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130 North 18th Street | Philadelphia, PA 19103-6998 

Blank Rome LLP | blankrome.com

February 14, 2022

VIA EMAIL

Zuzana Pacious

Federal Election Commission 

Audit Division

1050 First Street, NE

Washington, DC 20463

Re: Response to Draft Final Audit Report 

US Veterans Assistance Foundation

LRA 1105 

Dear Ms. Pacious:

We submit this Response to the Draft Final Audit Report (“DFAR”) provided by the 

Audit Division on January 25, 2022. USVAF declines its option to request a hearing. 

US Veterans Assistance Foundation (“USVAF”) has operated as a nonconnected, 

expenditure-only political action committee since 2017. USVAF uses independent expenditures to 

support candidates and political causes devoted to addressing veterans’ issues, such as 

homelessness. Mr. Piaro and his family hold veterans’ issues near and dear to their hearts. Mr. 

Piaro served in the Marine Corps in Vietnam from 1968 through 1969. He lost a leg during his 

service. After serving the United States in Vietnam, Mr. Piaro devoted himself to supporting 

veterans. 

Prior to forming this committee, Mr. Piaro operated two successful 501(c)(3) organizations 

dedicated to combating veteran homelessness. One was based in Wisconsin (Veterans Assistance 

Foundation) and one was based in California (California Veterans Assistance Foundation). Both 

organizations provided housing assistance, including providing homes for veterans. It also 

provided assorted other assistance, such as securing employment or food. Mr. Piaro formed 

Veterans Assistance Foundation in 1994 with the support of former Wisconsin Governor Tommy 

Thompson. Governor Thompson requested that Mr. Piaro establish and run a state-supported 

program in conjunction with the Wisconsin Department of Veterans Affairs. Mr. Piaro received a 

Phone: 215 - 569 - 5536

Fax: 215 - 832 - 5417

Email: mmlee@blankrome.com
Federal Election Commission, Audit Division

February 14, 2022

Page 2

grant from the Wisconsin Department of Veterans Affairs to start the program. Mr. Piaro served 

as President and CEO of both organizations until 2016, when he transitioned his support for 

veterans issues into a political effort. 

Mr. Piaro formed USVAF as a political action committee to support federal political 

campaigns and candidates who support veterans issues and address veteran homelessness. Unlike 

many PACs that operate behemoth political organizations, Mr. Piaro formed USVAF as a familyrun committee supported only by Mr. Piaro and his two daughters, Michelle Hammen and Melissa 

Stetler. Both daughters are employed full-time as nurses. They engage in USVAF related activities 

in addition to their full-time jobs. 

A novice to the world of political campaigns at the time he founded USVAF in 2017, Mr. 

Piaro engaged a small law firm based out of Milwaukee, Wisconsin to provide counsel and 

compliance advice related to Federal Election Commission statutes and regulations. The law firm 

presented itself to Mr. Piaro as experienced in the industry and Federal Election Commission 

matters. Unfortunately, the law firm’s services during 20 17 and 2018 were not satisfactory. It was 

during this time that USVAF encountered numerous reporting issues. Without adequate legal 

counsel these issues accumulated. After about a year of experience in the industry, Mr. Piaro began 

to recognize these ongoing issues. As a result, USVAF ended its relationship with the former law 

firm. He thereafter began his relationship with Blank Rome LLP. 

As a small, family-run committee, USVAF relies on the expertise and support of outside 

vendors. The vendors provide support in each one’s area of expertise, including solicitations, 

marketing, and general fundraising support. An accounting firm, EWH, provides accounting and 

related services. The required Federal Election Commission reporting is provided by a reporting 

team that has improved drastically at the reporting function over time. 

Consequently, USVAF has drastically improved its reporting procedures and performance 

over time. This improvement has coincided with ongoing efforts to develop and implement an 

effective filing software. After more than two years of effort and refinement, the FEC approved 

the filing software, PACSmart, that USVAF’s reporting team uses to file required reports. The 

improvement in processes and procedures decreased the rate of requests for additional information 

(RFAIs) by 70% from the reports related to the 2018 election cycle (10 RFAIs) to the reports 

related to the 2020 election cycle (3 RFAIs). In addition, with the support of Blank Rome, the 

assorted vendors continue to refine their practices to improve compliance, particularly as it relates 

to recordkeeping and reporting. 

