WASHINGTON, D.C. 20463

MEMORANDUM 

October 4, 2021 

TO: Patricia C. Orrock

Chief Compliance Officer

Dayna C. Brown 

Assistant Staff Director

Audit Division

FROM: Neven F. Stipanovic 

Associate General Counsel 

Policy Division

Lorenzo Holloway 

Assistant General Counsel

Compliance Advice 

Danita Alberico

Attorney 

SUBJECT: Draft Final Audit Report of the Audit Division – Connecticut 

Democratic State Central Committee (LRA 1112)

 The Office of the General Counsel has reviewed the Draft Final Audit Report 

(“Report”) on the Connecticut Democratic State Central Committee (“Committee”). The 

Report contains five findings: (1) Contributions from Unregistered Political 

Organizations; (2) Recordkeeping for Employees; (3) Reporting of Debts and 

Obligations; and (4) Reporting of Apparent Independent Expenditures. We concur with 

the findings, and comment on Finding 2. If you have any questions, please contact 

Danita Alberico, the attorney assigned to this audit. 
Connecticut Democratic State Central Committee DFAR

LRA 1112

Page 2 of 2 

 The Report found that the Committee did not maintain any monthly logs to 

document the percentage of time each employee spent in connection with a federal 

election. For 2017 and 2018, the Audit Division identified payments to Committee 

employees totaling $111,8121 for which the Committee did not maintain monthly logs. 

This amount includes payroll expenses totaling $32,764 for employees paid exclusively 

with nonfederal funds. The Audit Division found that the Committee was required to, but 

did not, maintain monthly logs for its employees, including those paid with exclusively 

nonfederal funds. The Audit Division concludes in the Report that the Committee did not 

provide monthly logs. We recommend that with respect to employees involved in 

exclusively nonfederal activities, however, the Audit Division give the Committee an 

opportunity to provide a record sufficient to verify that those employees were involved in 

exclusively nonfederal activities. 

Depending on the percentage of time an employee spends on federal activities, 

Commission regulations dictate which accounts a committee may use to pay for the 

salary and benefit of the employee. Accordingly, salaries and benefits for employees 

who spend more than 25% of their compensated time on federal election activity (“FEA”) 

or activities in connection with a federal election in a given month must be paid only 

from a federal account. 52 U.S.C. § 30101(20)(A)(iv); 11 C.F.R. § 106.7(d)(1)(ii); see 

also 52 U.S.C. § 30125(b). Salaries and benefits for employees who spend 25% or less of 

their time on FEA or activities in connection with a federal election must either be paid 

from a federal account or be allocated as administrative costs. 11 C.F.R. §§106.7(c)(1), 

106.7(d)(1)(i). Employees who spend none of their compensated time on FEA or 

activities in connection with a federal election may be paid entirely from a nonfederal 

account if the funds comply with state law. 11 C.F.R. §106.7(d)(1)(iii). 

Commission regulations also require political committees to maintain records that 

provide in sufficient detail the necessary information and data from which filed reports 

and statements may be verified, explained, clarified, and checked for accuracy and 

completeness. 11 C.F.R. § 104.14 (b)(1). The Commission, however, has no way of 

knowing whether an employee spent no time on federal election-related activities unless 

it can review documentation that indicates that information. We do not believe that a 

monthly log is necessary to verify this information since only one type of activity (the 

percentage of time an employee spent in connection with a federal election) must be 

tracked and verified. Instead, we conclude that a record prepared in accordance with 

section 104.14(b)(1) would be sufficient for verification purposes. A simplified record 

for these types of employees would also be less burdensome than a monthly log for a 

committee to create and maintain. Therefore, we recommend that the Audit Division 

give the Committee an opportunity to provide records consistent with 11 C.F.R. § 104.14 

(b)(1) to show that certain employees were involved in exclusively nonfederal activities. 

1 This amount in payroll does not include payments to employees paid 100% with federal funds. 

See Proposed DFAR, at Part 1. Background, Commission Guidance, at 1.