407 West Jefferson, Boise, Idaho 83702 

November 7, 2022 

Sent Via Email 

Federal Election Commission 

Audit Division 

Rebecca Yarbrough 

1050 First Street, NE 

Washington, DC 20002 

Re: Campaign Comment and Response to Draft Final Audit Report 

Jim Risch for U.S. Senate 

FEC No. C00440362 

Dear Ms. Yarbrough, 

Please accept this correspondence as the Jim Risch for U.S. Senate Committee’s 

comments and response to the Draft Final Audit Report dated October 20, 2022. The 

Committee provides this repose as a supplement to its prior response to provide proof of 

compliance. 

Finding Two: Receipt of Contributions in Excess of the Limit 

(Supplemental Response) 

A. No request for Refunds. 

As stated in the draft report the Committee sent redesignation letters to certain 

applicable donors. The Committee can now report that it did not receive any requests for 

refunds as a result of any of those letters; thus the contributions as noted in the corrected 

public record are now accurate. 

B. Proof of refunds attached. 

The draft report states on Page 11: 

“The Audit staff notes that JRUSC did not provide copies of the front and back of the 

$20,300 in negotiated checks or evidence that any refunds not cashed by the 

contributors have been disgorged to the U.S. Treasury. Absent this documentation 

demonstrating that the excessive contributions are no longer in JRUSC’s bank account, 

the Audit staff concludes that JRUSC has not resolved this finding.” 

Attached to this correspondence are the front and back of fully negotiated checks 

reflecting refunds and disgorgements related to the above quoted language. More specifically 

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Sincerely, 

R. John Insinger 

these are refunds to Karfunkel and Rebholtz and disgorgements of the Moujtahed, Blue, Farr 

and Lindsey contributions. The cancelled checks total $14,700. 

The remaining $5,600 constitutes a single refund to Marc Brinkmeyer. Mr. Brinkmeyer 

is the president of an Idaho company and is personally known by the by the Committee. The 

attached email communication regarding this check indicates the donor cashed the check, 

however, there remains a discrepancy as the cancelled check is not showing up in the 

Committee’s bank records thus a canceled check cannot be provided. The Committee is in 

regular contact with this donor, with the last communication as recent as the date of this 

reply, and is confident that the contribution will be resolved. If for some reason the money is 

not removed from the Committee’s bank account through the original check, another check 

can easily be issued and this particular excessive contribution will be resolved. 

The Committee believes this additional information, along with the previous responses 

evidence that the Committee has worked diligently to resolve all the issues as requested a 

result of the audit. Presuming this repose is provided to the Commission and/or the contents 

are incorporated in a report to the Commission, the Committee sees no need to request a 

formal hearing. 

Very truly yours, 

Jim Risch for U.S. Senate 

Campaign Treasurer 

Attachments: Canceled checks and email correspondence (11 pages). 

Cc: Sheraline Thomas via email 

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