• A81-33

FEDERAL ELECTION COMMISSION

WASHINCTON, 0 C 204bl

REPORT OF THE AUDIT DIVISION

ON THE

LEAGUE OF CONSERVATION VOTERS CAMPAIGN FUND

..

r··

;'

I. Backqround

A. OVerview

This report i. based on an audit of the League of

Conservation Voters Campaign Fund (Wthe CommitteeW), undertaken

by the Audit Division of the Federal Election Commission in . accordance with the Commission's audit policy to determine whether

there has been compliance with the provi.ions of the Federal

Election Campaign Act of 1971, as amended (Wthe ActW). The audit

was conducted pursuant to Section 438(b) of Title 2 of the United

States Code which states, in part, that the Commission may conduct

audits and field investigations of any political committee required

to file a report under Section 434 of this title. Prior to

conducting any audit under this section, the Commission ahall

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.

The Committee registered with the United State. Bou.e

of Representatives on April 17, 1972 as an affiliate of the League of Conservation Voters (LCV). The Committee was organized by the

LCV and its purpose is to give financial support to federal candidates

that are endorsed by LCV. The Committee maintains its headquarters in Washington, D.C.

The audit covered the period from January 1, 1980 through December 31, 1980. The Committee reported an opening cash balance

of $2,346.85, total receipts of $125,894.00, total expenditures of

$128,302.10, and a closing cash balance of ($61.25) !I during the

period.

This report i. based on documents and working papers supporting each of its factual statements. They fo~ part of

the record upon which the Commission based its decisions on the

matters in the report and were available to the Commis.ioners

and appropriate staff for review.

•!/ The correct bank balance is $208.75J the negative balance

was created by the Committee reporting as a disbursement

a check that was returned by the bank.
...-

__ I

,......

. .,

it..,

'-'-.,

-2-

B. Key Personnel

The officer. of the committ.. during the period aUdited

were a. follow.: Mr. Rafe Pomerance, Trea.urer, January 1, 1980

through January 31, 1980 and Ma. Marion Edey, Trea.urer, January 31, 1980 through December 31, 1980.

C. Scope

The audit ·included such te.t. a. verification of total

reported receipts, expenditure. and individual tran.action.,

review of required supporting documentation and analy.i. of

Committee debts and obligations, and .uch other audit procedures

as deemed necessary under the circumstance••

II. Audit Finding and Recommendation

A•

Section 434 (b) (2) (F) of Title 2 of the United Stat•• Code states, in part, that each report shall disclose transfers

from affiliated committees•

Section 104.3(a) (4) (iii) (8) of Title 11 of the Code of

Federal Regulations states, in part, the aggregate year-to-date total shall be reported for each transfer of funds from affiliated

committees.

The Committee did not itemize three (3) August 1980

transfers from LeV totaling $12,000, although the total was

included on the Detailed Summary Page. On January 26 and

February 13, 1981, the Committee was requested by the Commission's

Reports Analysis Division to provide a Schedule A in support of

these transfers, the Committee did not respond. In addition, the

Committee did not correctly disclose the aggregate year-to-date totals for 28 of the 30 transfers it received from LeV during 1980.

In the interim audit report, the Audit staff recommended

that the Committee submit a Schedule A itemizing the three (3)

transfers from LeV and submit an amendment disclosing the correct

aggregate year-to-date totals for the 28 transfers from LeV.