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fll)lRAl. ELECTION COMMISSION

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May 7, 1979

ME~10Rl\NDU~1

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THROUGH:

FROrwl:

SUBJECT:

FRED EILAND

PRESS OFFICE~

BOB COS'l'A ~'1_

JUDY HAWKINS

PUBLIC ISSUANCE OF AUDIT REPORT -

onIO REPUBLICAN FIN1\NCE COr-U~ITTEE

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Attached please find a copy of the final audit report

of the Ohio Hepublican Finance Comnlittee which was approved

by the Commission on April 20, 1979.

As of this date, May 7, 1979, all informational copies

of the report have been received by all parties involved, and

this report may be released to the public.

cc: FEC Library

RAD

~ic Record

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FEDfRAI. ELECTION COMMISSION

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RRPORT OF TilE AUDIT DIVISION

ON THE

01110 REPUBLICAN FINANCE COr-1r1ITTEE

I. Background

This report is based on an audit of the Ohio Republican

Fillc'll1ce Committee ("the Committee"), undertaken by the Audit

Div i :~ion of the Federal Election Conunission in accordance wi th the Comll\ission~s-audit pol icy _t_Q J:1~t:crmine whether there has been

compliance with the provisions of the -Pcde-rc:fl El~cti-on Campaign

l\ct of 1971, as anlcndec1 ("the Act"). The audit was conducted

pursuant to Section 438(a) (8) of Title 2 of the United States

Code which directs the Commission to make from time to time audits

,lnd field investigations with respect to reports and statements

filed under the provisions of the Act.

A. Ovcrvic\'/

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The Conmlittcc registered with the United States House

of Representutivcs on January 10, 1974 as an affiliate of the

Ohio Republican St3te Central and Executive Committee. The

Cooonitteo maintains its headquarters in Columbus, Ohio.

The audit covered the period January 1, 1976 throuqh

October 23, 1978, the final covera~e date of the most recent

report filed by the Committee nt the time of the audit. The

Committee reported an opcninq CLlsh balance on January 1, 1976

of $122,761.72, total receipts for the period of $4,674,949.11,

total expenditures for the period of $4,631,449.65, and n closina

cash balance on October 23, 1978 of ~166, 273.68 • .!./

The closing cash balance was overstated $12.50 because of

minor discrepancies in reported balances•

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'rhis audit report is based on documents and working

papers which support each of the factual statements. They form

part of the record upon which the commission based its d(~cisions

on the matters in the report and were available to Cornminsioners

and appropriate staff for review.

B. Key Personnel

II. ~urlitor's Statement and Description of Findings

'Phe principal officers of the Committee durinq t hp

period Clu(Li ted were Mr. David S. Ingalls, Jr., Chairman, lllHl

Mr. CharleB E. Shanklin, Treasurer.

The audit included such tests as verification of total

reported receipts, expenditures and individual transactions;

re-vicw of rc-qu-irca supporting documentation-;analysis- of Committ~)(·

debts and ol>liqntions; and such other audit procedures ns deemed

necessary under the circumstances.

C. Scope

It is the opinion of the Audit staff, based upon examination

of the reports and statements filed and the records presented,

that, except for the deficiencies noted below, the reports and

statements of the Ohio Republic~n Finance Committee fairly present

the financial activities of the Committee for the period covprcd

by the audit. Further, except as noted below, no material problems in complyinq with the Federal Rlcction Campaign Act wert'

discovered during the course of the audit.

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A. Receipt of Rxcessive contribution

Section 44Ia(a) (1) of Title 2 of the United States

Code stutes, in part, that no person shnll make contributions

to llny political committee in any calendar year which, in the

aqqrcq.:1te, exceed $5,000, except that:

(il) contributions to ~ny candidate and his authorized

pol i tical conlmi ttces with respect to any election for Federal

office shall, in the aggregate, not exceed ~l,OOO: or

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(b) contribution~ to political committees established

and Ill.1.int,·,incd by it national political party, which are not

the iluthorizcd political committecs of any candidate, in any

calendar ycar shall, i.n thC' tl.qqrQqatc, not cxcced $20,000.

Scction 441" (f) of 'l'itle 2 of thf' lTnitecl States Cod(~

statcs, in part, thi\t no officer or employ('e of a political

committee shull kno\-Jinqly ,1.ccept n contribut.ion in violation of

any limitation impo~ll\d on contributions unc1c'r this section.

It \vas dctcQ-mincc1 th.,t the Carom; tt.cc accepted and

retai ned contributions from onl"' (1) individual during a calendar ycnr

which, in the aqqrcqate, totc:llel1 $6, 000. rrhe contributions were

m~c1e :iubsequcnt to the r-lay 11, ] 976 effective datc of the statutory

limi t .., I ions wi th re!:;pcct to such contributions.

rrhc· Committee offici,·l-ls were unaware ofthc. c.:<coss:j.v~

contrihution.

Hccommenc1c:l L i (>11

Bl1scd upon the l\udit st..,ff's rccommend.:1tio~1, the Committee

refundec1 to the contributor th(~ excessive portion ($1, 000) of the

contribution on tlarch 30, 197() ~n<.l presented t.he l\udit staff a

copy of the certified chccl: a:-; evidence of t.he refund. Therefore,

no further Llction is recomr.1cndC'd on the m~t tC'r.

Section 433 (b) (9) of 'l'itle 2 of the United States Code

rc'cyuires political cornrai t tee to includc \vi thin its statement

of orqaniz~tion a listinq of '.111 bnnks or other repositories uscd.

Section 433(c) of Title 2 of the united States Code stntcs

t h~l t ilny ch~nge in in forr.1~i t· i.on plAcviously submi t- ted in a statement

() r orq~niz(l tion 5h"11 be rv!)()rtl'd to the Commi;,!~ i.on \~i thin a

10-{l.lY period follo\vino lh,' cl1.lnqe.

1\ rcvic\v of the C()j:::~1 i t t·~'.·' s records revealed thnt a C~1l\1p •.,i<1n depository opened Ly thl' Committee on i\uqllst 31, 1978

h,"'1. I not been llisclosed to the Cnmmission. Ho\\·C'\Pcr, all receipts

and c':·~penc1itures attribllt.lbl\." to thc depasi tory \-ICre properly

di ~;(" lased by the Conu:li tt(~(".

'rhe Cnmmit:t:ec 0~:-ici;11~; \\'cre un.:\\,1.:lrc thc:lt the depository

had not b(,l~n di:;closl~d•
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HC'commcndation

Based upon the 1\udit staff's recommendation, the Committee

filed a statement of organization amendment on April 4, 1979

disclosing the caml'aiqn depository. Therefore, no further action

is recommended on the matter.

c. Other Matlers

Presented helow are other mutters noted durinq the

audit for which the ~udit staff feels no action is warranted.

'rhe committee officials have been advised of the matters and

informed of the respective requirements of the Act.

(1) A system for recording pledges and disclosing

them as debts owed to the Committee was not adequately maintained.

The pl~qg~~~C_9J'Q~ W~l:'~ I1ot updated on a regular basis, and the

pledqes were automatically deleted from the dent scheaules at the

end of each year.

(2) A Schedule D disclosing $12,720.00 proceeds from

a func1raisinq event was not filed. However, the event and

proceeds were reported on the summary page of the disclosure

report covering the quarter durinq which the event was held.

Further, the r~ccipts were adequately disclosed as contributions.

(3) Contributions not requiring itemization, received

after M3rch 31, 1978 were included on the same schedule as those

requirinq itemization, rather than on a separate schedule as

required by Section 104.2(b) (3) (ii) of Title 11 of the Code of

Federal Regulations•

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