1321) K SI REI 1 N.W,

WA~HINC 1{)N.l>.C. 20463

FEDERAL ELECTION COMMISSION

Overview

REPORT OF THE AUDIT DIVISION

ON THE

GUN OWNERS OF AMERICA CAMPAIGN COMMITTEE '76,

GUN OWNERS OF CALIFORNIA CAMPAIGN COMMITTEE,

GUN OWNERS OF AMERICA LEGISLATIVE ACTION FUND

A.

Background

GOA originally registered with the Federal Election

Commission on September 4, 1975, under the name of "Target

'76", which was changed to Gun Owners of America Campaign

Committee '76 in January, 1976. GOA's major function is to

solicit contributions in the 49 states other than California,

mainly utilizing direct mail techniques, for the purpose of

influencing and encouraging pro-gun legislation through the

election of legislators at the Federal level. GOA was

formed primarily because of the success of its sister committee, Gun Owners of California (GOC); which organized prior

to GOA, and which restricts its operations to soliciting

contributions from within the State of California and

influencing legislation and electi9ns on the state level.

The Gun Owners of America Legislative Action Fund (LAF) was

established in May, 1976, as a Federal lobbying organization

and is primarily funded with corporate or apparent corporate

contributions which, under the Act, GOA could not accept.

Rather than continue returning such contributions, as was

the practice during the first several months of 1976, GOA

established LAF as a pro-gun Federal lobbying organ~zation

in order to utilize these contributions.

I.

This report is based upon audits of the Gun Owners

of America Campaign Committee '76 ("GOA"), Gun Owners of

California Campaign Committee ("GOC"), and the Gun Owners of

America Legislative Action Fund ("LAF") undertaken by the

Audit Division of the Federal Election Commission 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 under the authority of Section

438(a)(8) of Title 2 of the United States Code which directs

the Commission to make from time to time audits and field

investigations with respect to reports and statements filed

under the provisions of the Act.

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The audits covered the period July 2, 1975, the

inception of GOe, through December 31, 1976, the final

coverage date of the latest report filed by GOA at the time

of the first audit, which conunenced April 12, 1977. Because

of i:;:;ues raised during that audit, a follow-up audit was

made, starting on August 1, 1977, at which time a complete

audit of GOC and a partial audit of LAF was conducted.

Durillc.J the audit period, GOA reported beginning cash of $-0-,

total receipts of $2,282,635.10, total expenditures of

$2,lLO,940.04, and ending cash of $161,695.06. ~/

u. Key Personnel

The principal officers of GOA were Mr. John E.

Bianchi, Treasurer, and Mr. Willis E. Laney, Jr., Executive

Director, from September 4, 1975 through January 28, 1976.

Mr. Laney occupied both positions from January 29, 1976

through October 28, 1976, at which time Mr. Thomas E. Hall

was designated as Treasurer. Mr. H. Donald Harper replaced

Mr. Hall effective November 30, 1976, and Mr. Timothy Macy

became Executive Director effective that same date. Effective

February 28, 1977, Mr. John H. Hodgson, II, assumed the

position of Treasurer of GOA. The above individuals performed

parallel functions for GOC and LAF during the audit period.

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.

II. Auditor's Statement and Description of Findings

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

of the reports and statements filed and records presented,

that the above mentioned Committees have not conducted their

activities in compliance with the Federal Election Campaign Act

and that the reports and statements originally filed by

GOA do not fairly present the financial activities of the

Committees for the period covered by the a~dit.

!/ As a result of our audit, Goe subsequently filed reports for

the audit period showing beginning cash of $-0-, total receipts

of $1,447,872.77, total expenditures of $1,391,305.13, and

ending c.:lsh as of December 31, 1976 of $56,567.64.

