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CCNGRESSr~NAL ~UO[7 ~E?C~7

James Corman · J/7/7~

State: Cal;forn; a

District: 21st

Lccat~ ·:n: Northwest Los Angeles - San Fernando Valley

Democrat

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'-v~~~o~I ~-cc~en-I.'. .." !- . I I • :.. \ ~; • Erwin Hogan (R)

Erwi n Hogan (R) r/II /"

101,837 - 66. 5:~

44,094 - 28 .8~~

7, 178 - 4. 7'~

1960

James Corman (0)

Erw; n Hogan (R)

Bill Hill (PF?)

Unopposed

5237,345.56

5232,377.95

'/etes Cas::

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rll)[RAl ELECTION COMMISSION

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REPORT OF THt: AUDIT DIVISION O~ TIlE COl~\1AN CN·1PAIGN COMr1ITTEE

'l'I1E

COlU1l\N DINNER CO~1MITrr'EE

A~~D 'rIlE

COI·UvtAN CONGRESSIO;·IAL 1{EYl'-1i\N/KEYt"10~1AN

I. Backgro\~nd

A. Ov(!rview

1'·h·ls report is based upon an audi.t._ oftll~ c.Q.~I1l~!) .

Campaign Committee, the Corman Dinner Committee, and the Corman

Cong re 5S iona 1 l~<..~yman/Keywoman (" the Coromi t tees") undertaken by

the Audit Division of the Federal Election Commission in accordance \'1i th the Commission IS audit policy to determine whether

there has been compliance with the provisions of the Federal

Election Campaign Act of 1971, as amended (lithe Act"). The

audit was conducted pursuant to Section 438(a) (8) of Title 2,

United States Code, \-lhich directs the Commission to make from

time to time audits and field investigations with respect to

reports and statements filed under the provisions of the Act.

Th(~ Corman Campaign Committee registered ''lith the Office

of the Clerk of the U.s. House of Representatives on April 17, 1972,

in support of James C. Corman, Democratic candidate for California's

21st Congressional District. On ~arch 17, 1976 the Candidate

designated lhe Corman Campaign Committee as his principal campaign

committee. Congressman Corman authorized the Corman Dinner Committee on October 21, 1974 and the Corman Congressional Keyman/

Keywoman on June 10, 1973, to accept contributions and make expenditures on his behalf.

'1'he audit covered the period January 1,1975, through

September 30, 1977, the final coverage date of the latest reports

filed b~· the Committees at the time of the audit. The Committees

reported the following activity for the period cnding September 30,

1977 •

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Total Expenditures 141,994.63

Beginning Cash

Total Receipts

Ending Cash

Corman

Campaign

Committee

$ 1),053.47

165,632.25

28,691.09

Corman Corman

Dinner Congressional

Committee Koyman/Kcywoman

$ 28,486.79 $ 118.44

60,601.70 6,144.00

89,088.49 6,262.44

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This audit report is based on documents and working

papers supporting each of its factual statements. They form

part of- _the rccord_ upon_ whJ_cb the ~QJllID_i..~~iQI} based its decisions

on the Matters in this report and were available to commissioners

ano appropriate staff for review.

B. Key Personnel

The principal officers of the Con~ittees during the

period audited WQrc:

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COnIDlittce

Corman Campaign

Committee

Corman Dinner Committee

Corman Congressional Kcyman/I~cywornan

Chai rman

Mr. John ~uarrcra

Mr. Lawrence E.

Silverton

l1r. Harold Svenson

rrrcasurer

Mr. James R. Anderson

4-17-72 to 5-31-77

Mr. ~1ichac1 ,1. ~!a rv id

6-1-77 to Present

~~r. James R. Anderson

Mr. James R. Anderson
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c.

The audit included such tests as verification of reported

receipts and expenditures and individual transactions: review of

required supporting documentation: analysis of Committees' debts

and ob1iqations; and, such other audit procedures as deemed necessary

under the circumstances•

II. Auditor's Statement and Description of Findings

It is the opinion of the Audit staff, based upon examination

of the reports and statements filed and the records presented, th~t,

except for the deficiencies noted below, the reports and statem011ts

of the Corman Campaign Committee, the Corman Dinner Committee

and the Corman Congressional Keyman/Keywoman Committees fairly

present the financial activities of the Co~mittees for the period

covered by the audit. Further, except as noted below, no material

problems in complying with the Federal Election Campaign Act were ~c1iscovere(r diiril1g~--the course of tnc audlt.

Section 44lb(a) of '!'itle 2, United States Code, in part,

states that it is unlawful for any corporation to make a contribution or expenditure in connection with any election to any

political office and for any candidate, political committee, or

other person to knowingly accept or receive any contribution from

a corporation •

The review of the Committees' contributor records

revealed that 14 contributions totaling $953.50 were received

from eight (8) corporate entities. The corporate status of

these entities was subsequently verified by the Secretary of

State of California. The Committees provided documentation that

six (6) of these contributions were not funded by corporate sources.