USVAF has demonstrated the improvements to the process and procedures throughout this 

letter response. Each response to a finding includes not only a general explanation or response to 
Federal Election Commission, Audit Division

February 14, 2022

Page 3

the DFAR Finding, but also an explanation of the improvements in process and procedures as 

applied to the specific issue raised in each finding. Simply put, USVAF submits that the issues 

highlighted in the DFAR Findings would not occur today. USVAF submits the following 

responses to each DFAR Finding.

I. Finding 1 – Misstatement of Financial Activity 

During audit fieldwork, a comparison of USVAF’s reported financial activity with its bank 

records revealed a misstatement of disbursements and the ending cash balance for calendar year 

2018. USVAF overstated its disbursements by $244,141 and understated its ending cash balance 

by $224,021. 

In response to the exit conference, USVAF stated that the overstatement of disbursements 

relates to a voided check to a vendor totaling $225,000. USVAF explained that its accounting firm 

voided this check but did not inform USVAF’s reporting team of the void. USVAF provided its 

December 2018 general ledger reflecting the voided payment and stated it would file an amended 

disclosure report. USVAF further explained that this error occurred due to communication issues 

between its accounting and reporting team and the lack of a standardized reconciliation process at 

that time. USVAF stated it has adjusted its process to improve reporting and avoid similar errors 

in the future. Additionally, it has instituted a two-level reconciliation prior to filing and improved 

communication between the accounting and reporting teams and it “will provide the appropriate 

amendments.” To date, the Audit staff maintains that USVAF has not correctly amended its reports 

to disclose the voided check.

The Audit staff recommends that USVAF amend its 2018 Year-End Report to include 

$200,000 check to “Congressional Leadership disbursement. Additionally, the five 2018 

disclosure reports USVAF amended in August 2021, contained a notation of the “discovery of the 

PayPal Account during this audit.” As a result, the amended reports reflect an increase in receipts 

totaling $71,385.The corresponding cash on hand increased accordingly. USVAF did not provide 

the monthly PayPal statements to the Audit staff in response to the audit notification. The Audit 

staff recommends that USVAF provide all monthly PayPal statements to the Audit staff for review 

and inclusion in the bank reconciliation. The Audit staff concludes that 2018 disbursements and 

ending cash on hand remain materially misstated by $198,327 and $237,251 respectively.

A. Response

In August 2021, USVAF filed the requested amendments and forms to address the issues 

identified in Finding 1 of the Interim Audit Report. Given the further purported issued identified 

by the FEC in the DFAR, USVAF will file amended reports. 
Federal Election Commission, Audit Division

February 14, 2022

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B. Implementation of Process and Improvements

As the DFAR acknowledges, USVAF has adjusted its process to improve reporting and 

avoid similar errors in the future. USVAF has instituted a two-level reconciliation prior to filing 

the required reports. First, EWH reconciles the expenses with the bank statement and other 

financial records. Second, USVAF’s reporting team has established a reconciliation process. After 

the reporting team receives from EWH the monthly expense reports, payroll reports, and relevant 

statements, the reporting team reconciles all of the bank statements with the expense reports to 

identify any issues. The filing software, PACSmart, also includes internal systems that identify 

discrepancies between bank statements and the FEC report. 

USVAF has also improved communication between the accounting and reporting teams. 

The reporting team has established a direct line of communication with EWH to resolve questions 

or issues for reporting expenses before filing reports. They have also established a process to 

provide source documents when necessary. EWH sends monthly payroll reports and expense 

reports to the reporting team. This improved communication and process has allowed the reporting 

team to review and reconcile all appropriate records. USVAF also continues to coordinate with 

the FEC to improve its reporting to comply with the FEC requirements and the FEC’s 

interpretation of these regulations. 