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Int.roduction

DUl4ing the period covered by the audit, the Committees

shared joint administrative expenses. Committee officials established procedure whereby GOA would make all initial administrative l'xpenditures and be reimbursed, in turn, by the other

COIn.'Ui t tt 't'S according to each comrnittee' s proportionate share of

total contributions received for the period. Initially, administr~tive expenses were to be allocated between GOA and GOC and

reimbur~a:,mcnts made by Goe to GOA based on the following formula:

Committee Receipts for Period

Tot~l Receipts of Both committees X (Total Overhead for Period

for Period

After lAF was organized in May of 1976, administrative expenses

were to be allocated between the three (3) committees based on

each con~ittee's expected share of contributions to be received:

GOA-45%, GOC-40%, LAF-15%.

As of February 1, 1977, this allocation/reimbursement

procedure was discontinued when Computer Caging Corporation was

formed. Computer Caging was designated to undertake the mailing,

sorting, and processing operations for each committee and bill

e.:lch directly for its share of overhead expenses on a per letter

bClsis.

A. Registration and Filing of Reports "

with the Commission

Section 433(a) of Title 2 of the united States Code,

requires each political committee receiving contributions or

milkin~ expenditures exceeding $1,000 in any calendar year for

th(~ vurposc of influencing Federal elections to register with

the corrunission. Section 434(a) and (b) of the Act requires

thc' treasurer of a political committee supporting candidates for

election to Federal office to file reports containing certain

infor~3tion regarding receipts, expenditures, and cash-on-hand

for the reporting period.

As was discussed earlier, GOA and GOC shared administrative expenses. GOA was to allocate expenses to GOC which

~as subsequently to reimburse GOA for its ~hare, based on GOe's

pcrccnt~ge of total contributions received for each period. The

CO~~li~sion approved this procedure (see AO 1976-43) providing:

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1) Such payments from Goe are not in excess of what

they normally would have to pay for such services. (The Commission's concern being that such payments not be a device for

providing additional funds to GOA, circumventing the contribution

limits of 2 U.S.C. 441a); and

2) Paymcnt from GOC to GOA be made from a segregated

aceount that docs not contain corporate or other Federallyprohi.bited contributions. (In accordance with this provision,

a separate bLlnk account termed the Federal Support Fund was

established by GOC which would contain only individual contributions, from \oJhich all transfers to GOA were to be made.)

As a result, GOA established procedures for

paying all expenses directly, then allocating 40% of the total

administrative cx~enses each period to GOC, which was then

sUPPo~ied to reimburse GOA for this amount from its Federal

Support Fund. The 40% figure was based on GOe's anticipated

sh,"lre of total contributions received by the eonunittees in

accordance with the prescribed formula. Based on a review of

a schcllu1e of total contributions received, broken down by

Con~itLee, GOe's actual share of total contributions for the

period 1/1/76-12/31/76 was 39.5% of the total.

Our examination of the allocation/reimbursement

relationship between GOA and Goe revealed the following facts:

1) Net trans[p!"s from Goe to GOA totalling

$272,948.92 \oJcre made with no discernible pattern and exceeded

GOe's actual share of allocated expenses as per the established

procedure by $29,137.20 (ilftcr adjustment for a fourth Committee's

share of shared administrative overhead attributed to GOC) •

2) For the months June through October, 1976,

GOC's balance of excess payments to GOA ranged from $68,186.16

to $119,569.64. During this period GOA made most of its contributions to Federal candidates.

3) A comparison of cnd-of-periqd GOC/GOA overpayment balances with the corresponding GOA cash-an-hand

figures showed a consistent pattern after May 31, 1976, of

net overpayments exceeding GOA's cash-on-hand (except as of

12/31/76) • (See Attachment I)

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Auf] it (.)pinion and Subsequent Developments

H.l:a~d on the facts developed, the Audit staff was of the

opiniull lhat the record of overpayments by GOC to GOA constituted

an c:·:pt·IHliture in excess of $1,000 which influenced the Federal

clccti<ll\ process and, accordingly, requirt'd GOC to register as

a po] it i(:(.ll committee and file reports wit-h the Commission. We

so rl'("()lIlll\(!nded to the Goe Officials at the conclusion of the first

GOA C:Hld i L performed in April, 1977. An interim audit report

L1iscu:;:;inq this and other findings was transmitted to the Office

of GC'neral Counsel on Junc 8, 1977. On August 8, 1977, the

Cor::::li~;sion found reason to believe that GOC had violated 2 U.S.C.

