Federal Election Commission 

Office of Inspector General 

Semiannual Report to Congress 

April 1, 2006 – September 30, 2006 

Federal Election Commission 

999 E Street, N.W., Suite 940 

Washington, D.C. 20463 

November 2006 
FEDERAL ELECTION COMMISSION 

WASHINGTON, D.C. 20463 

December 1,2006 

OFFICE OF THE CHAIRMAN 

The Honorable J. Dennis Hastert 

Speaker of the House of Representatives 

Washington, D.C. 205 15-6501 

Dear Mr. Speaker: 

Pursuant to the Inspector General Act of 1978, as amended, the Federal Election 

Commission submits the Inspector General's Semiannual Report to Congress, which 

summarizes the activity of that office over the six-month period April 1,2006 through 

September 30,2006. 

During thls reporting period the FEC's Inspector General commenced an audit of 

the FEC's Employee Transit Benefit Program. The FEC expects to receive a favorable 

audit when the final report is released. Also in progress is an audit of the FEC Fiscal 

Year 2006 Financial Statements, which FEC will respond to once the final audit is 

released. 

The report additionally discusses the completion of an investigation of several 

agency staff. As noted previously, Management is aware of the investigation referenced 

in the report. Management cooperated with the Inspector General and took prompt action 

with respect to the issues raised by the Inspector General. Management has already 

implemented many of the recommendations as suggested by the IG. For example, FEC 

has held mandatory EEO training and is currently updating a number of its internal 

personnel policies. Management will continue to ensure that FEC improves 

communications to all employees on the FEC's Rules of Behavior. 

The Commission appreciates and shares the Inspector General's commitment to 

sound financial and management practices, and we anticipate a continued cooperative 

working relationship as management takes appropriate measures to improve operations of 

the Commission. Copies of this semiannual report are being provided to the Chairman 

and Ranking Members of FEC's oversight committees. 

Sincerely, flqT% ichael E. Toner 

Chairman 

Enclosure 
MANAGEMENT REPORT ON FINAL ACTION 

ON AUDITS WITH QUESTIONED COSTS 

FOR THE SIX-MONTH PERIOD ENDING SEPTEMBER 30,2006 

Number of Questioned 

Audit Reports 

A. Audit reports for which no management 

decision has been made by commencement 

of the reporting period 0 0 

B. Audit reports issued during the reporting period 0 0 

Subtotals (A + B) 0 0 

C. Audit Reports for which a management decision 

was made during the reporting period 0 

(i) dollar value of disallowed costs 0 

(ii) dollar value of costs not disallowed 0 

D. Audit Reports for which no management decision 

has been made by the end of the reporting period 0 

E. Audit Reports for which no management decision 

was made within six months of issuance 0 

Unsupported 

Costs 
MANAGEMENT REPORT ON FINAL ACTION 

ON AUDITS WITH RECOMMENDATION TO PUT FUNDS TO BETTER USE 

FOR THE SIX-MONTH PERIOD ENDING SEPTEMBER 30,2006 

Number of Funds to be Put 

Audit Reports to Better Use 

A. Audit reports for which no management 

decision has been made by the commencement 

of the reporting period 

B. Audit reports issued during the reporting period 

C. Audit Reports for which a management decision 

was made during the reporting period 

(i) dollar value of recommendations that were 

agreed to by management 

- based on proposed management action 

- based on proposed legislative action 

(ii) dollar value of recommendations that were 

not agreed to by management 

D. Audit Reports for which no management decision 

has been made by the end of the reporting period 

E. Audit Reports for which no management decision 

was made within six months of issuance 
FEDERAL ELECTION COMMISSION 

WASHINGTON, D C 20463 

A Message from the Inspector General 

This report summarizes the work completed by the Office of Inspector General (OIG) for the 

semiannual reporting period April 1, 2006 - September 30, 2006. The activities highlighted 

in this report demonstrate our continuing commitment to the promotion of integrity, 

accountability, efficiency and effectiveness in the programs and operations of the Federal 

Election Commission (FEC). 

This past year has seen a great change in the FEC. Three new Commiesioners joined the 

Commission, two of whom replaced Commissioners with over twenty years tenure at the 

agency. The FEC also saw the retirement of the Staff Director and Budget Officer, both with 

over thirty years service to the FEC. This summer a new Staff Director was hired and plans 

are in place to fill other senior staff positions. This is a new and exciting time for the FEC as 

fresh ideas and methods are being put into practice. The OIG looks forward to working with 

the new management team at the FEC. 

The OIG has also seen a significant increase in the volume and complexity of our work. As 

are other OIGs, we are now required to conduct an annual financial statement audit as 

required under the Chief Financial Officers Act of 1990, as amended. This reporting period 

also reflects the completion of phase one of an inspection the OIG is conducting in response 

to OMB Memorandum M-06-16, Protection of Sensitive Agency Information. Phase two will 

be completed early in the next reporting period. 

We have also seen a noteworthy increase in the number of hotline complaints received in the 

office. Concurrently, an increase in the number of investigations has also followed. During 

this reporting period, an investigation we had been working jointly with the Federal Bureau 

of Investigation and the United States Attorney's Office was closed. 

The OIG has risen to these additional challenges, but it is becoming increasingly difIicult to 

continue without further resources. I have discussed my concerns with the Chairman and 

Vice Chairman and am hopeful that an increase in staffing will be possible. 

During the next reporting period, the OIG will continue our commitment to work with the 

Federal Election Commission to ensure the efficiency, effectiveness and integrity of agency 

operations. 

inspector General 

Federal Election Commission 

October 31,2006 

Semiannual Report to Congress April 1.2006 -September 30,2006 
________________________________________________________________________________________________ 

TABLE OF CONTENTS

EXECUTIVE SUMMARY-------------------------------------------------------- 1 

THE FEDERAL ELECTION COMMISSION------------------------------ 6 

AUDITS-------------------------------------------------------------------------------- 9 

INSPECTION------------------------------------------------------------------------ 15 

HOTLINE COMPLAINTS------------------------------------------------------- 17 

INVESTIGATION------------------------------------------------------------------ 18 

ADDITIONAL OFFICE OF INSPECTOR GENERAL 

ACTIVITY----------------------------------------------------------------------------- 28 

ECIE AND PCIE ACTIVITY---------------------------------------------------- 31 

REPORTING REQUIREMENTS---------------------------------------------- 34 

TABLE I - QUESTIONED COSTS-------------------------------------------- 35 

TABLE II - FUNDS PUT TO BETTER USE------------------------------- 36 

TABLE III - SUMMARY OF AUDIT REPORTS WITH

 CORRECTIVE ACTIONS OUTSTANDING 

FOR MORE THAN SIX MONTHS-------------------------- 37 

FEC/OIG STRATEGIC PLAN – FY 2005-2010---------------------------- 38 

CONTACTING THE OFFICE OF INSPECTOR 

GENERAL----------------------------------------------------------------------------- 39 

Semiannual Report to Congress April 1, 2006 – September 30, 2006 
________________________________________________________________________________________________ 

EXECUTIVE SUMMARY

This Semiannual Report to Congress summarizes the work of the 

Federal Election Commission (FEC), Office of Inspector General (OIG) for the 

period covering April 1, 2006 through September 30, 2006. 