II. Finding 2 – Increased Activity

A comparison of USVAF’s bank activity with its originally filed reports revealed 

that disbursements were understated by $2,795,679 for calendar years 2017 and 2018. In 

response to the Interim Audit Report recommendation, USVAF reiterated its earlier response 

to the exit conference by stating that its original 2018 July Quarterly and October Quarterly 

Reports were inadvertently uploaded without all of the corresponding disbursements. 

USVAF stated that it has implemented “processes and procedures to avoid similar errors in 

the future.” USVAF cited its improved communication and document sharing with its 

accounting firm; and the added functions and technical features to its filing software to detect 

discrepancies between the software reports and the bank statements. The Audit staff 

concludes that USVAF misstated disbursements by $2,795,679, on its originally filed 

reports.

A. Response

USVAF reiterates that it has previously filed amendments to correct the reporting errors. 

USVAF corrected the 2017 error with amendments filed on November 8, 2018 (FEC-1290974). 

This related to a payment to a vendor, TPFE, for fundraising expenses. Similarly, USVAF has 

previously filed amendments to correct the $2,700,458 difference between the schedule of reported 
Federal Election Commission, Audit Division

February 14, 2022

Page 5

activity on the original FEC report and the bank statements that occurred in 2018.

Of the $2,700,458 that went unreported in the original reports filed in 2018, $2,134,594.30 

related to the July 2018 Second Quarter report. Put simply, the member of the filing team who had 

filing responsibilities at that time filed the report without uploading the expenses. USVAF and its 

reporting team amended that error on November 12, 2018 (FEC-1291189). The reporting team no 

longer employs this particular person due to frequent issues and errors. In addition, the current 

processes, described in detail in Section II(B), would identify this error prior to filing the report. 

B. Implementation of Process and Improvements

The DFAR recognizes that USVAF has also implemented processes and procedures to 

avoid similar errors in the future. As an initial point, the improved communication between EWH 

and the reporting team, as well as the increased sharing of source documents required for filing, 

has alleviated many of the errors that occurred in 2017 and 2018. For the 2017 error, with a 

difference of $95,222, the reporting team now communicates with EWH, receives expenses and 

bank statements, and reconciles the amounts included on the expense reports compiled by EWH 

against the bank statements and other relevant financial data.

Likewise, the current reconciliation process would detect issues before filing reports in the 

future. The increased communication between the reporting team and EWH, and the monthly 

expense documents provided by EWH to the reporting team, have together greatly improved the 

process for reporting. For further detail, USVAF has instituted the following improvements:

 Added a function to the PACSmart filing software that produces a color-coded variation 

report to detect differences between deposit and disbursement data in comparison to the 

bank statements;

 When populating the F3X form, the PACSmart filing software color codes the deposit 

and disbursement totals in comparison to the bank statements;

 Added a "Check for Problems" system into the PACSmart software. The system applies 

an array of tests, including a check that expenses are included, a warning if expenses are 

not included in the FEC report, a check that donations and deposits are uploaded into the 

report, checks for common and/or problematic descriptions for disbursements, checks for 

records missing addresses and/or names, and other common reporting issues; 

 Integrated the FEC's "Validation Tool” to review the report to detect issues such as 

missing treasurer signature, missing name/address/employer/occupation, or other 

common reporting issues; 

 Implemented a filename/upload tracking system to review the names/data for particular 

files that have been uploaded. This tool ensures that the reporting team has properly 
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February 14, 2022

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uploaded expenses to the report;

 Implemented a "Checklist" system to track the steps by the reporting team to prepare the 

FEC filing, who performed the task, and any relevant notes related to each step. The 

checklist includes a detailed breakdown and instructions to file the report. 

III. Finding 3 – Disclosure of Occupation and Name of Employer

During audit fieldwork, a review of all contributions from individuals requiring itemization 

indicated that 160 contributions totaling $40,850 lacked or inadequately disclosed the required 

occupation and/or name of employer information. USVAF did not sufficiently demonstrate “best 

efforts” to obtain, maintain and submit the required information. In response to audit fieldwork, 

USVAF provided some documentation of “best efforts,” however, USVAF has not filed amended 

reports to disclose and report the missing or inadequate information. 