Section 433 and Section 434, and the appropriate letter was

for~ardcd to the Committee (GOC) during the course of the fol1owup audit which commenced on August 1. On August 29, 1977, Gac

filed a statement of or<Fluization and reports of receipts and

expenditures for the periods ending December 31, 1975 and

Dccer.1bcr 31, 1976. On November 29, 1977, the Commission found

rc~sonab1e cause to believe that GOC had violated the prompt

and timely filing rcquirements of 2 U.S.C. Section 433 and

Section 434.

Recommendation

The Commission entC'red into a conciliation process with

ttl" Cor.1mi ttee which culminated in an agreement being signed

~n'l approved by the Commission on May 3, 1978. Therefore,

nu f.urther action is recommended on this matter.

B. Acceptance of Prohibited Contributions

Section 441b(~) of Title 2 of the United States Code

Fro!1ibits any political co~nittec from knowingly accepting

cO~-i.~oratc or union conteibutions made in connection with any

FC\.~0ral election.

In May of 1976, legal counsel for GOA requested an

opi~ion concerning the propriety of requesting contributions for

its connected lobbying committee (LAF) witnin the same solicitation

fer donations to its regular GOA fund. 'rhe Commission responded

th~~ such a practice was not prohibited under the Act, provided:

1) the entire cost of the joint mailing is borne

b~· ~. h,' political fUI1d; and

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2) that the contributor expressly designate his

de:jire, via a reply card, etc., to contribute to either the

political contribution fund (GOA) or the legislative activities

func} (LAF).

Audit Opinion and Subseql~~_~_nt. Developments

Based on these facts, it was the opinion of the Audit staff

that GOA, a committee supporting Federal candidates, accepted funds

comprised of corporate contributions from LAF, as payment for shared

dllministra tive expenses.

We advised the Officials representing both Committees

tiL the conclusion of the April, 1977 audit that this matter

\oJould be referred to the Office of General Counsel for its considpI:ation. This matter wns included in the interim audit report forw~rded to the Office of General Counsel on June 8, 1977. On August

8, 1977, the Commission found reason to believe that both GOA and

LAF had violated 2 u.s.c. Section 44lb. 3/ In addition, the Commission found reason to b(~lievc that LAF had also violated 2 U.S.C.

Section 433 and Section 434 because, as in the case of GOC, the net

ovcriJ~i'ment balance from LAt-' to GOA in excess of $1,000 qualified

LAP as a political committee, subject to the requirements of those

sections of the Act. The appropriate letters were delivered to the

Conun-ittees' represcntativl's during the cour:se of the follow-up

audit in August, 1977.

Despite the apparent prohibition against shared expenses

embodied in the Commission's response, an allocation/reimbursement

proc(~dure, similar to the one established between GOA and GOC, was

set lip between GOA and LAF. The Executive Director of GOA confirmed

Lfd'- funds were 100~ corporate or apparent corporate contributions.

I-d\l'- was to reimburse GOI\ from these funds [or its share of administrative expenses, baspu on LAI-" s expected share of contributions

(lS'~) received by the th14ce (3) committees. However, LAF's actual

share of total contributions received during that portion of the

audit period when LAF \v~l~; in existence (5/14-12/31/76) was 5.2%.

