Page 12 of 13
Approved January 31, 2002



The Audit staff reviewed the disclosure of disbursements for the
completeness and accuracy of the information provided on Committee reports. Based on
this review, we identified a material number of disbursements for which the purpose
disclosed did not meet the requirements of 11 CFR §104.3(b)(3). The purposes were
disclosed as “contract services.”

During audit fieldwork, and at the exit conference, the Audit staff
informed the Committee officials of this matter. The Committee subsequently filed
amended reports that corrected its disclosure reports.

In the preliminary audit report, the Audit staff recommended no further action

regarding this matter.

Ti. DETERMINATION OF NET OUTSTANDING CONVENTION EXPENSES
AND AMOUNT DUE TO THE U.S. TREASURY

Section 9008(b) of Title 26 of the United States Code states that the
national committee of a major party shall be entitled to payments under paragraph (3),
with respect to any presidential nominating convention, in amounts that, in the aggregate
shall not exceed $4,000,000, as adjusted by the Consumer Price Index. The Committee’s
entitlement for the 2000 nominating convention was $13,512,000.

Section 9008.8(a)(1) of Title 11 of the Code of Federal Regulations states
the national committee of a major party may not incur convention expenses with respect
to a Presidential nominating convention which, in the aggregate, exceed the amount to
which such committee is entitled under 11 CFR 9008.4 and 9008.5.

Section 9008.10(g) of Title 11 of the Code of Federal Regulations states,
in part, a convention committee shall file, no later than sixty days after the last day of the
convention, a statement of that committee’s net outstanding convention expenses.

Section 9008.12(b)(5) of Title 11 of the Code of Federal Regulations
states if any portion of the payment under 11 CFR 9008.4 remains unspent after all
convention expenses have been paid, that portion shall be returned to the Secretary of the
Treasury. The national committee or convention committee shall make an interim
repayment of unspent funds based on the financial position of the committee as of the
end of the ninth month following the last day of the convention, allowing for a
reasonable amount as determined by the Commission to be withheld for unanticipated
contingencies. The interim repayment shall be made no later than 30 calendar days after
the end of the ninth month following the last day of the convention.

Page 6 of 13
Approved January 31, 2002


REPORT OF THE AUDIT DIVISION
ON THE

COMMITTEE ON ARRANGEMENTS
FOR THE 2000 REPUBLICAN
NATIONAL CONVENTION

Approved January 31, 2002

FEDERAL ELECTION COMMISSION
999 E STREET, N.W.
WASHINGTON, D.C.



CHRONOLOGY

COMMITTEE ON ARRANGEMENTS FOR THE
2000 REPUBLICAN NATIONAL CONVENTION

Audit Fieldwork December 6, 2000 -
February 9, 2001
Preliminary Audit Report
To Committee November 8, 2001

Response Received to the
Preliminary Audit Report January 7, 2002

Final Audit Report Approved January 31, 2002

Page 13 of 13
Approved January 31, 2002


Page 10 of 13
Approved January 31, 2002


Page 2 of 13
Approved January 31, 2002


TABLE OF CONTENTS

COMMITTEE ON ARRANGEMENTS FOR THE 2000
REPUBLICAN NATIONAL CONVENTION

Page

Executive Summary 1
Final Audit Report 3
Background 3
Findings 5

Transmittal to Committee 11

Chronology 13




FEDERAL ELECTION COMMISSION
WASHINGTON, D.C. 20463

February 25, 2002

Mr. Alec Poitevint, Treasurer
Committee on Arrangements for the

2000 Republican National Convention
228 South Washington Street, Suite 200
Alexandria, VA 22314

Dear Mr. Poitevint:

Attached please find the Report of the Audit Division on the Committee on
Arrangements for the 2000 Republican National Convention (Final Audit Report). The
Commission approved this report on January 31, 2002. As noted on page 3 of this report,
the Commission may pursue any of the matters discussed in an enforcement action.