The Office of Inspector General is responsible for directing and 

carrying out audits, inspections, and investigations related to the Federal 

Election Commission’s programs and operations. The OIG recommends 

policies that promote economic, efficient, and effective use of agency resources 

and programs that prevent fraud, waste, abuse, and mismanagement. The 

OIG is also responsible for keeping Congress and the Commission fully 

informed regarding problems and deficiencies detected in FEC programs and 

operations, and the necessity for corrective action. 

The audits performed by the OIG are conducted in accordance with the 

Government Auditing Standards issued by the Government Accountability 

Office (GAO). The investigations carried out by the OIG comply with the 

Quality Standards for Investigations developed by the President’s Council on 

Integrity and Efficiency (PCIE) and the Executive Council on Integrity and 

Efficiency (ECIE). 

Semiannual Report to Congress Page 1 April 1, 2006 – September 30, 2006 
________________________________________________________________________________________________ 

The audits, inspections, investigations, and other activities highlighted 

in the Executive Summary demonstrate our continuing commitment to the 

promotion of integrity, accountability, efficiency, and effectiveness in the 

programs and operations of the Federal Election Commission. 

The Audit of the FEC’s Employee Transit Benefit Program - OIG06-01 was initiated during the previous reporting period and continued into 

this reporting period. The Employee Transit Benefit Program is a federally 

mandated program that provides a monthly transit subsidy to eligible 

employees who commute by means other than single-occupancy motor 

vehicles. The primary objectives of the audit are to 1) assess program policies 

and operating procedures for compliance with applicable regulations, 2) 

verify employee compliance with program participation requirements, and 3) 

ensure the appropriate internal controls are in place. 

To identify possible internal control weaknesses in the current transit 

benefit program, the OIG reviewed and analyzed documentation discussing 

past employee violations of the transit benefit program. Prior to the end of 

this reporting period, various meetings, reviews, and evaluations have been 

conducted, and the fieldwork was completed. To obtain additional 

information pertaining to the audit of the transit benefit program, refer to 

page 9. 

Semiannual Report to Congress Page 2 April 1, 2006 – September 30, 2006 
________________________________________________________________________________________________ 

The OIG is also currently working on the Audit of the FEC’s Fiscal 

Year 2006 Financial Statements – OIG–06-02. To perform the audit of 

the FEC’s FY 2006 financial statements, the OIG utilizes the services of 

independent public accounting firm Clifton Gunderson, LLP (CG-LLP). This 

audit is required by The Chief Financial Officers Act of 1990 (Public Law 101-

576), as amended. The entrance conference has been conducted, at which 

time the audit work plan was discussed along with other pertinent 

information as it relates to the FEC’s financial statement audit. To ensure 

that the audit is carried out in accordance with auditing standards generally 

accepted in the United States of America, the OIG will continue to monitor 

the performance of Clifton Gunderson, LLP. See page 13 for additional 

information pertaining to the FEC’s FY 2006 Financial Statements Audit. 

As a result of numerous federal government incidents involving the 

compromise or loss of sensitive personal information, the Office of 

Management and Budget (OMB) issued Memorandum M-06-16, Protection of 

Sensitive Agency Information. The memorandum recommends that federal 

agencies take all necessary and reasonable measures to swiftly eliminate 

significant vulnerabilities to the sensitive information entrusted to them. 

The OIG, in conjunction with Clifton Gunderson LLP, performed phase one of 

a two part inspection of Personally Identifiable Information (PII) maintained 

Semiannual Report to Congress Page 3 April 1, 2006 – September 30, 2006 
________________________________________________________________________________________________ 

by the Commission. Phase one of the inspection was conducted to assess the 

FEC’s progress to protect PII. To obtain information regarding phase one of 

the PII inspection, see the section entitled Inspection located on page 15. 

The OIG opened four hotline complaints during this reporting period, 

bringing the total number of complaints to ten. Six complaints are pending; 

four hotline complaints are in progress; and one complaint was closed. 

Additional information associated with the hotline complaints can be found 

on page 17, the section entitled Hotline Complaints. 

Additionally, the OIG opened one investigation, and closed one 

investigation during this time frame. The closed investigation involved 

allegations of misconduct by several senior management officials. The 

alleged misconduct also included a violation of a criminal conflict of interest 

law. 

The OIG initiated a joint criminal investigation with the Federal 

Bureau of Investigation and the United States Attorney’s Office. Over the 

course of several months, the investigative team interviewed over twenty-six 

witnesses, reviewed thousands of electronic and paper records, executed a 

search warrant and performed other investigative work in order to obtain the 

facts surrounding the allegations concerning senior management. 

Semiannual Report to Congress Page 4 April 1, 2006 – September 30, 2006 
________________________________________________________________________________________________ 

A key event in the investigation involved a $10,000 obligation of funds 

payable to a law firm representing one of the witnesses and ultimate subjects 

in the investigation. In addition to the involvement in creating a false 

statement of work (description of services ordered), a manager took the 

unusual step of signing a procurement request in multiple places to enable 

the funds to be processed. This action removed one of the routine checks and 

balances in the procurement process to ensure that Commission funds are 

properly spent. 

In September 2006, the U.S. Attorney’s Office for the District of 

Columbia ultimately declined to prosecute the primary subject of the 

investigation. Except for one employee, all of the subjects of the investigation 

retired, separated, or were terminated from the agency. At the conclusion of 

the investigation, the OIG recommended FEC management review the facts 

of the investigation and consider disciplinary action against one of the 

subjects who is still employed by the agency. For further details on the 

investigations, see the Investigation section which can be found on page 18. 

