Attached as stated

December 22, 1980

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PUBLIC ISSUANCE OF FINAL AUDIT REPORT -

CONNECTICUT DEMOCRATIC FEDERAL CANDIDATES

COMMITTEE

FRED EILAND

PRESS OFFICE

BOB COSTA

JUDY HAWKINS

FEDF.RAl ELECTION COMMISSION

\\'''SItI~CIO~. DC 204b1

cc: FEC Library

RAD

Public Record ;,..' .

Informational copies of this report have been received

by all parties involved and this report may be releused to

the public as of today, December 22, 1980.

AttGched please find a copy of the final audit report of

the Connecticut Democratic Federal Candidates Committee which

was ~pproved by the Commission on December 10, 1980.

SUBJECT:

FROM:

THROUGH:

TO:

MEMORANDUM

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FEDERAL ELECTION COMMISSION

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REPORT OF THE AUDIT DIVISION

ON THE

CONNECTICUT DEMOCRATIC FEDERAL CANDIDATES CO~~ITTEE

A. Overview

This report is based on an audit of the Connecticut

Democratic FeJ.eral Candidates Committee (lithe Committee")

undertaken by the Audit Division of Federal Election Commission

in accordance with the Commission's audit policy to determine

whether there has been compliance with the provisions of the

Federal Election campaign Act of 1971, as amended (lithe Act") .

The audit was conducted pursuant to Section 438(a) (8) of Title 2

of the United States Code which, at the time of the audit,

directed 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.

The Committee registered as the Connecticut Democratic

Federal Candidates Committee with the Federal Election Commission

on October 1, 1976. The Committee maintained its headquarters

in Hartford, Connecticut.

The audit covered the period from September 28, 1976

through November 29, 1976, the date of the Committee's termination report.

The Committee reported a beginning cash balance on

September 28, 1976 of $-0-, total receipts of $11,100.00, total

expenditures of $11,100.00, and a closing cash balance as of

Nov~mber 29, 1976 of $-0-.

This audit report is based on documents and workpapers

which support each of its factual statements. They form part

of the record upon which the Commission based its decisions on

till! matters in the report and were available to Commissioners

and appropriate staff for revie\'l.
C. Scope

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II. Audit Findings and Recommendations

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Transfer Received from Unregistered Committee

Key Personnel

A.

B.

(ii) Establish a single con~ittee with a single account

to make contributions to Federal and non-Federal candidates, but

only if all contributions received ~re permissable under the

;'.ct, and all contributors arc in f(ll"1n(~d that all contributions are

subject to the limitations or Sections 110.1, 110.2, and 110.5.

During the period of th~~ dUllit, Section l02.6(b) (2) of

Title 11, Code of Federal Regulations, stated, in part, that the

acco~nts and committees in (a) (2) (i) and (ii) of this section may

not receive transfers from an account or committee established

b'.' a State committee, subordinate committee of a State committee,

o~ another political committee, exc(Jpt from a cOIl~ittee or account

s~t out in paragraph (a) (i) and (ii) of this section.

~/ The Commission's Regulations were not promulgated until

April 13, 1977.

(i) Establish a sep~rate Federal campaign Committee

~hich shall register as a pollical committee. The Federal

cu~paign committee shall establish a segregated Federal account

i~ either a national or Stale bank; or

During the period of the audit, the proposed section

102.6(a) (2) (i) and (ii) of Title 11, Code of Federal Regulations, 1/ stated that any political committee which has solicited

or receIved contributions for or on behalf of, or made expenditures

or transfers to or on behalf of, any candidate for Federal office

shall either:

The audit included such tests as verification of total

reported receipts and expenditures and individual transactions;

review of required supporting documentation; analysis of debts

and obligations; and such other audit procedures as deemed

necessary under the circumstances.

The principal officers of the Committee during the

period audited were: Henry D. Altobello, Chairman, and Arline

M. Bidwell, Treasurer.

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On February 5, 1980, the Commission approved the

recommendation of the Office of General Counsel and closed the

file.

During our review of Conuuittee records, we found that

tho Committee made six (6) transfers to Federal candidates

tot.::l1ing $11,000.00. Of this total, three (3) transfers were in

excess of $1,000.00 with respect to the 1976 General Election.

Section 44la(a) (1) (A) of Title 2 of tho United States

Code states that no person shall make contributions to any candid.::lte and his authorized political committees with respect to

any election for Federal office which, in the aggregate, exceed

$1,000.00.

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13. Contributions In Excess of the Limitation

\'le found that the Committee failed to meet the criteria

est.:lblished by the Act to qualify as a mul ticandidate political

committee since the Committee was not registered with the Federal

Election Commission for at least six (6) months as required.

'l'll~refore, it \.;ras the opinion of the Audit staff that the Committet:

oxceeded the limitation in its support of Federal candidates in

one (1) instance by $4,000.00 and in the two (2) remaining instances

by $750.00 each.

This matter was referred to th~ Commission's Office of

General Counsel for further review on April 16, 1979, where

Matter Under Review 1089 was subsequently initiated. The Office

of General Counsel, after investigating the matter, recommended

that the Commission take no further action against the Committee

with regard to a violation of Section 102.6(b) (2) in view of the

fact that the Commission's Regulations were not promulgated until

April 13, 1977, and the Committee is no longer involved in federal

activity.

During our review of Coromi ttee n:,cords, we found that

the Committee received one (1) transfer fl"01l\ the connecticut

Democl:"atic State Central Committee, an unn'qistered state level

party organization, totaling $11,100.00. This transfer represents

the only funds received by the Committee. Although the State of

Connecticut prohibits corporate contributions, there is no such

restriction on labor union contributions.

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This matter was referred to the Conm\ission's Office

of General Counsel for further review on April 16, 1979, where

M~tter Under Review 1089 was subsequently initiated. The

Office of General Counsel after investigating the matter,

recommended that the Commission find reason to believe that the

Committee may have violated section 441a(a) (1) (A) by exceeding

the $1,000.00 limitation in its support of the three (3) Foderal

candidates, and take no further action in the matter. The

Office of General Counsel based its recommendation on the fact

that the activity dates back to 1976 and ~he Committee is no

longer in existence. On February 5, 1980~ the Commission

approved the recommendation of the oft ice of Gener':11 Counsel

and closed the file.
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FEDERAL ElECTION COM.'vllSSION

H.!'j to. "I lotH I "'.\\'.

W\"HI'c; ION.I H'. .!lJ4b \

AIDmaw.. INFORMATION REGARDING 'lHIS ORGANIZATION

MAY BE IOCATED IN A OOMPLETED cn1PLIANCE ACTIOO

FILE RELEASED BY 'mE CDMISSION AND MADE PUBLIC IN

'!HE PUBLIC RECX>RDS OFFICE. FOR '!HIS PARTICULAR

ORGANIZATION'S OOMPLETED CXH'LIANCE ACTION FILE

SIMPLY JSK FOR '!HE PRESS st»fARY OF MIJR 41 / oJ? .

'!HE PRESS SUt+fARY WIIL PROVIDE A BRIEF HIS'lURY OF

'!HE AND A StM1ARY OF 'mE ACTIONS TAKEN, IF AN'{.