U~)inCJ the latter percenldqc as a basis for computing LAF's share

of joint administrative l'xpcnses, and comparing the resulting total

with actual transfers from 1,1\1;' to GOA ($38,531.53), less GOA

payment of LAP expenses, 14('~;l1l ted in a net overpa~'mL'nt by LAF to

CUA of $17 ,634.38. ~/ (~~(\L~ Attachment II)

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installments: 1) $18,244.00 on June 28, 1977, for the Committees'

calc~lation of net overpayments as of 12/31/76: 2) $13,755.17

on August 15, 1977, representing the net overpayment resulting

from the LAF transfel~ to GOA in January 1977, less that month's

allocation and correction for miscalculation in the 6/28/77

payback.

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According to the lcyal analysis, LAF nlso appeared to have

violated Section 44lb in that it continued to receive corporate

contributions after it had attained status as a political committee (once its overpttymcnts to GOl\ exceedL'd $1,000).
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On November 29, 1977, in accordance with the Office

of General Counsel's recommendations, the Conmlission found reasonable

cause to believe that violations of the above sections had occurred.

Reconunend~ltion

'fhe Commission entered into a conciliation process with the

Corrunittee wh.ich culminated in an agreement being si~Jneq and approved

by the Commis~;ion on May 3,1978. Therefore, no further action is

recon@cndcd on this matter.

c. Rcp_ortinq of Receipts and Expenditure~.

Section 434(b) of Title 2 of the United States Code

requires the treasurer of a political committee supporting candidates

for election La Federal office to include in reports filed with the

Con~ission sp0cific information regarding receipts, expenditures,

and cash-on-hllnd for the reporting period.

During the course of the first GOA audit (4/12-4/24/77),

tlH~ (allowing errors were discovered in GOA's reports filed with

thl~ Commission from the Committees' inception to December 31, 1976:

1) Expenditures, occurring a total of 244 times, were

either over-reported or under-reported in each of the Committees'

reports filed up to 12/31/76.

2) Nine (9) instances of failure to itemize expenditures to seven payees aggregating in excess of $100 during the

calendar ~lear.

3) An overstatement of total receipts by $101,101.75

for the year ending December 31, 1976, due to the reporting of an

inter-account transfer as a receipt and the inclusion in receipt

totals of apparent corporate contributions deposited in the segregated LAF "Holding Account."

4) An overstatement of total expenditures by $627.16

for the year enuing December 31, 1976.

5) A resulting overstatement of cash-on-hand as of

December 31, 1976 of $100,474.59.

At the conclusion of the first audit in April, the

Audit staff recommended to GOA that they amend their reports

for all perious covered by the audit, to include the necessary

Schedules A ':lnd B and adjusted periodic and year-end sununary

schedules. On June 16, 1977, the Committee filed comprehensive

amenumcnts [or the years ending 12/31/75 and 12/31/76 which.

matcri~llly complied with our reconunendations •

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In the course of the follow-up audit (8/1-8/12/77),

during which the audit for GOA was completed, and Goe and LAP

received full and partial audits respectively, no additional

Inatprial findings regarding the Cormnittees' reports and records

wert' discovered.

Hccommendation

:;ince satisfactory amendments were received from GOA on

Junc' 1.6, 1977, no further action is recommended regarding this

malt f't-.

D. Other Mc:ltters

The following matter for which the Audit staff feels

no further action is warranted, was discussed with GOA representatives at the conclusion of our April audit.

Our judgmental review of the timeliness of GOA's

depositing of receipts disclosed that for 31 receipt days

examined, in 22 instances the receipts were deposited from

11 to 19 days later. The Comn\ittee was advised of the

requirements of Section l03.3(a) of Title 11, Code of Federal

Regulations, which states receipts shall be deposited within

10 days of the Committee's acceptance of them. Since that

aUllit, GOA has streamlined the receipts handling system undL~r the Computer Caging Corporation which, in our opinion,

\oJill reduce the deposit lag-time for all the Committees involved.

Attachments as stated

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.. Attachrrent II

GUN <l-JNERS OF AMERICA CAMPAIGN ~1I'rI'EE '76 :.;

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SUIlll'.ary of Receipts fran IAF, GOA Payments on Behalf of IAF, and Allocation of D:penses to IN

Based an 5.2% Actual Share of Contributions Received *

Period

June

July

August

September

Ck:tober 1-18

oct. 19 - Dec. 31

Totals

Al1ocaab1e

Admin. EXp.