Semiannual Report to Congress Page 5 April 1, 2006 – September 30, 2006 
________________________________________________________________________________________________ 

THE FEDERAL ELECTION COMMISSION 

In 1975, Congress created the Federal Election Commission (FEC) to 

administer and enforce the Federal Election Campaign Act (FECA). The 

duties of the FEC, an independent regulatory agency, are to disclose 

campaign finance information; enforce the provisions of the law; and oversee 

the public funding of Presidential elections. 

The Commission is made up of six members, who are appointed by the 

President and confirmed by the Senate. The current Chairman and Vice 

Chairman of the Federal Election Commission are Michael E. Toner and 

Robert D. Lenhard respectively. The other Commissioners are David M. 

Mason, Steven T. Walther, Hans A. von Spakovsky, and Ellen L. Weintraub. 

Each member serves a six-year term, and two seats are subject to 

appointment every two years. By law, no more than three Commissioners 

can be members of the same political party, and at least four votes are 

required for any official Commission action. The Chairmanship of the 

Commission rotates among the members each year, with no member serving 

as Chairman more than once during his or her term. 

There have been several personnel changes in top management 

positions within the FEC. With such changes, there are opportunities to 

Semiannual Report to Congress Page 6 April 1, 2006 – September 30, 2006 
________________________________________________________________________________________________ 

implement new ideas that can result in additional improvements throughout 

the Commission. 

OFFICE OF INSPECTOR GENERAL

The Inspector General Act of 1978 (P.L. 100-504), as amended in 1988, 

states that the Inspector General is responsible for: 1) conducting and 

supervising audits and investigations relating to the Federal Election 

Commission’s programs and operations; 2) detecting and preventing fraud, 

waste, and abuse of agency programs and operations while providing 

leadership and coordination; 3) recommending policies designed to promote 

economy, efficiency, and effectiveness of the establishment; and 4) keeping 

the Commissioners and Congress fully and currently informed about 

problems and deficiencies in FEC agency programs and operations, and the 

need for corrective action. 

The mission of the OIG is to be an independent, objective voice that 

aids the Commission by promoting positive change, accountability and 

integrity. An inventory of suggested audits, investigations, and inspections 

received from a variety of sources is maintained. The most important 

challenges are identified and the final step is to plan and conduct audits, 

investigations, and inspections that address those challenges. 

Semiannual Report to Congress Page 7 April 1, 2006 – September 30, 2006 
________________________________________________________________________________________________ 

The OIG will continue its commitment to work with the Commission to 

ensure the efficiency, effectiveness, and integrity of agency programs. We 

take pride in our past accomplishments and anticipate future ones of even 

greater significance. 

Semiannual Report to Congress Page 8 April 1, 2006 – September 30, 2006 
________________________________________________________________________________________________ 

AUDITS

TITLE: Audit of the FEC’s Employee Transit Benefit 

Program 

ASSIGNMENT #: OIG – 06-01 

RELEASE DATE: In Progress 

PURPOSE: The primary objectives of the audit are to 1) assess 

program policies and operating procedures for compliance with applicable 

regulations, 2) verify employee compliance with program participation 

requirements, and 3) ensure the appropriate internal controls are in place. 

The OIG examined and compared the Commission’s current directive, 

as it pertains to the transit benefit program, to the Commission directive that 

was in effect during the previous employee transit benefit audit conducted by 

the OIG in 1994. Based on the comparison, it was found that the employee 

transit benefit program has experienced only a few minor changes. 

The OIG evaluated the transit subsidy application approval process, 

and reviewed the applicable SmarTrip monthly benefits/claims activity 

reports, as well as the monthly fare media distribution listing to determine 

whether the participants received the transit benefits in the first full 

calendar month after the application had been approved. This step was 

conducted to ensure that participants received benefits in a timely manner. 

Semiannual Report to Congress Page 9 April 1, 2006 – September 30, 2006 
________________________________________________________________________________________________ 

The OIG researched various websites and other program material to 

determine the current transit carriers who accept SmarTrip as a form of 

payment for commuting services. The OIG obtained and reviewed the FEC 

transit subsidy program participant applications to determine if the 

participants were Metrochek recipients utilizing carriers who accept 

SmarTrip Cards as a form of payment. 

The OIG identified the number of sampled program participants 

currently receiving Metrocheks who qualify to receive the monthly transit 

benefit on SmarTrip cards. This audit step was completed to determine 

whether program participants could switch from paper Metrocheks (which 

requires manual distribution monthly) to the paperless distribution method 

(electronic transfer of transit benefits on a SmarTrip card). 

To further assist with the audit, the OIG contacted all employees who 

participated in the Commission’s subsidized parking program from January 

2003 through December 2005. The OIG completed this audit step to identify 

permit holders who had FEC employees carpool with them on a regular basis. 

In addition, the OIG reviewed the transit subsidy eligibility and the transit 

subsidy claiming/distribution lists to determine whether or not passengers of 

permit holders received transit subsidy benefits. 

Semiannual Report to Congress Page 10 April 1, 2006 – September 30, 2006 
________________________________________________________________________________________________ 

The OIG also contacted the agency’s SmartBenefits program 

administrator to obtain copies of the agency’s SmarTrip claiming reports for 

various calendar years. The claiming reports, produced by METRO’s online 

database system, capture employee transit benefits usage data and will be 

used to observe the amount of transit subsidy actually claimed by program 

participants during the audit review period. 

Travel orders maintained by the Finance office were reviewed to 

document program participants on extended official travel for ten or more 

business days during a one month period. The OIG also reviewed travel 

expense reports generated by the Commission’s electronic travel service and 

the transit subsidy claiming reports to ascertain the number of transit 

benefit program participants who were on work related travel for two or more 

weeks during a month time frame, but claimed their full monthly transit 

benefit. Under FEC policy, commuters who alter their commute two weeks or 

more during a month are to adjust their transit benefit. 

Meetings were held with management to discuss various issues 

regarding the review of the employee transit benefit program and to discuss 

the responsibilities of the overall management of the employee transit benefit 

program. During one of the meetings, the OIG discussed the SmarTrip 

account, and the separation process for removing former employees. The OIG 

Semiannual Report to Congress Page 11 April 1, 2006 – September 30, 2006 
________________________________________________________________________________________________ 

requested more information regarding separated employees that appear to be 

listed as eligible recipients of transit benefits. 