USVAF stated that, in relation to the disclosure of missing information, it is “currently 

investigating” and will amend its disclosure reports to include this information to the extent it 

possesses the information. In relation to the “best efforts” documentation, USVAF stated that it 

continues its investigation to obtain and produce “best efforts” documentation for the contributions 

discussed during the exit conference.

The Interim Audit Report recommended that USVAF amend its reports or file a Form 99 

(Miscellaneous Electronic Submission) to report and submit the occupation and/or name of 

employer information for the 160 contributions. In response to the Interim Audit Report 

recommendation, USVAF stated that it amended its reports to include “...this missing information 

to the extent it possesses the information.” As for the “best efforts” documentation, USVAF 

“continues its investigation to obtain and produce “best efforts” documentation to the satisfaction 

of the FEC for contributors for whom USVAF has not received employer/occupation

information.” The Audit staff concludes that USVAF materially corrected the public record by 

amending its 2017 and 2018 disclosure reports to include this previously missing or inadequate 

occupation and name of employer information.

A. Response

USVAF agrees with the conclusion of the FEC that it materially corrected the public 

record. This finding should be withdrawn.

B. Implementation of Process and Improvements

The reporting team has instituted an internal process to update and amend the occupation 

and employer information on a regular basis. The internal process, a DEEP SEARCH system, 
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February 14, 2022

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scans the donation information from all available records uploaded to the related committees to 

locate contributors who had missing employer and occupation information. The DEEP SEARCH 

process is manually executed by the reporting team, generating a current list of donors missing 

employer/occupation information and feeds them through the DEEP SEARCH system. The 

reporting team analyzes the results and updates contribution records. In addition, a system error 

that impacted the collecting of updated employer/occupation information was identified and 

corrected, which has improved best efforts results. 

IV. Finding 4 – Disclosure of Disbursements

During audit fieldwork, the Audit staff identified 144 disbursements totaling $5,358,342 

with inadequate or inaccurate disclosure information. In response to the Interim Audit Report 

recommendation, USVAF stated that it was “...in the process of amending its reports to disclose 

accurate addresses and purposes and to address the FEC’s recommendation pertaining to 

disclosing itemized disbursements.” USVAF continued to deny it violated the applicable reporting 

requirements or that it lacked or had inadequate disclosure information and maintained that this 

information was correctly reported. USVAF did not correct the disclosure information for the 

disbursements included in this finding. The Audit staff concludes that USVAF’s disclosure reports 

continue to reflect inadequate or inaccurate disclosure information pertaining to disbursements 

totaling $5,358,342.

A. Response

USVAF is in the process of amending its reports to address the FEC’s recommendation 

pertaining to disclosing itemized disbursements. With regard to the 144 disbursements to major 

vendors totaling $5,358,342, USVAF again denies that it violated 52 U.S.C. § 30104. USVAF also 

denies that it lacked or had inadequate disclosure information. This information was correctly 

reported. The purported errors relate to accounting practices, specifically memo entries for 

payments, that § 30109(b) does not specifically address. The provision does not impose 

requirements that a committee disclose “payees” as a “memo entry.” 

The vendors listed—Unified Data Services LLC, Compliance Consultants LLC, and 

American Technology Services LLC––all received payments from USVAF. The statements 

USVAF previously submitted to the FEC demonstrate payment from USVAF to all vendors 

throughout all of 2018. While the vendors changed names and addresses in August 2018, the 

payments from USVAF to the vendors from August 2018 through December 2018 correlate to the 

vendor’s invoice number and as reported. 

USVAF will provide the FEC with an updated list of vendor addresses. USVAF has also 
Federal Election Commission, Audit Division

February 14, 2022

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corrected a vendor name.

B. Implementation of Process and Improvements

For the major vendor payments, USVAF will separate each wire transfer to the specific 

vendor such that three wire transfers to the three specific vendors will occur (as opposed to a single 

wire transfer). USVAF denies and objects to the finding that it violated 52 U.S.C. § 30104(b). 

