• FEDERAL ELECTIO~ COMMISSION

WASHINGTON, 0 C 204&3

A83-3

November 30, 1983

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MEMORANDUM

TO:

FROM:

SUBJECT:

FRED EILAND

PRESS OFFICER~

BOB COSTA ~y

PUBLIC ISSUANCE OF FINAL AUDIT REPORT - OKLAHOMA REPUBLICAN STATE COMMITTEE

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•

Attached is a copy of the final audit report of the Oklahoma

Republican State Committee which was approved by the Commission

on November 17, 1983.

Informational copies of the report have been received by all

parties involved and the report may be relea~d to the public.

Attachment as stated

cc: FEC Library

~~lic Record

Office of General Counsel
FEDERAL ELECTION COMMISSION

WASHINCTON. D.C. 20463

A83-3

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REPORT OF THE AUDIT DIVISION

ON THE

OKLAHOMA REPUBLICAN STATE COMMITTEE

I. Background

A. Overview

This report is based on an audit of the Oklahoma

Republican State Committee ("the Committee"), undertaken by the

Audit Division of the 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 ("the Act"). The audit was

conducted pursuant to Section 438(b) of Title 2 of the United

States Code which states, in part, that the Commission may conduct audits and field investigations of any political committee required to file a report under Section 434 of this

title. Prior to conducting any audit under this section, the

Commission shall perform an internal review of reports filed by selected committees to determine if tbe reports filed by a

particular committee meet the threshold requirements for

substantial compliance with the Act.

The Committee registered with tbe United States House

of Representatives on April 17, 1972 and maintains its

headquarters in Oklahoma City, Oklahoma.

The audit covered the period January 1, 1981, through December 31, 1982. The Committee reported an opening cash on

hand balance January 1, 1981 of $21,858.66; total receipts for

the period of $847,569.85; total disbursements for the period of

$836,679.71; and a closing cash balance December 31, 1982 of

$32,748 .. 20. Y

This report is based on documents and working papers supporting each of its factual statements. They form part of the

record upon which the Commission based its decisions on the

matters in this report and were available to Commissioners and

appropriate staff for review. .

1/ The Committee made minor math errors with regard to reported

activity.
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B. Key Personnel

The Treasurers of the Committee during the period of

audit were Mr. Carl Anderson, Jr. from January 1, 1981 through February 1981J Mr. Lesley Ming from February 1981 through December 1981; Mr. Michael Freeman was acting Treasurer December

1981 through February 14, 1982J and Mr. Herbert G. Davis from

February 15, 1982 through December 31, 1982. 2/

c. Scope

The audit included such tests as verification of total

reported receipts and disbursements and individual transactions;

review of required su~porting documentationJ analysis of

Committee debts and obligationsJ and such other audit procedures

as deemed necessary under the circumstances.

II. Audit Findings and Recommendations

A. Disclosure of Contributions

Section 434 (b) (2) (F), (3) (D) and (5) (C), Title 2,

United States Code, requires a political party committee to

disclose in its Reports of Receipts and Disbursements the total

amount of all receipts of transfers from other political party

committees, and the name and address of each political party committee from which it receives a transfer, or to which it makes

a transfer, together with the date and amount of such transfers.

Further, subsection (3) (B) of this section requires disclosure of

the identification of each political committee which makes a

contribution to the reporting committee, together with the eate

and amount of any such contribution.

The Audit staff reviewed the Committee's daily cash

receipts journal, contribution files and bank recores for the

period of audit and determined that the Committee received 10

contributions totaling $3,192.62 from seven (7) political committees. The Committee did not disclose the identification of

these political committees, and the dates and amounts of the

contributions. These receipts were apparently disclosed as

unitemized contributions.

In response to the interim audit report, the Committee

filed an amendment disclosing the contributions noted above.

1/ The Committee was not specific with regard to dates of

changes in the Office of Treasurer.

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Recommendation

The Audit staff recommends no further action on this matter.

B. Disclosure of Interest Income

Section 434(b) (3) (F) and (G), Title 2, United States

Code requires a political committee to disclose in its Reports of

Receipts and Disbursements the identification of each person who

provides a rebate, refund, or other offset to operating expenditures, or interest income, in an aggregate amount or value

in excess of $200 within the calendar year, together with the

date and amount of such receipt.

The Audit staff reviewed the Committee's daily receipts

journal and bank records during the period of audit and

determined that the Committee received interest income totaling $8,732.82. The Committee did not disclose the identification of

two (2) banks from which it received interest income aggregating in excess of $200 during the calendar years and totaling $8,494.25. The Detailed Summary Pages of Receipts and

Disbursements (Page 2, FEe Form 3X) filed during the period of

audit contained the disclosure of other receipts (dividends,

interest, etc.) totaling $7,306.88. Since no Schedules A were

filed in support of this disclosed amount, the Audit staff could

not associate this reported amount with the recorded amount.

The accountant for the Committee stated that he did not

realize that these receipts required itemization on Schedule A.

The discrepancies noted above did not materially affect

the total receipts reported for the period.

In response to the interim audit report, the Committee

filed amendments to the disclosure reports disclosing the above

receipts.

Recommendation

The Audit staff recommends no further action on this matter.

c. Matters Referred to the Office of General Counsel

Certain matters noted during the audit were referred to

the Commission's Office of General Counsel on November 17, ·1983.