Additional meetings were held to discuss the Commission’s subsidized 

parking program. The OIG summarized and provided management with 

comments and suggestions for improvement to the proposed commission 

bulletin on subsidized parking policies & procedures. 

The FEC’s fare media eligibility list was reviewed to determine 

whether employees had been assigned a SmarTrip card number; and the 

transit subsidy distribution list was also reviewed to determine whether or 

not the employees claimed the paper Metrocheks. Furthermore, the OIG 

compared sampled participants’ transit subsidy benefits claimed to 

reasonable costs associated with the commuting options available for those 

participants who utilize the Metro’s subway trains or bus to ensure that 

participants did not claim excessive or unreasonable commuting costs. 

The fieldwork for this audit was completed during this reporting period 

and we anticipate releasing the final report shortly. 

Semiannual Report to Congress Page 12 April 1, 2006 – September 30, 2006 
________________________________________________________________________________________________ 

AUDITS

TITLE: Audit of the FEC’s Fiscal Year 2006 Financial 

Statements 

ASSIGNMENT #: OIG – 06-02 

RELEASE DATE: In Progress 

PURPOSE: The Chief Financial Officers Act of 1990 (Public 

Law 101-576, commonly referred to as the “CFO Act”), as amended, requires 

the FEC Office of Inspector General (OIG), or an independent external 

auditor as determined by the Inspector General, to audit the agency financial 

statements. Under a contract monitored by the OIG, Clifton Gunderson LLP 

(CG-LLP), an independent certified public accounting firm, is performing the 

audit of the FEC’s FY 2006 financial statements. 

The OIG is responsible for oversight of the financial statement audit. 

This includes: 1) reviewing the auditors approach and planning of the audit; 

2) evaluating the qualifications and independence of the auditors; 3) 

monitoring the work of the auditors; 4) examining audit documents and 

reports to ensure compliance with Government Auditing Standards, and 

OMB Bulletin No. 01-02 Audit Requirements for Federal Financial 

Statements; and 5) other procedures the OIG deems necessary to oversee the 

contract and audit. 

Semiannual Report to Congress Page 13 April 1, 2006 – September 30, 2006 
________________________________________________________________________________________________ 

The entrance conference was conducted, at which time management, 

the OIG staff, and Clifton Gunderson, LLP, discussed the audit scope and 

ways to ensure an efficient and effective audit process for fiscal year 2006. 

This included a discussion on the issuance of an audit opinion; review of the 

internal control structure, including the material weaknesses and reportable 

conditions from the prior years’ audits; review of compliance with laws and 

regulations; and information technology related compliance. 

The OIG coordinated and participated in bi-weekly audit status 

meetings and attended a fraud awareness brainstorming meeting with the 

auditors. The OIG also reviewed the auditor’s notice of findings and 

recommendations (NFR) recently submitted to management. The NFRs 

inform management of potential audit findings and allows management the 

opportunity to respond to the issues before the final audit report is issued. 

Semiannual Report to Congress Page 14 April 1, 2006 – September 30, 2006 
________________________________________________________________________________________________ 

INSPECTION

As a result of numerous federal government incidents involving the 

compromise or loss of sensitive personal information, the Office of 

Management and Budget (OMB) issued Memorandum M-06-16, Protection of 

Sensitive Agency Information. The memorandum recommends that Federal 

agencies take all necessary and reasonable measures to swiftly eliminate 

significant vulnerabilities to the sensitive information entrusted to them. 

Sensitive PII is defined by OMB as “any information about an 

individual maintained by an agency, including, but not limited to, education, 

financial transactions, medical history, and criminal or employment history 

and information which can be used to distinguish or trace an individual's 

identity, such as their name, social security number, date and place of birth, 

mother’s maiden name, biometric records, etc., including any other personal 

information which is linked or linkable to an individual.” Information 

systems can be either electronic or manual. 

The OIG’s inspection of PII internal controls includes two phases. 

Phase one, involved an assessment of the FEC’s progress to protect PII. 

Based on the results of phase one, the OIG concluded that the FEC has taken 

steps to protect sensitive personal information. Specifically, the FEC has 

categorized all portable devices as containing or processing PII and is 

Semiannual Report to Congress Page 15 April 1, 2006 – September 30, 2006 
________________________________________________________________________________________________ 

designing security controls (hard drive encryption and password protection) 

to protect these devices. 

The results of phase one were documented in a computer spreadsheet 

and sent to another federal OIG. The results from each federal OIG will be 

consolidated into a single report detailing the federal government’s progress 

to protect PII. Phase two of the OIG’s inspection will include additional 

review work, and a written inspection report detailing the inspection results 

and conclusions. 

Semiannual Report to Congress Page 16 April 1, 2006 – September 30, 2006 
________________________________________________________________________________________________ 

HOTLINE COMPLAINTS

The Office of Inspector General established a hotline to enable 

employees and others to have direct and confidential contact with the OIG. 

The OIG receives complaints through various means such as U.S. mail, 

telephone, e-mail, and personal visits to the OIG. Once a hotline complaint 

has been received, a preliminary inquiry is conducted. When the inquiry has 

been completed, the hotline complaint can be closed with no further action 

taken, referred to management for action, or closed and an investigation is 

opened on the issue. 

During the period April 1, 2006 - September 30, 2006, the OIG opened 

four hotline complaints. One hotline complaint was closed and opened as an 

investigation. The OIG has a total of ten hotline complaints at different 

stages - six are pending; and four are currently in progress. 

Semiannual Report to Congress Page 17 April 1, 2006 – September 30, 2006 
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INVESTIGATION

The Office of Inspector General is authorized by the IG Act to receive 

and investigate allegations of fraud, waste and abuse occurring within FEC 

programs and operations. Alleged incidents of possible fraud, waste and 

abuse could include administrative, civil or criminal wrongdoing by FEC 

employees or contractors. Allegations are received primarily from FEC staff 

and management. However, members of Congress, other agencies, citizens, 

contractors, and public interest groups may also refer matters to the OIG for 

investigation. 

During this reporting period, the OIG completed an investigation that 

involved allegations of misconduct by several senior management officials. 

The alleged misconduct included a violation of a criminal conflict of interest 

law. As a result of the allegations, in November 2005, the OIG initiated a 

joint criminal investigation with the Federal Bureau of Investigation and the 

United States Attorney’s Office. Over the course of several months, the 

investigative team interviewed over twenty-six witnesses, reviewed 

thousands of electronic and paper records, executed a search warrant and 

performed other investigative work in order to obtain the facts surrounding 

the allegations. 