V. Finding 5 – Recordkeeping for Disbursements and Use of Designated Depository

During audit fieldwork, the Audit staff identified payments totaling $5,456,675, which 

USVAF made to “Usvetassistfound,” however, USVAF reported these disbursements as 

payments to vendors on its disclosure reports. USVAF did not provide any “Usvetassistfound” 

bank statements to demonstrate that these payments were subsequently transmitted to the 

disclosed vendors. In response to the Interim Audit Report recommendation, USVAF reiterated 

that the payments were made to the intended vendors and not to “the U.S. Veterans Assistance

Foundation, LLC, nor any other entity or entities.” In response to the Interim Audit Report 

recommendation, USVAF further submitted the redacted bank statements obtained from four of 

its vendors which reflected 84 payments totaling $2,963,742, for the period January 1, 2018 

through August 9, 2018. However, the payments outlined on the redacted bank statements are 

not supporting and verifiable evidence that the disclosed vendors were paid with the funds 

transferred from USVAF’s bank account. USVAF provided no additional documentation for 

the remaining 63 vendor payments totaling $2,492,834. The Audit staff concludes that USVAF 

did not provide sufficient supporting and verifiable evidence that the disclosed vendor payments 

totaling $5,456,675, were made with the funds transferred from

USVAF’s bank account.

1. Recordkeeping for Disbursements

During audit fieldwork, the Audit staff identified payments totaling $5,456,675, which 

USVAF wired to “Usvetassistfound,” however, USVAF reported these disbursements as payments 

to vendors on its disclosure reports. USVAF did not provide any “Usvetassistfound” bank 

statements to demonstrate that these payments were subsequently transmitted to the disclosed 

vendors. USVAF denied it violated the applicable regulations and stated that it properly disclosed 

disbursements to its vendors.

According to USVAF:
Federal Election Commission, Audit Division

February 14, 2022

Page 9

• The vendors’ statements presented in response to the exit conference demonstrate 

payment from USVAF “to all vendors throughout all of 2018.”

• Three vendors changed their names and addresses in August 2018 but “the 

payments from USVAF to the vendors from August 2018 through December 2018 

correlate to the vendor’s invoice number.”

• “The purported entity “US Veterans Assistance Foundation LLC” does not exist.” 

USVAF made the ACH wire transfer in a single transfer to pay for all three vendors, 

as opposed to three separate wire payments, “because the single wire was a more 

cost effective and efficient way to transfer funds.” To support this assertion, 

USVAF submitted an attachment detailing PNC Bank wire transfers and invoices.

The Audit staff maintains that:

• USVAF did not provide sufficient and verifiable records to demonstrate that the 15 

vendors disclosed on the reports were paid by way of the disbursements discussed 

in this finding. USVAF’s bank statements indicate that the recipient of the wire 

transfers was a single entity titled “Usvetassistfound.” This entity appears to be the 

US Veterans Assistance Foundation, LLC. USVAF only provided vendor 

statements to support that all billed amounts presented were paid. USVAF provided 

no verifiable documentation to demonstrate whether “Usvetassistfound” 

subsequently made the payments to the disclosed vendors.

• Changes to the new names and addresses of vendors should have been reflected in 

USVAF’s disclosure reports. Unless such changes are disclosed, the public record 

is not accurate.

• The US Veterans Assistance Foundation, LLC registered with the Nevada 

Secretary of State on November 20, 2017, three months after USVAF registered 

with the Commission. In addition, while the Nevada Secretary of State discloses 

the LLC’s current status as “Revoked,” USVAF’s Treasurer, was listed as one of 

the managers of the LLC, along with two family members and, according to the 

public record, this entity was formed as a domestic limited liability company.

