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FEDERAL ELECTION COMMISSION

W~SHINC10N. DC 2(Mt,J

REPORT OF 'l'HE AUDIT DIVISION

ON THE

REPUBLICAN STATE CENTRAL COMMI'1"1'EE OF IOliA

AND ITS

FINANCE COMMI'1"1'EE

I. Background

A. Overview

This report is based on an audit of the Republican

state Central Committee of Iowa and its Finance Committee ("the

Committee"), 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

provisions of the Federal Election Campaign Act of 1971, as

amended ("the Act"). The audit was conducted pursuant to Section

438(b) of Title 2 of the United States Code which states 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 shall 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 Comptroller General

of the United States on April 17, 1972. The Committee maintains

its headquarters in Des Moines, Iowa.

The audit covered the period January 1, through December

31, 1980. The Committee reported a cash balance at January 1,

1980 of $2,174.88, total receipts for the period of $953,884.28,

total disbursements for the period of $938,082.35, and a cash

balance on December 31, 1980 of $17,976.81.

This audit report is based on documents and work papers which support each of its factual statements. They form part of

the record upon which the Commission based its decisions on the

matters in the report and were available to the Commissioners and

appropriate staff for review.
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B. Key Personnel

The Treasurer of the Committee during the period covered

by the audit was Ms. Martha Charles.

C. Scope

The audit included such tests as verification of total

reported receipts and expenditures and individual transactionsJ

review of required supporting documentation and analysis of

Committee debts and obligationsJ and such other audit procedures

as deemed necessary under the circumstances.

II. Finding and Recommendation

A. Disclosure of Federal and Non-Federal Activity

Section 102.5(a) (1) (i) of Title 11 of the Code of

Federal Regulations states, in relevant part, that a political committee which finances political activity in connection with

both federal and non-federal elections and has established a

separate federal account in a depository shall treat such an

account as a separate federal political committee which shall

comply with the registration and reporting requirements of the Act.

Our review of the reports filed by the Committee revealed

that the Committee disclosed the activity of its non-federal account

as well as its federal activity. The committee's reports were

prepared in such a manner that federal activity was indistinguishable

from non-federal activity. By reporting both federal and nonfederal activity, it appears that the Committee has not treated the

federal account as a separate political committee.

The Committee officials acknowledged the disclosure of

federal and non-federal activity in reports filed with the

Commission and stated their intent to begin reporting only federal

activity at the earliest possible date.

Recommendation

It is the recommendation of the Audit staff that the Committee

discontinue the disclosure of non-federal activity in reports filed

with the Commission with the next report filed after receipt of

this audit report.