The report reflects the Committee’s repayment to the United States Treasury of
$32,525 on January 7, 2002 in accordance with 11 CFR 9008.12. This amount agrees with
the amount recommended be repaid in the preliminary audit report.

The Commission approved audit report will be placed on the public record on
March 4, 2002. Should you have any questions regarding the public release of this report,
please contact the Commission’s Press Office at (202) 694-1220.

Any questions you may have related to matters covered during the audit or in the
audit report should be directed to Tom Hintermister or Marty Favin of the Audit Division

at (202) 694-1200 or toll free at (800) 424-9530.
Sincerely, : /

Jos£ph F. Stoltz
Assistant Staff Director
Audit Division

cc: Mr. Keith Davis
Huckaby, Davis and Associates

Attachment as stated

Page 11 of 13
Approved January 31, 2002


FEDERAL ELECTION COMMISSION

WASHINGTON, DC 20463

REPORT OF THE AUDIT DIVISION
ON THE
COMMITTEE ON ARRANGEMENTS FOR THE
2000 REPUBLICAN NATIONAL CONVENTION

EXECUTIVE SUMMARY

The Committee on Arrangements for the 2000 Republican National Convention
(the Committee) registered with the Federal Election Commission on January 30, 1998,
as a national convention committee of the Republican Party. During the period covered
by the audit, Mr. Alec Poitevint was the treasurer of the Committee and continues to
serve in that capacity. The Committee maintained offices in Washington, D.C.,
Alexandria, VA and Philadelphia, PA.

The audit was conducted pursuant to Section 9008(g) of Title 26 of the United
States Code, which directs the Commission to conduct an examination and audit of the
payments for presidential nominating conventions no later than December 31 of the
calendar year in which the presidential nominating convention is held.

The matters summarized below were presented to the Committee at an exit
conference held on March 27, 2001 and later in the preliminary audit report. Action
taken by the Committee is described in the audit report.

DISCLOSURE OF DISBURSEMENTS — 2 U.S.C. §§437(2), 434(b)(4)(A) & (5)(A)
and 11 CFR §104.3(b)(3)(iA) & (B). The Audit staff identified a material number of
disbursements for which the purpose disclosed as “contract services” did not comply
with the regulations. The Committee filed amended reports to correct these items.

DETERMINATION OF NET OUTSTANDING CONVENTION EXPENSES AND
AMOUNT DUE TO THE U.S. TREASURY — 26 U.S.C. §9008(b); 11 CFR §§9008.8(a)(1),
9008.10(g) and 9008. 12(b)(5) & (c). The NOCE as calculated by the Audit staff in the
preliminary audit report showed unspent funds, or an amount spent that was less then the
limitation, of $32,525. In response to the preliminary audit report, the Committee made
a repayment to the United States Treasury in that amount.

Page 1 of 13
Approved January 31, 2002


FEDERAL ELECTION COMMISSION

WASHINGTON, DC. 20463

March 4, 2002

MEMORANDUM

TO:

FROM:

SUBJECT:

RON M. HARRIS
PRESS OFFICER
PRESS OFFICE

JOSEPH F.STOLTZ .
ASSISTANT STAFF/ TOR

PUBLIC ISSUANCE;OF THE FINAL AUDIT REPORT ON
THE COMMITTEE ON ARRANGEMENTS FOR THE 2000
REPUBLICAN NATIONAL CONVENTION

Attached please find a copy of the final audit report and related documents on the
Committee on Arrangements for the 2000 Republican National Convention that was
approved by the Commission on January 31, 2002.

Informational copies of the report have been received by all parties involved and
the report may be released to the public on March 4, 2002.

Attachment as stated

ce: Office of General Counsel
Office of Public Disclosure
Reports Analysis Division
FEC Library


cC.

