FEDERAL ELECTION COMMISSION

 WASHINGTON, D.C. 20463

June 6, 2023

MEMORANDUM 

To: The Commission 

Through: Alec Palmer 

Staff Director 

Dayna C. Brown 

Assistant Staff Director 

Audit Division 

Zuzana O. Pacious

Audit Manager 

From: Patricia C. Orrock 

s

Chief Compliance Officer ce Offic

irecto

k

By: Christopher Carrell

Lead Auditor 

Subject: Audit Division Recommendation Memorandum on the Communications 

Workers of America – COPE Political Contributions Committee (A21-09

Pursuant to Commission Directive No. 70 (FEC Directive on Processing Audit Reports), 

the Audit staff presented the Draft Final Audit Report DFAR) to the Communications 

Workers of America–COPE Political Contributions Committee (CWA) on March 1, 2023 

(see attachment). CWA did not request an audit hearing. 

This memorandum provides the Audit staff’s recommendation for each finding outlined in 

the DFAR. 

In response to the DFAR, to address Finding 2, Disclosure of Occupation and Name of 

Employer, CWA provided comments on March 17, 2023. Subsequently, on April 3, 2023, 

CWA responded formally and filed amended disclosure reports on April 3, 4 and 5, as noted 

below. 
2 

Finding 1. Misstatement of Financial Activity 

The Audit staff recommends that the Commission find that, in 2019, CWA 

overstated its beginning and ending cash on hand balances by $244,198 and 

$222,357, respectively; and, in 2020, overstated its beginning and ending cash on 

hand balances by $222,357 and $265,267, respectively. 

Finding 2. Disclosure of Occupation and Name of Employer 

In its initial March 17th response to the DFAR, CWA stated that it was “...having 

difficulty submitting the updated occupation and name of employer information for 

the 16,7[6]8 contributions totaling $597,808 for which it has obtained that 

information.” CWA stated that it initially was prepared to disclose the information 

via a Form 99, however, such a filing would require dozens of forms due to character 

limitations. CWA further stated that it was hopeful that the Reports Analysis 

Division (RAD) could assist in filing the information on a Form 99, and it was 

working to find a way to do so.1

 In its subsequent April 3rd response, CWA stated 

that “While [it] appreciates the need to comply with all the steps required by 11 

C.F.R. §104.7(b) to demonstrate “best efforts,” the difficulty that [it] has 

encountered in attempting to do so is not unique.” Due to the large volume of 

occupation and name of employer entries at issue, CWA urged the Commission to 

consider expanding and modernizing the options available to filers disclosing 

additional occupation/name of employer information to comply with the regulation. 

CWA subsequently filed 23 amended reports for the 2019-2020 election cycle, to 

disclose occupation and name of employer information that was previously 

undisclosed or inadequate. CWA's amended reports disclosed additional adequate 

occupation and name of employer information for 10,944 contributions totaling 

$423,840. However, the occupation and name of employer information for 7,758 

contributions, totaling $246,877, remain inadequate or undisclosed.2

 As such, CWA 

did not materially correct the public record. 

The Audit staff recommends that the Commission find that CWA failed to disclose 

or adequately disclose the occupation and name of employer information for 18,702 

contributions from individuals totaling $670,717. 

The Office of General Counsel has reviewed this memorandum and concurs with the 

recommendations. 

If this memorandum is approved, the Proposed Final Audit Report will be prepared and 

circulated within 30 days of the Commission’s approval. 

1

 On March 20, Audit and RAD staff met with the CWA representatives. The representatives acknowledged 

that, due to Form 99 character limitations, such a filing may not be feasible, given the significant number 

of transactions to be disclosed. CWA asked if an Excel spreadsheet with the required information could be 

submitted to RAD, so that RAD could upload it onto Form 99. RAD and Audit staff explained that, given 

the text-only limitations of Form 99, such an upload was not possible and suggested that CWA consider 

other ways to remedy the disclosure, as recommended in the DFAR. 2 Of the 7,758 contributions, 7,394 contributions totaling $235,076 continue to disclose “Information 

Requested” as the occupation. The remaining 364 contributions totaling $11,801 contain inadequate 

occupation and/or name of employer information. 
3 

If this Audit Division Recommendation Memorandum is not approved on a tally vote, 

Directive No. 70 states that the matter will be placed on the next regularly scheduled 

open session agenda. 

Documents related to this audit report can be viewed in the Voting Ballot Matters folder. 

