A8l-4'2

FEDERAL ELECTION COMMISSION

WASHINCTON. D.C. 20463

REPORT OF THE AUDIT DIVISION

ON THE

SOUTH CAROLINA REPUBLICAN PARTY C~~AIGN '80' FUND

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I. Background

A. Overview

This report is based on an audit of the South.Carolina

Republican Party Campaign '80 Fund ("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) ~f Title 2 ~f

the united States Code which states, in part, that the .. Commission may conduct audits and field in7estigations of any ..r'A:>litical committee required to file a rep~rt under Section 434 ~f this title. Prior to conducting any audit under this section, ~" the Commission shall perform an internal review of reports filed

f."' by selected committees to determine if the reports·filed by a

particular committee meet the threshold re~uirements for ~'" substantial compliance with the Act.

The Committee register~d with the Federal Election Corr~ission on February 27, 1976~ The Co~ittee maintains its " , headquarters in Columbia, South Carolina.

The a~dit covered the period Jan~ary 1 through December

31, 1980. The Co~~ittee reported a cash ca1ance January 1, 1980

of $124.58; total receipts for the period of $143,832.33; total

disbursements for the period of $125,373.53: and a cash balance

on December 31, 1980 of $18,583.38.

This audit report is based on dc:u~ents and working

papers which support each of its factual s~atements. They form

part of the record upon which the Commiss:on based its decisions

on the matters in the report and were available to the Co~missioners and appropriate staff for re7iew.

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Section 434(b) (1) (2) and (4) of Title 2 of the United

States Code states, in part, that each report filed by the

treasurer of a political committee shall disclose the amount of ,...ash on hand at the beginning of the reporting period: for the'

·..,eporting period and the ca~endar year, the total amount of all _ receipts: and for the repor~ing period and the calendar year, the

total amount of all disbursements. .

The understatement of reported receipts was created by

the omission of one bank deposit from repo:ted activity, and the

understatement of cash disbursements resulted from clerical

errors (such as typing errors) in report F:eparation. AltQough

such errors and omissions could have been ?revented by a

reconciliation of reports to bank activity at the time of report preparation, the Committee stated that reconciliations were-not

performed.

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Misstatements of Financial Activity

Key Personnpl

A.

B.

II. Findings and Recommendations

The Treasurer of the Committee from January 1, 1980 to

June 15 was Mr. Wayne Adams: from June 15 to August 10, 1980, Mr.

Wallace Towe: and from August 10, 1980 th:ough December 31, 1980,

Mr. Martin Suber.

C. Scope

The audit included such tests as verification of total

reported receipts and expenditures and individual transactions:

review of required supporting documentation and analysis of , Committee debts and obligations: and such other audit procedures 'as deemed necessary under the circumstances.

As part of routine audit proced~:es, the Committee's

reported cash at January 1, 1980, and cash receipts and

r' disbursements for the calendar year ending December 31, 1980 were

reconciled with bank statements for the s~e period. The

reconciliation revealed that receipts were understated by $3,444.95 or 2.4% of the reported tQtal, a~d disbursements

understated by $11,483.04 or 9.2% of the reported total. The net -. effect of these misstatements was an overstatement of ending cash

by $8,038.09 or 43.2% of the reported total.
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In the Interim'Audit report; the huditstaff

recommended that the Committee file a co~~:ehensive amendment

correcting the total amount ,of reported receipts, disbursements, . -and cashon hand for the year ending Dece::~er 31, 1980'and for su~sequent reporting periods. --,". . .

On January 11, 1982, the Commit~ee sub~itted a . ,comprehensive amendment correcting the reported totals for the 1~80 Year End report and.subsequent.reporting periods.

Recommendation

On the basis of the amendments submitted by the Committee,.

the Audit staff recommends no further action on this matter.

B. Disclosure of Contributor Identification

Section 434(b) (3) and 431(13) (A) of Title 2, United r~ States Code, states, in part, that each report shall disclose the' " identification (the name, mailing address, occupation, and n~e

:. of employer) of each person who makes· a contribution to the . -, reporting committee in an aggregate amount or value in excess of . $200 within a calendar year, together with the date and amount of

'.ny such contribution., . " '. . .: .... ' . ., .

Section 104.7(b) of Title 11, Code of Federal .' C~ ·Regulati~ns, states, in part, that a treasure~ will not be deemed

to have exercised best efforts to obtain the identification of a : " cont~ibutor, unless he or she had made at least one effort per r~ solicitation either by a written request 0: by an oral request documented in writing ,to obtain·, such info:tlation. from the, contributor. .. ",'" - -

Our review of the Committee's receipt records revealed,

that the contri.butor' s "name of employer n was not disclosed on

schedules A for 91 contributions or'80.5% of the 113

contributions requiring such information. ..

Three (3) contributor cards used by the Committee in

their fundraising events were provided for our review. Two (2) of these cards were used in 'direct mail e:forts, and both . reauested comolete contributor identification. The third card

omitted the request for the contributor's nna~e of employer".

The Co~~ittee Treasurer stated that this card was used in a~l

other fundraising activities, primarily ~~:so~al solicitations.

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