1090 Vermont Ave NW, Suite 750 SANDLER REIFF Washington, DC 20005 

www.sandlerreiff.com 

ROSENSTEIN & BIRKENSTOCK, P.C. T: 202-479-1111 

F: 202-479-1115 

SANDLER REIFF LAMB 

July 26, 2022 

Ms. Dayna C. Brown 

Assistant Staff Director 

Audit Division 

Federal Election Commission 

1050 First Street, N.E. 

Washington, D.C. 20463 

Dear Ms. Brown: 

This letter will serve as the response ofthe Sheila Jackson Lee for Congress ("SJLC") to the 

Interim Audit Report ("IAR") ofthe Federal Election Commission's Audit Division ("the Audit 

Division") for the period covering the SJLC's financial activities for 2019 and 2020. 

The response to each ofthe Audit Division's three findings is as follows: 

Finding #1 

The IAR's first finding involved the apparent misreporting of financial activity during the 

calendar years 2019 and 2020. Based upon schedules provided to the committee by the Audit 

Division, SJLC has filed comprehensive amendments to all reports during these calendar years in 

accordance with the documentation provided by the Audit Division. 

It should be noted that two items identified as misreported on the documentation were 

memo entries. Therefore, SJLC's amendments slightly deviated from the documentation as these 

transactions should not have been included in the Audit Division's analysis. Notwithstanding, all 

opening and closing cash on hand numbers matched the Commission's analysis. 

Finding #2 

The IAR's second finding involved the apparent receipt of contributions in excess ofthe 

limits. The contributions fell into two categories. 

First, certain contributions, while within the aggregate limits for the 2020 election cycle, 

required certain documentation to be provided to the donors so that the committee could 

presumptively redesignate or reattribute their excessive contributions from the primary election 

contribution limit to the general election contribution limit or to a spouse, as applicable. The IAR 
requested that SJLC either provide a copy ofthis documentation or send letters to the affected 

donors. In response to the IAR, SJLC, through counsel, has sent letters to all donors who could 

have received a presumptive redesignation or reattribution letter. A complete set ofthese letters is 

attached to this response as Exhibit A. 

Second, certain contributions that exceeded the combined primary and general election 

limits and could not otherwise be presumptively reattributed to a spouse were required to be 

refunded to the donor or disgorged to the U.S. Treasury. In response to the IAR, SJLC has issued 

refunds to all such donors. A list ofrefunded checks are attached in Exhibit B. 

Finding #3 

The third finding involves the apparent receipt of contributions from prohibited sources. 

These contributions can be separated into two categories. 

First, the Audit Division identified contributions from five Limited Liability Companies 

("LLC"). Under Commission regulations an LLC may contribute to a federal campaign ifit has 

selected taxation as a partnership. A committee may not accept a contribution from an LLC if it is 

taxed as a corporation. Committees must obtain documentation from the LLC that it is taxed as a 

partnership. The Audit Division has requested that SJLC provide documentation that the LLC's in 

question were taxed as a partnership. In response to the Audit Division's request, SJLC has 

contacted the five LLC's and requested documentation as to their taxation status. To date, two of 

the five LLC's have responded affirmatively to the committee to provide the necessary 

documentation. This documentation is attached as Exhibit C. SJLC continues to seek 

documentation form the other three LLC's and will provide that information as soon as possible. If 

SJLC is unable to obtain this documentation in the near future, it will refund the donations or 

disgorge those funds to the U.S. Treasury. 

Second, the Audit Division identified contributions that were received from corporations. 

In response to the IAR, SJLC has refunded all such contributions. A list ofrefunded checks are 

attached in Exhibit B. 

Ifyou require any further information, or have any other questions, please call me at (202) 

479-1111. 

Sine}/, 

NeilReiff # 

Counsel to Sheila Jackson Lee for Congress