Should you have any questions, please contact Christopher Carrell or Zuzana Pacious at 

694-1200. 

Attachment: 

- Draft Final Audit Report of the Audit Division on the Communications Workers of 

America – COPE Political Contributions Committee 

cc: Office of General Counsel 
Draft Final Audit Report of the 

Audit Division on the 

Communications Workers of 

America – COPE Political 

Contributions Committee 

(January 1, 2019 - December 31, 2020)

Why the Audit 

Was Done

Federal law permits the 

Commission to conduct 

audits and field 

investigations of any 

political committee that is 

required to file reports 

under the Federal 

Election Campaign Act 

(the Act). The 

Commission generally 

conducts such audits 

when a committee 

appears not to have met 

the threshold 

requirements for 

substantial compliance 

with the Act. 1 The audit 

determines whether the 

committee complied with 

the limitations, 

prohibitions and 

disclosure requirements 

of the Act.

Future Action

The Commission may 

initiate an enforcement 

action, at a later time, 

with respect to any of the 

matters discussed in this 

report.

About the Committee (p. 2)

Communications Workers of America – COPE Political 

Contributions Committee is a separate segregated fund – labor 

organization and lobbyist/registrant political action committee, 

headquartered in Washington, DC. For more information, see the 

chart on the Committee Organization, p. 2. 

Financial Activity (p. 2)

• Receipts

o Contributions from Individuals

o Contributions from Other

Political Committees

o Refunds of Contributions Made

to Political Committees

Total Receipts

$ 8,884,026 

7,500 

98,400 

$ 8,989,926 

• Disbursements

o Operating Expenditures

o Transfers to Affiliated/Other

Party Committees

o Contributions to Federal

Candidates/Committees

o Independent Expenditures

o Contribution Refunds

o Other Disbursements

Total Disbursements

$ 784,482 

22,582 

5,222,523 

55,708 

948 

5,236,445 

$ 11,322,688 

Findings and Recommendations (p. 3) 

• Misstatement of Financial Activity (Finding 1)

• Disclosure of Occupation and Name of Employer (Finding 2)

1

 52 U.S.C. §30111(b).

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Draft Final Audit Report of the 

Audit Division on the 

Communications Workers of 

America – COPE Political 

Contributions Committee 

(January 1, 2019 - December 31, 2020) 

DRAFT
Table of Contents 

Page 

Part I. Background

 Authority for Audit 1 

 Scope of Audit 1 

Part II. Overview of Committee 

Committee Organization 2 

Overview of Financial Activity 2 

Part III. Summaries 

Findings and Recommendations 3 

Part IV. Findings and Recommendations

Finding 1. Misstatement of Financial Activity 4

Finding 2. Disclosure of Occupation and Name of Employer 5

 

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1 

Part I

Background

Authority for Audit

This report is based on an audit of the Communications Workers of America – COPE Political 

Contributions Committee (CWA), undertaken by the Audit Division of the Federal Election 

Commission (the Commission) in accordance with the Federal Election Campaign Act of 1971, 

as amended (the Act). The Audit Division conducted the audit pursuant to 52 U.S.C. §30111(b), 

which permits the Commission to conduct audits and field investigations of any political 

committee that is required to file a report under 52 U.S.C. §30104. Prior to conducting any audit 

under this subsection, the Commission shall perform an internal review of reports filed by 

selected committees to determine if the reports filed by a particular committee meet the threshold 

requirements for substantial compliance with the Act. 52 U.S.C. §30111(b). 

Scope of Audit

Following Commission-approved procedures, the Audit staff evaluated various risk factors and 

as a result, this audit examined: 

1. the disclosure of individual contributors’ occupation and name of employer; 

2. the consistency between reported figures and bank records; 

3. the completeness of records;

4. the disclosure of independent expenditures; and 

5. other committee operations necessary to the review.