Semiannual Report to Congress Page 18 April 1, 2006 – September 30, 2006 
________________________________________________________________________________________________ 

During the investigation, additional evidence of administrative 

misconduct was uncovered by the OIG involving other employees. When 

appropriate, the OIG promptly forwarded the facts to management for 

further review. 

In September 2006, the U.S. Attorney’s Office for the District of 

Columbia ultimately declined to prosecute the primary subject of the 

investigation. Except for one employee, all of the subjects of the investigation 

retired, separated, or were terminated from the agency. At the conclusion of 

the investigation, the OIG recommended FEC management review the facts 

of the investigation and consider disciplinary action against one of the 

subjects who is still employed by the agency. 

In addition, during the course of the criminal and subsequent 

administrative investigation, the OIG provided management with several 

suggestions for administrative improvement, these included: 

• Improvement of Internal Control 

A key event in the investigation involved a $10,000 

obligation of funds payable to a law firm representing one 

of the witnesses and ultimate subjects in the 

investigation. 

Semiannual Report to Congress Page 19 April 1, 2006 – September 30, 2006 
________________________________________________________________________________________________ 

In addition to the involvement in creating a false 

statement of work (description of services ordered), a 

manager took the unusual step of signing a procurement 

request as the “Requestor,” “Office Head,” and “Budget 

Officer” to enable the funds to be obligated. This action 

removed one of the routine checks and balances in the 

procurement process to ensure that Commission funds are 

properly spent. Absent a written procedure requiring the 

segregation of duties on the procurement request, and 

with pressure by a supervisor, the Administrative Officer 

approved the procurement request, with reservations. 

The OIG suggested a written policy requiring the 

“Requestor”, “Office Head,” and “Budget Officer” to be 

separate individuals to further strengthen the internal 

controls over the procurement process. Effective internal 

controls, such as policies and procedures, can help detect 

and prevent errors and irregularities from occurring. 

Examples of internal controls include the integrity and 

ethical tone established by senior management, proper 

documentation of transactions, and segregation of duties. 

The segregation of duties requires different people to be 

responsible for the authorizing of transactions. This 

Semiannual Report to Congress Page 20 April 1, 2006 – September 30, 2006 
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control is to ensure than no single individual has control 

over all phases of a transaction, such as a financial 

obligation or payment of government funds. 

The OIG suggested the FEC revise existing procurement 

policies and procedures to ensure adequate segregation of 

duties on the approval of procurements. Specifically, the 

Administrative Officer’s approval of procurements should 

require adequate segregation of duties, i.e. the requestor 

of the goods and services should generally be a different 

person than the office head approval. Likewise, the 

budget approval should be a different person than the 

requestor and office head. 

Status 

Management agrees in principle with the suggestion for 

the additional control. The OIG suggested management 

evaluate the level of additional control and incorporate 

the change into the existing policies and procedures. 

• Lack of a Formalized EEO Training Program and Outdated 

Policies 

During the early part of the investigation, it became 

apparent that improvement was necessary in the FEC’s 

EEO program. Specifically, the FEC lacked a formalized 

Semiannual Report to Congress Page 21 April 1, 2006 – September 30, 2006 
________________________________________________________________________________________________ 

EEO training program and policies were in need of 

updating. 

A former Acting EEO Director held mandatory EEO 

training in December 2005 for all managers and 

supervisors. However, prior to this training program, the 

FEC’s formalized EEO training program for management 

and staff was minimal or non-existent. 

In addition, the FEC’s Personnel Instruction (PI) 713.1, 

Equal Employment Opportunity – Complaint Processing 

Procedures, has not been revised since June of 1986. The 

June 1986 personnel instruction continues to cite a 

federal regulation that was superseded in 1992 by a new 

Equal Employment Opportunity Commission (EEOC) 

regulation. The OIG identified the concern of outdated 

personnel policies during the fiscal year 2004 financial 

statement audit and recommended improvement in this 

area. 

The OIG suggested the FEC establish a formalized EEO 

training program and issue/update the necessary EEO 

policies and procedures. The training program should be 

provided on a regular and consistent basis to all 

employees. 

Semiannual Report to Congress Page 22 April 1, 2006 – September 30, 2006 
________________________________________________________________________________________________ 

Status 

The FEC is in the process of updating and creating 

several policies on the following: Alternative Dispute 

Resolution (ADR); Reasonable Accommodation; AntiHarassment; and a Personnel Instruction to replace PI 

713.1 Equal Employment Opportunity-Complaint 

Processing Procedures. In addition, the Staff Director has 

commenced an extensive review of Commission Directives 

in order to update Commission policy. 

The EEO Director has scheduled a mandatory EEO 

briefing on the No FEAR Act in October 2006 for all 

Commission staff. In addition to the training in October, 

all new employees are required to be trained on the No 

FEAR Act within ninety days of hire and all employees 

are to receive refresher training every two years. In 

addition, the EEO Director has plans to provide 

additional EEO training in 2007 to management, 

supervisors, and staff. 

• Improve the EEO Director’s Reporting Responsibility to the 

Commission 

The primary issue of the OIG’s investigation centered 

upon the allegation a senior management official was 

committing a criminal conflict of interest. Specifically, 

Semiannual Report to Congress Page 23 April 1, 2006 – September 30, 2006 
________________________________________________________________________________________________ 

the allegation suggested a senior management official was 

purposely hiding from the Commission an EEO complaint 

filed against him by a Commission employee and 

attempted to settle the complaint at the lowest level 

possible. It was further alleged the senior management 

official ignored his own EEO contractor’s advice 

cautioning about being directly involved in any EEO 

settlement negotiations, since the official was a named 

alleged discriminating official. 

As a result of the investigation, the OIG suggests the FEC 

improve the EEO Director’s reporting responsibilities to 

the Commission. 

There is a federal regulation requirement for the EEO 

Director to be under the immediate supervision of the 

agency head. This direct reporting requirement also 

ensures that the EEO director is able to act with the 

greatest degree of independence. 

Status 

Currently the EEO Director reports to the Staff Director. 

Since there are no plans to change the reporting 

responsibility of the EEO Director, the OIG suggests the 

EEO Director submit quarterly reports, through the Staff 

Director, to the Commission. The quarterly reports would 

Semiannual Report to Congress Page 24 April 1, 2006 – September 30, 2006 
________________________________________________________________________________________________ 

include a list of the types of complaints and the offices 

involved to inform the Commission of the EEO Office’s 

activities. 