Based on 5.2%***

$ 2,872.08

2,053.77

3,052.48

2,158.04

1,430.48

5,153.28

$16,720.13

GOA Payment

of 1M"

Payroll Taxes

$4,177.02

$4,177.02

IAF

Transfers

'1b GOA

$20,133.50

9,105.99

9,292.04

$38,531.53

Balance

OVerpayment

(Underpayment)

$ (2,872.08)

'(4,925.85)

12,155.17

9,997.13

17,672.64

17,634.38

$17,634.38

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Net Overpayment as of 12/31/76 According to

Conmittee's Amended Schedule of 8/77

Difference

* Revised as a result of additional fieldwork conducted 8/1-8/12/77

15,721.40

$ 1,912.98**

** Difference represents amolIDt of allocated expenditures due OOA which Conmittee listed for December 1976

per their schedule. This amount is not supported by accounting records or our examination.

*** Actual percentage to 2 decimal places is 5.16 which the Audit staff originally used. Ccmnittee rounded-up

to the nearest lOth decimal place. As difference anounts to $128.62, Audit staff feels this is not

significunt.
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Attachment I

Gtm O\"NERS OF AMERICA CA;·1PAIG1 CCMMITrEE '76

S~j of Receipts fram GOC and Allocation 0= =Q~~ ;':~~~s~a~~~~ ~~~.ses to GOC Based on

l\ctual Varying Share of Contributions Received.*

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Allocable l\clmin. l~.

fused on Gee's i\ctual Share

of 'Ibta1 Contributions by Period . Transfers In

to OOA fran GOC

Net Balance

Overpayrrent

(Underpaynent)

GOA Cash-Qn-Hand

at end of

Pericx:1 per Records

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1975

CCtobcr

Novcrn1Jcr

Dcccml..lcr

1976

J.:ultl.uy-~1arch 31 ..·..rri1

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JtU1C

July

August

September

C£t. 1-18

Q:t. 19-~c. 31

(35.9%)

(35. 9~)

(35. 9~)

(4l.3·~)

(41.3%)

(41.3%)

(4l.3~)

(41.3%)

(41. 3~)

$ - 0 -

6,900.00

3,439.73

35,193.95

18,437.71

22,285.30

22,810.93

16,311.66

24,243.70

17,139.78

11,361.33

40,928.98

$ 5,000.00 $ 5,000.00

7,000.00 5,100.00

10,339.73 12,qOO.OO $19,682.27

38,315.19 15,121.24 32,843.76

28,800.00** 25,483.53 22,049.66

23,000.00** 26,198.23 33,150.72

83,864.00** 87,251.30 76,887.39

48,630.00** 119,569.64 36,318.31 -°- 95,325.94 57.431.80

(10,000.00)** 68,186.16 57,839.64

38,000.00 94,824.83 66,808.67 -°- 53,895.85 61,220.47

Totals $219,053.07 $272,948.92 $53,895.85

less: Net Overpayment According

to GOA per Their Amended Schedule of 8/77

Difference

29,137.20

$24,758.65 *** ,..

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Revised as a result of additional fieldwork conducted 8/1-8/12/77.

Net of Payments of GOC Postage by GOA

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*** Represents share of administrative overhead attributable to the Law and Order Car:1paign C~ittee (I.DCC)

fOt- tilC period Junc-lJcc., 1976 \oJhich \\05 payable to rnA and advanced by GOC 0:1 1:c;-::il: c: :.occ. OX

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rescntlY 5110\\'5 the advance on behalf of LCCC a.-....eceivable from LOCC on its scr-.c.~:·Jlc 0: debts an.d

ligations. GOC fcels ti1is can be legittmatel ected in their share of a~~istrative overhea

ce, reduccs the overpa:zment balance according ·

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