D.

appropriate:

COMMITTEE ORGANIZATION

The Committee registered with the Federal Election Commission on
January 30, 1998, as a National Committee of the Republican Party. Alec Poitevint has
been the Treasurer for the Committee since January 30, 1998. At various times during
the period covered by the audit, the Committee maintained offices in Washington, D.C.,
Alexandria, VA and Philadelphia, PA. The Committee records are currently maintained
in Alexandria, VA.

The Committee used three bank accounts to handle its financial activity.
From these accounts it made approximately 2,300 disbursements during the period
covered by the audit. The Committee received $13,512,000 in federal funds that
represented the full entitlement established at 26 U.S.C. §9008(b).

AUDIT SCOPE AND PROCEDURES

The audit included testing of the following general categories as

N

the receipt of contributions from prohibited sources;

the receipt of contributions or loans in excess of the statutory
limitations;

proper disclosure of receipts including the itemization of receipts
when required, as well as, the completeness and accuracy of the
information disclosed;

proper disclosure of disbursements including the itemization of
disbursements when required, as well as, the completeness and
accuracy of the information disclosed (see Section II.);

proper disclosure of Committee debts and obligations;

the accuracy of total reported receipts, disbursements and cash
balances as compared to Committee bank records;

adequate record keeping for Committee transactions;

accuracy of the Statement of Net Outstanding Convention Expenses
filed by the Committee to disclose its financial condition
(see Section III.);

compliance with requirements concerning expenditures for convention
expenses;

Page 4 of 13
Approved January 31, 2002


FEDERAL ELECTION COMMISSION

WASHINGTON, DC 20463

REPORT OF THE AUDIT DIVISION
ON THE
COMMITTEE ON ARRANGEMENTS FOR THE 2000 REPUBLICAN
NATIONAL CONVENTION

1 BACKGROUND
A. AUDIT AUTHORITY

This report is based on an audit of the Committee on Arrangements for the
2000 Republican National Convention (the Committee), to determine whether there has
been compliance with the provisions of the Federal Election Campaign Act of 1971, as
amended (the Act). The audit was conducted pursuant to Section 9008(g) of Title 26 of
the United States Code that directs the Commission to conduct an examination and audit
of the payments for presidential nominating conventions no later than December 31 of
the calendar year in which the presidential nominating convention is held.

In addition to examining the receipt and use of Federal funds, the audit
seeks to determine if the Committee has materially complied with the limitations,
prohibitions and disclosure requirements of the Act.

B. AUDIT COVERAGE

The audit covered the period from February 18, 1998 (the date of the
Committee’s first financial transaction) through September 17, 2000. In addition,
financial activity was reviewed through September 30, 2001 to determine any amounts
due to the United States Treasury. The Committee reported an opening cash balance of
$-0-, total receipts of $14,252,108, total disbursements of $10,570,300, and a closing
cash balance on September 17, 2000 of $3,681,808. The Committee also reported the
receipt of goods and services from various commercial vendors in exchange for
promotional consideration at the national nominating convention.

Page 3 of 13
Approved January 31, 2002








Section 9008.12(c) of the Title 11 of the Code of Federal Regulation states
the Commission will follow the same repayment determination procedures, and the
committee has the same rights and obligations as are provided for repayment
determinations involving publicly funded candidates under 11 CFR 9007.2(c) through

(h).

The 2000 Republican Convention ended on August 3, 2000. The
Committee filed a Statement of Net Outstanding Convention Expenses (NOCE), as of
September 17, 2000. The Audit staff reviewed the Committee’s financial activity
through September 30, 2001 and estimated winding down costs in preparing the figures
shown on the next page.

Page 7 of 13
Approved January 31, 2002


The Audit staff calculated the Committee has unspent funds after all
convention expenses had been paid and considering winding down costs estimated
through June 30, 2002. Pursuant to 11 CFR §9008.12, the Committee shall make an
interim repayment of unspent funds no later than 30 calendar days after the end of the
ninth month following the last day of the convention (June 30, 2001). On August 15,
2001, the Committee submitted an interim repayment in the amount of $269,537.
Therefore, as of September 30, 2001, the remaining amount of unspent funds repayable
to the United States Treasury is $32,525.

