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FEDERAL ELECTION COMMISSION

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A83-120

REPORT OF THE AUDIT DIVISION

ON THE

RHODE IS~AND REPUBLICAN CAMPAIGN COMMITTEE

I. Background

A. Overview

This report is based on an audit of the Rhode Island

Republican Campaign Committee ("the COffimittee"), 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, 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 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 Federal Election

Commission on June 24, 1977 and maintains its headquarters in

Providence, Rhode Island.

The audit covered the period January 1, 1981 through

December 31, 1982. The Committee reported a beginning cash

balance on January 1, 1981 of $-0-; total receipts for the period

of $91,146.32; total disbursements for the period of $91,031.02;

and an ending cash balance on December 31, 1982 of $115.30.

This report is based on docu~ents and work papers

supporting each of its factual statements. They form part of the

record upon which the Commission based its decisions on the

matters in this report and were available to Commissioners and

-4 appropriate staff for review.
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B. Key Personnel

The Treasurers of the Committee during the period

covered by the audit were Mr. Ernest R. Beaulieu from January 1,

1981 through June 10, 1982 and Mr •.Jonathan T. Isham from June

11, 1982 through the present.

c. Scope

The audit included such tests as verification of total

reported receipts and disbursements and individual transactions;

review of required supporting documentation; analysis of

Committee debts and obligations; and such other audit procedures

as deemed necessary under the circumstances.

II. Audit Findings and Recommendations

A. Itemization of Receipts

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Section 434(b) (3) (A) of Title 2, United States Code,

states in part, that each report shall disclose the

identification of each person (other than a political committee)

who makes a contribution to the reporting committee, whose

contribution or contributions have an aggregate amount or value

in excess of $200 within the calendar year, together with the

date and amount.

Section 434(b) (3) (C) of Title 2, United States Code,

states that each report shall disclose the identification of each

authorized committee which makes a transfer to the reporting

committee.

Section 434 (b) (3) (E) of Title 2, United States Code,

states in part, that each report shall disclose the

identification of each person who makes a loan to the reporting

committee together with the date and amount.

A review of the Committee's contribution records

revealed the following:

1. The Committee received 18 contributions totaling $4,363.35 requiring itemization which were not itemized. This

represents 19% of the number and 12% of the dollar value of

contributions requiring itemization.

2. The Committee received a $1,250 contribution from

an authorized political committee which ~as not itemized. This

·4 re:presents 50% of the number and 33% of the dollar value of

contributions from political committees•

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3. The Committee received a $2,000 bank loan on April 28, 1981 which was not itemized as required, and reported a

$5,000 bank loan as a transfer from the Rhode Island Republican

Party.

On April 2, 1984, the Committee filed the necessary amendments to correct the three reporting deficiencies.

Recommendation

Based on the above, the Audit staff recommends no further

action.

B. Recordkeeping for Contributions

Section 432(c) of Title 2, United States COde, states

in part, that the treasurer of a political committee shall keep

an account of all contributions received by or on behalf of such

political committee as well as the name and address of any person

who makes any contribution in excess of $50, together with the

date and amount.

For the period covered by the audit the Committee's

recordkeeping procedures consisted of maintaining:

1. photocopies by deposit of all contributions

received in the form of checks;

2. deposit slips listing the contributors' surnames

and amounts of contributions; and

3. an alphabetized contributor card file of all

contributions received.

Committee officials stated that subsequent to the audit

period the Committee underwent a change in the personnel who

maintained the financial records and, in addition, relocated

their office headquarters. In the transition, the contributor

card file and a portion of the deposit batches (deposit slips and

photocopies of contributor checks) were misplaced.

Our initial review indicated that the missing batches

comprised $30,027.70 in contributions. At the Audit staff's

request, photocopies of the missing deposit slips listing the

contributors' surnames and amounts of contributions were obtained

from the bank. As a result we determined that there were 92

contributions, each in excess of $50, totaling $12,630.05 for

which the contributors' full names and mailing addresses were

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Due to the circumstances surrounding the loss of the

original contributor records and to the fact that the Committee's

current system is at least as efficient as the former system (both of which include features beyond the requirements of the

Act), the Audit staff is of the opinion that no benefit can be

derived from further Committee action.

Recommendation

The Audit staff recommends no further action on this matter.

C. Matter Referred to the Office of General Counsel

A certain matter noted during the audit was referred to

the Commission's Office of General Counsel on April 17, 1984.

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