The Interim Audit Report recommended that USVAF provide supporting and verifiable 

evidence, such as bank statements, that the disclosed vendors were paid with the funds transferred 

from USVAF’s bank account to the “Usvetassistfound. The Audit Staff disagrees with the 

response of USVAF. The Audit staff recommends USVAF provide sufficient supporting and 

verifiable evidence to demonstrate that the 53 ACH transfers resulted in the 147 vendor payments 

USVAF reported on its disclosure reports. The Audit staff recommends that, in addition to the 

aforementioned transfer documentation, USVAF may also provide a written explanation from a 

bank official regarding how the ACH transactions appear on its monthly bank statements and 

how exactly the funds were transferred. The Audit staff maintains that USVAF did not provide 
Federal Election Commission, Audit Division

February 14, 2022

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sufficient supporting and verifiable evidence that the disclosed vendor payments totaling 

$5,456,675, were made with the funds transferred from USVAF’s bank account.

2. Use of the Designated Depository

In addition, USVAF failed to use its designated depository to make payments to vendors. 

The Audit staff identified 147 payments totaling $5,456,675 disclosed as payments to vendors 

which, according to USVAF bank statements, were instead wire transfers to “Usvetassistfound.” 

In response to the Interim Audit Report recommendation, USVAF disagreed with the Audit 

staff’s conclusion and maintained that the ACH transfers were made from its designated 

depository, as discussed in Part A above. The Audit Staff admitted that USVAF demonstrated 

“circumstantially” that these 84 payments appear to have reached its vendors as USVAF reported, 

but maintains that this is not sufficient. 

To demonstrate that the vendor payments originated from its bank account, the Audit staff 

recommends USVAF provide sufficient supporting and verifiable evidence such as, debit 

memorandum or similar electronic receipt for each payment to demonstrate that the 53 ACH 

transfers initiated by USVAF resulted in the 147 vendor payments reported on its disclosure 

reports. USVAF may also provide a written explanation from a bank official regarding how the 

ACH transactions appear on its monthly bank statements and how exactly the funds were 

transferred. The Audit staff concludes that USVAF has not provided sufficient supporting and 

verifiable evidence to support that the disclosed vendors were paid with the funds transferred from 

USVAF’s bank account.

A. Response 

With regard to the $5,456,675 in payments to major vendors, USVAF denies that it violated 

52 U.S.C. § 30102(d),(h) or 11 C.F.R. § 104.14. USVAF correctly reported this information. The 

vendors listed —Unified Data Services LLC, Compliance Consultants LLC, and American 

Technology Services LLC––all received payments from USVAF’s PNC checking account. The 

previously submitted statements demonstrate payment from USVAF to all vendors throughout all 

of 2018. 

USVAF correctly reported this information. The payees—Unified Data Services LLC, 

Compliance Consultants LLC, and American Technology Services LLC— were correctly 

reported, as was the address and purpose of the payment. USVAF made the ACH wire transfer in 

a single transfer to pay for all three vendor invoices. USVAF made the single wire payment, as 

opposed to three wire payments, because the single wire transfer was a more cost effective and 
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February 14, 2022

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efficient way to transfer the funds. USVAF has previously submitted proof of the wire payments 

to the Audit staff. During the period in question, for each of the ACH wire transfers made from 

USVAF’s designated depository with the stated vendors as intended recipients, PNC labeled the 

transfers “ACH Settlement Vendor Pay Usvetssistfound.” However, this label was created solely 

by PNC, and does not reflect payment to the U.S. Veterans Assistance Foundation LLC, nor to 

any entity or entities other than the intended vendors. 

The labeling of the wire transfers occurred as part of the process by which funds were 

transferred directly from USVAF’s designated depository to the vendors in question. For each 

payment to a vendor, only one transfer occurred—the payment from USVAF to the vendor, though 

it may have appeared that two transfers were being made—one from USVAF’s designated 

depository to “Usvetssistfound” (or, as the Audit staff has baselessly claimed, an intermediary 

entity) and one from “Usvetssistfound” to each of the vendors—because of the bank’s internal 

recordkeeping practice. Because this labeling process is controlled by the bank, USVAF’s ability 

to more clearly demonstrate the direct flow of funds from its designated depository to the vendors 

is limited. Although the FEC requested that USVAF provide a statement from a bank official to

explain the labeling of transactions, USVAF was unable to do so before the February 14, 2022

deadline.