In the preliminary audit report the Audit staff recommended that the Committee
provide documentation demonstrating that either (a) no repayment of unspent funds was
due, or (b) a repayment was due of a lesser amount. Absent such a showing, the Audit
staff recommended that the Commission determine that $32,525 was repayable to the
United States Treasury pursuant to 11 CFR §9008.12. A repayment of $32,525 was made
on January 7, 2002.

Page 9 of 13
Approved January 31, 2002






10. the Committee’s compliance with spending limitations, and
11. other audit procedures that were deemed necessary in the situation.

As part of the Commission’s standard audit process, an inventory of
campaign records was conducted prior to the audit fieldwork. This inventory was
conducted to determine if the committee’s records were materially complete and in an
auditable state. The records were found to be materially complete and the audit
fieldwork commenced.

Unless specifically discussed below, no material non-compliance was
detected. It should be noted that the Commission may pursue further any of the matters
discussed in this report in an enforcement action.

I. AUDIT FINDING AND RECOMMENDATION
DISCLOSURE OF DISBURSEMENTS

Section 437(2) of Title 2 of the United States Code states, in part, that
each committee or other organization which represents a national political party in
making arrangements for the convention of such party held to nominate a candidate for
the office of President or Vice President, shall, within 60 days following the end of the
convention (but not later than 20 days prior to the date on which the presidential and
vice-presidential electors are chosen), file with the Commission a full and complete
financial statement, in such form and detail as it may prescribe, of the sources from
which it derived its funds, and the purpose for which such funds were expended.

Sections 434(b)(4)(A) and (5)(A) of Title 2 of the United States Code
state, in relevant part, that each report shall disclose expenditures made to meet
committee operating expenses, and the name and address of each person to whom an
expenditure in an aggregate amount or value in excess of $200 within the calendar year is
made by the reporting committee to meet a committee operating expense, together with
the date, amount, and purpose of such operating expenditure.

Sections 104.3(b)(3)(i)(A) and (B) of Title 11 of the Code of Federal
Regulations state, in part, that the term “purpose” means a brief statement or description
of why the disbursement was made. Descriptions which would not meet the
requirements of 11 CFR 104.3(b)(3) for reporting the purpose of an expenditure are
advance, election day expenses, other expenses, expenses, expense reimbursement,
miscellaneous, outside services, get-out-the-vote and voter registration.

Page 5 of 13
Approved January 31, 2002


COMMITTEE ON ARRANGEMENTS FOR THE 2000 REPUBLICAN

NATIONAL CONVENTION

STATEMENT OF NET OUTSTANDING QUALIFIED CONVENTION EXPENSES

As of September 17, 2000

As Calculated September 30, 2001

ASSETS
Cash in Bank
Capital Assets
Other Assets
Accounts Receivable
Total Assets
OBLIGATIONS
Disbursements for Convention Expenses and
Winding Down Costs

(9/18/00-9/30/01)

Estimated Winding Down Costs *
(10/1/01-6/30/02)

Total Obligations

NET OUTSTANDING CONVENTION EXPENSES

Less: Interim Repayment made 8/15/01

Amount Repayable to the United States Treasury

$ 3,681,965
$ 0
$ 0
$ 214.495
$ 3,241,948
$ 352.450

$ 3,896,460

$_3,594,398

302.062”

$

$ (269,537)

g 32,525*

The Audit staff's calculation includes $100,000 for estimated costs relative to the printing and distribution

of the 2000 Official Proceedings. The NOCE statement prepared by the Committee includes estimated

winding down costs through 12/31/04

This figure represents the amount of unspent convention funds as calculated 9/30/01. Since estimates

were used in calculating this figure, the Audit staff will review the Committee's disclosure reports and
Committee records to compare the actual figures with the estimates and prepare adjustments as necessary.

“ Repayment of $32,525 was made on January 7, 2002
Page 8 of 13

Approved January 31, 2002