The remaining eight (8) contributions which totaled $317.00

(Corman Congressional Kcymnn/Keywoman - four (4) totaling $187.00

and Corman Campaiqn Committee - four (4) totaling $130.00) were

refunded on April 19, 1978. ~he matter was referred to the Office

of General Counsel on June 19, 1978, where ~atter Under Review

626(78) was initiated. Subsequent information was received by the

Office of General Counsel that one (1) check was personal rather

than corporate. On August 29, 1978, the Commission found reason

to believe that the Committees accepted corporate contributions

in violation of 2 U.S.C. 441b(a) •

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A• Corporate Contributions
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The Office of General Counsel deterMined that no l':no~linq

violdt.ions occurred and since the COMmittees refunded the contri1>utionn they recommended that no further action be taken on this

matlC'r. The Commission voted on January 24, 1979, to accept the

Office' of General Counsel's recommendation and close thp file.

B. Retention of Supporting DocUMentation For Fxpen(~itu~-C's

Section 432(d) of Title 2, United States Code, in part,

requiros the treasurer to obtain and keep a receipted bill, statinq

the particulars, for every expenditure made by or on behalf of

a political comMittee in excess of $100, or expenditures aggregating in excess of $100, to the same person within a calendar year•

Section 102.9(c) (4) Title 11 of the Code of Federal

Regulations states that when a receipted bill is not available,

the treasurer may keep the cancelled check showing payment of the~ bill-; and -thebiI1, invoico or other -c0ntcmporaneous -memorandum

of the transaction containinq the identification of th0 person

to whom the expenditure is made, the amount of the expenditure,

the particulars of the expenditurc and tht' elate the expendi ture

was made •

Our examinaticn of the Comrnittec'R' records revealed

the following:

Corman Campaign Committee: Of 471 expenditures reqU1r1nq supportin0 documentation, ·~7 expenditures, or 16.35~

lacked adequate supporting documentation. These 77 expenditures

totaleu $20,338.81 and represented l5.28~ of the total requiring

documentation.

Corman Dinner Committee: Of 221 expenditures requ1r1ng

supporting documentation, 35 expenditures or 15.84% lacked

adequate supporting documentation. These 35 expenditures totaled

$9,524.02 and represented ll.03~ of the total requiring rlocu~entation.

The Cornmi ttecs subrnit tC'(l supporting <loeUIncnta ticn or

evidence of their best efforts to obtain the required documentation

for 91.07~ of the above expenditures•
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Recommendation

Based on the above documentation submitted by the Committees,

and the Committees' efforts to obtain the additional documentation

the Audit staff recommends that no further action be taken on thiR

matter.

c. Itemization of Expenditures

Section 434(b) (9) of Title 2, United States Co~c, in

part, requires the committee to disclose the identification of

each person to whom expenditures have been made by such committcp

or candidate which in the aggregate exceeds $100 within a ca1endc:uyear, together with the purpose, amount and date of the expenditurr..

Our examination of the Committees' records revealed

the following exceptions:

Corman ninner Cammittee: O-f 2'21 experiditrir'es re'qllirirteJ itemiz~tion, 16 c~pcnditurcs, or 7.24% lacked itemization. These

16 expenditures totaled $~86.31 and represented .56t of the

total expenditures requiring itemization.

A list of the unitemized expenditures was provided to

the Committees wi th t.he request that amendments be submitted

to correct the it0mizcd and unitemized expenditure totals on

the report su~nary pages along with the appropriate Schedules B

to provide the particulars as required by the Act.

Recommendation

Since we received the Committees' amended reports on April 3,

1978, disclosing the required information, we recommend no further

action be taken on this matter.

D. Itemization of Transfers from Political Committees

Section 434(b) (4) of Title 2, United States Code, in

part, requires disclosure of the name and address of each political

committee from which transfers are received, together with the

dates and amounts of each transfer•
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Our examination of the Committees' receipt records

and a comparison of the Committees' reports to reports of other

political committees filed with the Commission disclosing transfers

to the Corman Committees revealed 10 transfers that were not

itemized by the Corman Campaign Co~ittee. Of 74 transfers

received by the Committee, these 10 transfers, or 13.51~ were not

itemized. Thcse 10 transfers totaled $795.00 and reprcspnted

1.85% of the total of transfers received.

Recommendation

Since the Conunit1,'c filed amended reports on ~.pri1 3, 1978,

itemizing the above m(~ntioned transfers, the Audit staff reconuncnds

that no further action be taken on this matter•
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FEDERAL ELECTION CO~1,\1ISSION

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A1DITIONAL JNFOm.fATION REGARDING '!HIS ORGANIZATION

MAY BE lOCATED mA CDMPLETED COMPLIANCE ACIION

FIlE RELEASED BY THE CDMISSION AND MADE PUBLIC IN

'1HE PUBLIC RECDRDS OFFICE. FUR'lHIS PARTICl1lAR

ORGANIZATION'S CXH'LETED COMPLIANCE ACTION FlLE

SlMPLY JSK FOR '!HE PRESS SUt+1ARY OF MJR 41 6" 6

'DiE PRESS StM-fARy WILL PROVIDE A BRIEF HIsroRY OF

'!BE CASE AND A StM1ARY OF 'mE ACrIONS TAKEN, IF I-El•

Audit 1ft 135'