Additionally, in August 2018, three vendors began invoicing under different names. The 

transition occurred after the August 8, 2018 invoice, and was billed through those names for the 

remainder of the year. USVAF has updated its records to reflect the vendor’s names as invoiced. 

For example, Compliance Consultants changed its name to as American PCI, American Tech 

changed its name to Unlimited Tech Support, and Unified Data changed its name to Cloud Data 

services. This information is verified from the vendor’s QuickBooks files, and vendors bank 

statements.

Regarding the Audit staff’s request for verifiable evidence, USVAF has made certain

amendments and has produced documents contemporaneous with this Response that support its

argument. Furthermore, USVAF objects to the Audit staff’s continued unsupported contention that 

the wire transfers in question went to an intermediary entity. Although the Audit staff concludes 

that this is the case, it has not provided any factual evidence or rationale to demonstrate how it has 

determined that the wire transfers were sent to an intermediary entity. Rather, it appears the Audit 

staff has simply decided that the wire transfer must have gone to an intermediary because the 

transaction on the bank statement includes the “Usvetssistfound” language. The Audit staff has 

not demonstrated any actual link between the wire transfer and an intermediary entity. 

On the basis of the foregoing, the Audit Division should withdraw its finding related to 

recordkeeping for disbursements and use of designated depository.
Federal Election Commission, Audit Division

February 14, 2022

Page 12

B. Implementation of Process and Improvements 

For the major vendor payments, moving forward USVAF will separate each wire transfer 

to the specific vendor such that three vendor wire transfers will show on the checking account 

statements each week (as opposed to a single wire transfer). USVAF denies and objects to the 

finding that it violated 52 U.S.C. § 30102(d), (h) or 11 C.F.R. § 104.14.

VI. Finding 6 – Failure to File 24/48-Hour Reports

During audit fieldwork, the Audit staff determined that USVAF untimely filed 48-hour 

reports for two independent expenditures totaling $17,000 and did not file the required 24-hour 

reports for two independent expenditures totaling $15,000. In response to the Interim Audit Report 

recommendation, USVAF stated that the errors were “unintentional” and it has implemented 

processes to ensure the filing of such reports in the future. The Audit staff concludes that USVAF 

untimely filed 48-Hour Reports for two independent expenditures totaling $17,000 and did not file 

24-Hour Reports for two independent expenditures totaling $15,000.

A. Response 

USVAF inadvertently failed to file the 24-hour and 48-hour reports. At the time, the 

reporting team and USVAF were establishing the appropriate protocols and processes to track and 

correctly report the independent expenditures. Once USVAF and its reporting team learned about 

the errors, USVAF reported these in its quarterly disclosure. USVAF and its reporting team also 

inadvertently failed to file the required F24 reports. Both errors were unintentional and the current 

process will ensure that all required 24-hour or 48-hour reports are filed, as are the F24 reports. 

B. Implementation of Process and Improvements

USVAF and its reporting team have implemented processes to ensure that it files all 24-

hour and 48-hour reports. The reporting team has direct contact with the Northstar Multimedia. 

The reporting team and Northstar Multimedia have also improved communication to avoid 

potential reporting issues. Northstar Multimedia alerts USVAF’s reporting team about all 

independent expenditures, dissemination dates, amounts spent, and the candidates/offices the 

independent expenditures support or oppose. Using that data and to obtain disbursement date with 

references to bank statements provided by EWH, USVAF and its reporting team generate the 

required F24 reports. 
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February 14, 2022

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Likewise, the reporting team has implemented software improvements to PACSmart filing 

software. For Schedule E's/F24s, the reporting team has made a major overhaul of the Schedule E 

system. It now includes the ability to import/export schedule E's into CSV/spreadsheet format, for 

ease of management/editing, and ease of population from the F24 reports into the Schedule Es of 

the next regularly scheduled F3X report. It also includes the ability to automatically calculate 

aggregate totals, based on the FEC's aggregation rules.

Please reach out with any questions.

Respectfully submitted,

/s/ Mark M. Lee

Mark M. Lee, Esq.

Encs.

cc: Zuzana O. Pacious, CFE (via e-mail)

Gregory S. Bergman, Esquire (via e-mail)