECA citations. 

Instead, it references the Commission’s authority under prior code 2 U.S.C. § 437(g) which 

was later reclassified as 52 U.S.C. § 30109 (a). Although outdated, Directive 06 is still in 

compliance with current FECA requirements as both 2 U.S.C. § 437(g) and 52 U.S.C. § 

30109 contain substantially the same provisions. 

2. Directive 06 does not identify the OIG as an operating division within the FEC and 

does not address OIG referrals to OGC.

Directive 06 provides the current procedures for referrals for each Operating Division within 

the FEC but is silent regarding the OIG.2 Specifically, Directive 06 does not identify the 

OIG as a separate Operating Division within the FEC and the Inspector General (IG) is not 

identified as a division leader. The OIG and IG’s lack of inclusion in Directive 06 is likely 

because the IG Act established the FEC OIG in April 1989, 11 years after Directive 06 was 

established. 

2 See Directive 06 Section II(A). 
FEC OIG 2023-10-001

Conclusion. Based on the foregoing observations, we conclude that Directive 06 is outdated 

and warrants an update in light of the FECA and IG Act statutory amendments that postdate 

it. 

Recommendations. The OIG recognizes that Directive 06 authorizes the Commission to 

determine its own procedures and set clear standards for generating internal compliance 

actions. As such, the OIG recommends the following for the Commission to consider: 

1) Revise Directive 06 to include current FECA citations and guidance related to OIG 

referrals of campaign finance related matters to OGC. 

If I can provide you with any further information, please do not hesitate to contact the OIG at 

(202) 694-1015.

cc: Alec Palmer, Staff Director