• Improve Communication to Employees on the FEC’s Rules of 

Behavior and on the FEC’s Rules of Behavior and Acceptable Use 

Standards for Federal Election Commission Information and 

Systems Resources 

In order to investigate the reported allegations, the OIG 

obtained and reviewed the archived e-mails from the 

official e-mail accounts of the subjects, and principal 

witnesses associated with the investigation. The e-mail 

accounts included those of two senior management 

officials and revealed evidence showing violations of the 

FEC’s Rules of Behavior and Acceptable Use Standards 

for Federal Election Commission Information and Systems 

Resources. Even though both of the individuals had 

received training on the FEC’s computer rules of 

behavior, the two employees were found to be in violation 

of the FEC’s computer policy. Specific violations of the 

computer policy included: 

1) Numerous instant messages (apparently using the 

FEC’s Lotus Notes e-mail program’s instant messaging 

function) containing explicit sexual language. The instant 

Semiannual Report to Congress Page 25 April 1, 2006 – September 30, 2006 
________________________________________________________________________________________________ 

messages (IMs) were apparently copied and pasted into 

the employee’s e-mail account and saved; and 

2) E-mails containing explicit sexual language; and 

3) FEC e-mails were forwarded by one of the employees to 

an outside party. The e-mails contained potentially 

confidential information on FEC budget, personnel, and 

EEO issues. 

The OIG suggested that the FEC improve communication 

to employees on the FEC’s Rules of Behavior and 

Acceptable Use Standards for Federal Election 

Commission Information and Systems Resources. In 

addition to the annual computer training, the agency 

should utilize additional methods to communicate the 

importance of the rules of behavior. 

Status 

The FEC has provided annual security training to all 

employees and contractors in the last two years. In June 

2006, the FEC implemented a computer network banner 

on all FEC computers, based on a recommendation from 

the OIG. A network banner is an electronic warning 

message that is displayed on the computer screen, usually 

when the computer is turned on. The network banner is 

intended to be a daily reminder to employees that the 

Semiannual Report to Congress Page 26 April 1, 2006 – September 30, 2006 
________________________________________________________________________________________________ 

FEC’s computers are to be used in accordance with FEC 

policy and misuse of the network can result in adverse 

action and/or criminal prosecution. 

The FEC has taken steps to prevent the misuse of 

computer resources and should continue to adjust their 

communication methods regarding the policies and 

procedures, based on problems and events reported by 

management, the OIG, and other sources. 

Semiannual Report to Congress Page 27 April 1, 2006 – September 30, 2006 
________________________________________________________________________________________________ 

ADDITIONAL OFFICE OF INSPECTOR GENERAL ACTIVITY

In addition to conducting audits, inspections, and investigations, the 

OIG performs, and is involved in a variety of other projects and activities. All 

legislation, as compiled by the Commission’s Congressional Affairs Office, is 

reviewed by the Inspector General, as required by the Inspector General Act 

of 1978, as amended. The Inspector General reviews and provides comments, 

when appropriate, on all legislation provided by the PCIE/ECIE Legislative 

Committee. In addition, the Inspector General routinely reads all 

Commission agenda items and attends the Finance Committee meetings. 

• The OIG’s audit contractor is required to follow-up on the status 

of the FEC’s corrective actions with respect to findings and 

recommendations contained in previous audit report(s) on 

internal control. In an effort to close one or more outstanding 

recommendations, the OIG performed a limited audit follow-up 

review of fiscal year 2005 financial statements audit. Due to the 

narrow focus of the follow-up, and the lack of full 

implementation of the recommendations reviewed, no 

recommendations were closed as a result of the limited follow-up 

review. As in the past, management has been responsive in 

attempting to implement all OIG recommendations. The OIG 

appreciates management’s support and we look forward to 

Semiannual Report to Congress Page 28 April 1, 2006 – September 30, 2006 
________________________________________________________________________________________________ 

working with management in our ongoing efforts to promote 

economy and efficiency in agency programs. 

• The OIG requested a legal opinion from the FEC’s Office of General 

Counsel (OGC) on whether or not the FEC is required to comply 

with provisions of the Consolidated Appropriations Act, 2005. 

Provisions of the law require, among other things, that agencies 

protect information in identifiable form (IIF), designate a Chief 

Privacy Officer, report to the Congress and agency IG on privacy 

matters, and provide training to employees on privacy and data 

protection policies. The provision also requires that every two 

years, the agency IG contract with an independent third party to 

conduct a review of the agency’s privacy program and practices 

and that the IG issue a report based on that review. 

• On an annual basis, the OIG community sponsors an award 

ceremony to recognize individuals and teams for outstanding 

accomplishments in various fields such as evaluations, audits, 

and investigations. During this reporting period, the Deputy 

Inspector General served on the ECIE’s 2006 awards 

nomination panel. The nomination panel reviewed the 

Semiannual Report to Congress Page 29 April 1, 2006 – September 30, 2006 
________________________________________________________________________________________________ 

nominations submitted by the various OIGs and selected those 

individuals and/or teams to receive awards. 

Semiannual Report to Congress Page 30 April 1, 2006 – September 30, 2006 
________________________________________________________________________________________________ 

ECIE AND PCIE ACTIVITY

The President’s Council on Integrity and Efficiency (PCIE) and the 

Executive Council on Integrity and Efficiency (ECIE) were established by 

Executive Order 12805 – May 11, 1992, and is chaired by the Office of 

Management and Budget, and in addition to the Inspectors General, includes 

representatives from the Office of Personnel and Management, the Office of 

Government Ethics, the Office of Special Counsel, and the Federal Bureau of 

Investigations. 

The PCIE/ECIE have identical functions and responsibilities to 

coordinate and enhance governmental efforts to promote integrity and 

efficiency, and to detect and prevent fraud, waste and abuse in Federal 

programs. The PCIE is comprised of IGs appointed by the President of the 

United States. The ECIE consists of IGs appointed by the head of their 

respective agencies. 

The Inspector General is an active member of the Executive Council on 

Integrity and Efficiency and has provided input on a number of initiatives 

proposed by the Council. The ECIE serves as a forum for the exchange of 

views for the Inspector General Community. The IG attends regular 

Semiannual Report to Congress Page 31 April 1, 2006 – September 30, 2006 
________________________________________________________________________________________________ 

meetings held by the ECIE, and the IG also participates in joint meetings 

and activities with the President’s Council on Integrity and Efficiency. 

The OIG staff, which consists of the Inspector General, the Deputy 

Inspector General, an Auditor and the Special Assistant to the Inspector 

General, continually seeks ways to improve their performance, skills and 

knowledge. For the period April 1, 2006 through September 30, 2006, the 

Inspector General and/or the OIG staff attended the following training, 

meetings, programs, seminars, and/or conferences: 

• ECIE – Monthly Meetings 

• PCIE – Financial Statement Audit Network (FSAN) Meetings 

• PCIE / ECIE – 2006 Training Conference & Retreat – Adapting to 

Change, The Changing Role of the Inspector General Community 

• PCIE/ECIE – Audit Peer Review Training 

• PCIE / ECIE – Inspection and Evaluation (I&E) Roundtable 

Discussion 

• General Accountability Office (GAO) – Inspector General 

Coordination Meeting 

• Association of Government Accountants (AGA) – Financial 

Management Breakfast Seminar 

• Association of Government Accountants (AGA) – 55th Annual 

Professional Development Conference & Exposition 

• Association of Government Accountants (AGA) –First National 

Internal Control & Fraud Conference 

Semiannual Report to Congress Page 32 April 1, 2006 – September 30, 2006 
________________________________________________________________________________________________ 

• Federal Audit Executive Council (FAEC) – 2006 Federal Auditing 

Executive Council Conference – Value Adding Auditing 

• Federal Audit Executive Council (FAEC) – Presentations on 

Financial Audit Revisions to GAGAS; the FISMA Framework and 

Personal Identifiable Information; and Data Collection Instrument 

• Inspector General Institute Investigator Academy – IG Hotline 

Training Program 

• Western Intergovernmental Audit Forum – 16th Biennial Forum of 

Government Auditors 

• Federal Bureau of Investigation (FBI) – Public 

Corruption/Governmental Fraud Meeting 

• Federal Election Commission – Information Technology (IT) 

Security Awareness Training 

• Federal Election Commission – Administrative Liaison Group 

Meetings 

• Federal Election Commission – Records Management Program 

Training 

• Federal Election Commission – Occupant Emergency Plan (OEP) 

Briefing 

• Federal Election Commission – Time Reporting System (TRS) 

Training 

• Federal Election Commission – SPAM Manager Overview Training 

Semiannual Report to Congress Page 33 April 1, 2006 – September 30, 2006 
________________________________________________________________________________________________ 

IG ACT REPORTING REQUIREMENTS PAGE

Reporting requirements required by the Inspector General Act of 1978, as amended 

by the Inspector General Act Amendments of 1988 are listed below: 

Section 4(a)(2) Review of Legislation----------------------------------------- 28 

Section 5(a)(1) Significant Problems, Abuses, and 

 Deficiencies------------------------------------------------------ None 

Section 5(a)(2) Recommendations with Respect to

 Significant Problems, Abuses, and 

 Deficiencies------------------------------------------------------ None 

Section 5(a)(3) Recommendations Included in Previous 

Reports on Which Corrective Action Has 

Not Been Completed-(Table III)--------------------------- 37 

Section 5(a)(4) Matters Referred to Prosecuting 

 Authorities------------------------------------------------------- 18 

Section 5(a)(5) Summary of Instances Where Information 

 was Refused------------------------------------------------------ None 

Section 5(a)(7) Summary of Significant Reports--------------------------- 9 

Section 5(a)(8) Questioned and Unsupported Costs-(Table I)---------- 35 

Section 5(a)(9) Recommendations that Funds be put

to Better Use (Table II)---------------------------------------- 36 

Section 5(a)(10) Summary of Audit Reports issued before 

the start of the Reporting Period for which

no Management Decision has been made---------------- N/A 

Section 5(a)(11) Significant revised Management Decisions-------------- N/A 

Section 5(a)(12) Management Decisions with which the

 Inspector General is in Disagreement---------------------- None 

Semiannual Report to Congress Page 34 April 1, 2006 – September 30, 2006 
________________________________________________________________________________________________ 

TABLE I 

INSPECTOR GENERAL ISSUED REPORTS 

WITH QUESTIONED COSTS

DOLLAR VALUE (in thousands) 

QUESTIONED UNSUPPORTED 

NUMBER COSTS COSTS 

A. For which no Management 0 0 [0]

 decision has been made by 

 commencement of the reporting 

 period 

B. Which were issued during 0 0 [0]

the reporting period 

Sub-Totals (A&B) 0 0 [0] 

C. For which a Management 0 0 [0]

decision was made during 

 the reporting period 

(i) Dollar value of disallowed 0 0 [0] 

 costs 

(ii) Dollar value of costs 0 0 [0]

 not disallowed 

D. For which no Management 0 0 [0]

decision has been made by the 

 end of the reporting period 

E. Reports for which no Management 0 0 [0]

decision was made within 

 six months of issuance 

Semiannual Report to Congress Page 35 April 1, 2006 – September 30, 2006 
________________________________________________________________________________________________ 

TABLE II 

INSPECTOR GENERAL ISSUED REPORTS WITH 

RECOMMENDATIONS THAT FUNDS BE PUT TO BETTER USE

NUMBER DOLLAR VALUE 

(in thousands) 

A. For which no Management 0 0 

decision has been made by 

the commencement of the

 reporting period 

B. Which were issued during 0 0 

the reporting period 

C. For which a Management 0 0 

decision was made during

the reporting period 

(i) dollar value of 0 0 

 recommendations 

 were agreed to by

 Management 

based on proposed 0 0 

 Management action 

based on proposed 0 0 

 legislative action 

(ii) dollar value of 0 0 

 recommendations 

that were not agreed 

 to by Management 

D. For which no Management 0 0 

decision has been made by 

the end of the reporting period 

E. Reports for which no 0 0 

 Management decision 

was made within six months 

 of issuance 

Semiannual Report to Congress Page 36 April 1, 2006 – September 30, 2006 
________________________________________________________________________________________________ 

TABLE III 

SUMMARY OF AUDIT REPORTS WITH CORRECTIVE ACTIONS 

OUTSTANDING FOR MORE THAN SIX MONTHS

Financial Statement Audits 

Recommendations 

Fiscal Year 

Report 

Number Repeat* New Closed Total 

Fiscal Year 2004 OIG-04-01 0 42 12 30 

Fiscal Year 2005 OIG-05-01 30 11 0 41 

* Repeat column represents recommendations from the prior fiscal year report that 

 are still applicable to the current fiscal year report. 

Semiannual Report to Congress Page 37 April 1, 2006 – September 30, 2006 
_____________________________________________________________________________________________ 

FEC / OIG Strategic Plan - Fiscal Years 2005 - 2010 

OIG Products: To provide products 

and services that promote positive 

change in FEC policies, programs, and 

operations. 

OIG Process: To develop and implement 

processes, policies, and procedures to ensure 

the most effective and appropriate use of OIG 

resources in support of our people and 

products. 

OIG Staff: To maintain a skilled and motivated 

work force in an environment that fosters 

accountability, communications, teamwork, and 

personal and professional growth. 

Objective A: Deliver timely, high-quality 

products and services that promote 

positive change. 

Strategy: - establish common OIG standards for communicating 

results; 

- conduct quality assurance programs; 

- solicit appropriate internal and external review and 

comment; 

- comply with applicable statutory guidelines and 

standards; 

- set realistic and appropriate milestones. 

Objective B: Address priority issues 

and concerns of the Commission, 

Management, and Congress. 

Strategy: Perform work that supports; 

- Federal Election Commission and Congressional 

priorities; 

- Strategic Management Initiative efforts; 

Focus OIG attention in the following areas of 

emphasis: 

- managing change; 

- resource allocation in relation to policy objectives; 

- delivery of client service; 

- causes of fraud and inefficiency; and, 

- automation and communication. 

Objective C: Follow-up and evaluate 

results of OIG products and services to 

assess their effectiveness in promoting 

positive change. 

Strategy: - Identify, as appropriate, lessons learned to improve 

timeliness and quality; and, 

- conduct follow-up reviews to determine if intended 

results have been achieved. 

Objective D: Satisfy customers, 

consistent with the independent nature 

of the OIG. 

Strategy: - establish professional communication and 

interaction with customers to promote the open 

exchange of ideas; 

- incorporate customer feedback, as appropriate; and, 

- be open to customer-generated solutions and 

options. 

Objective A: Maintain a dynamic strategic 

planning process. 

Strategy: - periodically review and update the strategic plan to 

address changing OIG and FEC priorities; and, 

- identify factors that influence organizational change 

and develop short and long term plans to address them. 

Objective B: Plan and conduct costeffective work that address critical issues 

and results in positive change. 

Strategy: 

- solicit FEC and Congressional input in planning OIG 

activities; 

- develop internal planning mechanisms to support FEC 

goals and priorities; 

- ensure that priorities of IG are effectively 

communicated; and, 

- identify specific targets for OIG review that are the most 

cost-effective 

Objective C: Identify customer needs and 

provide products and services to meet 

them. 

Strategy: - establish new customer feed back mechanisms; 

- consider and evaluate customers feedback when 

planning and developing products and services; 

- respond to Congressional inquires and request for 

briefing and testimony; 

- promote open exchange of ideas and information 

through outreach and through use of e-mail; and, 

- receive, evaluate, and respond, as appropriate, to 

information received through the OIG hotline and other 

sources. 

Objective D: Implement efficient, effective, 

and consistent resolution and follow-up 

procedures. 

Strategy: - ensure that IG follow-up procedures are followed and 

that management is aware of their role in the process; 

- establish common OIG standards for terminology, date 

maintenance and communications. 

Objective E: Establish a positive and 

productive working environment. 

Strategy: - reengineer or streamline OIG procedures to achieve the 

most effective use of resources; and, 

- ensure that necessary technologies, evolving and 

otherwise, are made available to staff as needed. 

Objective A: Attract and retain well-qualified, 

diverse and motivated employees. 

Strategy: - develop and implement a comprehensive recruiting program 

that attracts a broad population with the knowledge, skills, 

abilities, and expertise necessary to make meaningful 

contributions to the OIG; 

- assess employee satisfaction and develop strategies to 

address employee concerns; 

- identify reasons for staff departures and develop plans to 

foster greater staff retention; and, 

- adhere to EEO principles and strive to maintain a diverse work 

force. 

Objective B: Provide training and 

developmental opportunities to employees. 

Strategy: 

- assess training needs in relation not only to employee but also 

office needs as well; 

- ensure that Government Auditing Standards in relation to 

training are adhered to; and, 

- maintain a reporting system to ensure that educational 

requirements are met. 

Objective C: Assess, recognize, and reward, 

when possible, performance that contributes to 

achieving the OIG mission. 

Strategy: 

- develop and articulate expectations for each employee's 

performance, including contributions in meeting the mission & 

goals of the OIG; and, 

- ensure that rewards, when possible, are given in recognition of 

exceptional employee performance. 

Objective D: Create and maintain a working 

environment that promotes teamwork and 

effective communication. 

Strategy: - ensure that communication between employees is open; 

- provide employees with the tools and incentives they need to 

adequately perform their duties. 

Performance Measures: Determine the 

timeliness and quality of products and 

services; their effectiveness in 

promoting positive change; and, reach 

agreement with management on at least 

90% of recommendations within six 

months of the report issue date. 

Performance Measures: An annual audit 

plan is issued; strategic plan is periodically 

reviewed; and, necessary technology is 

provided to staff to enable them to most 

efficiently perform their duties. 

Performance Measures: All employees meet 

the training requirements; all employees have 

performance standards; and all employees 

meet the basic requirements for the position in 

which they were hired to perform. 

Semiannual Report to Congress Page 38 April 1, 2006 – September 30, 2006 
________________________________________________________________________________________________ 

CONTACTING THE OFFICE OF INSPECTOR GENERAL 

The success of the OIG mission to prevent fraud, waste, and abuse depends 

on the cooperation of FEC employees (and the public). There are several 

ways to report questionable activity. 

Call us at 202-694-1015 or toll-free 1-800-424-9530. A confidential or 

anonymous message can be left 24 hours a day/7 days a week. 

Write or visit us - we are located at: Federal Election Commission 

 Office of Inspector General

 999 E Street, N.W., Suite 940 

 Washington, D.C. 20463 

Mail is opened by OIG staff members only. 

You can also contact us by e-mail at: oig@fec.gov.

 Website address: http://www.fec.gov/fecig/fecig.shtml 

Individuals may be subject to disciplinary or criminal action for knowingly 

making a false complaint or providing false information. 

Semiannual Report to Congress Page 39 April 1, 2006 – September 30, 2006