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2 

Part II

Overview of Committee 

Committee Organization 

Important Dates

• Date of Registration March 20, 1975 

• Audit Coverage January 1, 2019 - December 31, 2020 

Headquarters Washington, District of Columbia

Bank Information 

• Bank Depositories One

• Bank Accounts One checking

Treasurer

• Treasurer When Audit Was Conducted Sara Steffens

• Treasurer During Period Covered by Audit Sara Steffens

Management Information

• Attended FEC Campaign Finance Seminar Yes

• Who Handled Accounting and 

Recordkeeping Tasks

Paid Staff

Overview of Financial Activity 

(Audited Amounts)

Cash on hand @ January 1, 2019 $ 3,252,122 

Receipts

o Contributions from Individuals 8,884,026

o Contributions from Other Political Committees 7,500

o Refunds of Contributions Made to Political 

Committees 98,400 

Total Receipts 8,989,926

Disbursements

o Operating Expenditures 784,482

o Transfers to Affiliated/Other Party Committees 22,582

o Contributions to Federal 

Candidates/Committees 5,222,523 

o Independent Expenditures 55,708

o Contribution Refunds 948

o Other Disbursements 5,236,445

Total Disbursements 11,322,688

Cash on hand @ December 31, 2020 $ 919,360

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3

Part III

Summaries

Findings and Recommendations 

Finding 1. Misstatement of Financial Activity

During audit fieldwork, a comparison of CWA’s reported financial activity with its bank 

records revealed a misstatement of the beginning and ending cash on hand balances for 

calendar years 2019 and 2020. In 2019, CWA overstated its beginning and ending cash 

on hand balances by $244,198 and $222,357, respectively. In 2020, CWA overstated its 

beginning and ending cash on hand balances by $222,357 and $265,267, respectively. In 

response to the Interim Audit Report recommendation, CWA corrected the public record 

by amending its cash on hand balance on its 2022 June Monthly Report filed on January 

26, 2023. In addition, CWA amended its subsequent 2022 disclosure reports to reflect 

the corrected cash on hand balance. (For more detail, see p. 4.) 

Finding 2. Disclosure of Occupation and Name of 

Employer

During audit fieldwork, a review of contributions from individuals requiring itemization 

indicated that 18,702 contributions, totaling $670,717, lacked or inadequately disclosed 

the required occupation and/or name of employer information. CWA did not sufficiently 

demonstrate “best efforts” to obtain, maintain and submit the required information. 

During audit fieldwork and in response to the exit conference, CWA provided “best 

efforts” documentation for 16,768 contributions totaling $597,808. However, CWA has 

not filed amended reports to disclose missing or inadequate information. In response to 

the Interim Audit Report recommendation, CWA stated that it intends disclose additional 

occupation and name of employer information obtained for contributions made during the 

audit period by filing Forms 99 (Miscellaneous Electronic Submission) or, alternatively, 

by filing amended Schedules A on future regularly-scheduled disclosure reports or 

amending its 2019-2020 disclosure reports. As of the date of this report, CWA has not 

done so. Absent the filing of amended 2019-2020 reports, Forms 99, or amended memo 

Schedules A on its next regularly scheduled disclosure reports, CWA has not corrected 

the public record for 16,768 contributions totaling $597,808 for which it received “best 

efforts” documentation. Additionally, for 1,542 contributions totaling $55,185, CWA has 

not provided “best efforts” documentation or disclosed the adequate occupation and/or 

name of employer for these contributions. Lastly, CWA may provide any comments it 

deems relevant for 392 contributions totaling $17,724 for which the “best efforts” 

notifications were sent untimely. (For more detail, see p. 5.) 

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4

Part IV

Findings and Recommendations

Finding 1. Misstatement of Financial Activity 

Summary 

During audit fieldwork, a comparison of CWA’s reported financial activity with its bank 

records revealed a misstatement of the beginning and ending cash on hand balances for 

calendar years 2019 and 2020. In 2019, CWA overstated its beginning and ending cash 

on hand balances by $244,198 and $222,357, respectively. In 2020, CWA overstated its 

beginning and ending cash on hand balances by $222,357 and $265,267, respectively. In 

response to the Interim Audit Report recommendation, CWA corrected the public record 

by amending its cash on hand balance on its 2022 June Monthly Report filed on January 

26, 2023. In addition, CWA amended its subsequent 2022 disclosure reports to reflect 

the corrected cash on hand balance. 

Legal Standard 

Contents of (Federal) Reports. Each report must disclose:

• The amount of cash on hand at the beginning and end of the reporting period; 

• The total amount of receipts for the reporting period and for the calendar year; 

• The total amount of disbursements for the reporting period and for the calendar 

year; 52 U.S.C. §30104(b)(1), (2), and (4).

Facts and Analysis 

A. Facts

During audit fieldwork, the Audit staff reconciled CWA’s reported financial activity with 

its bank records for calendar years 2019 and 2020. This review indicated that, in 2019, 

CWA overstated the beginning and ending cash on hand balances by $244,198 and 

$222,357, respectively. In 2020, CWA overstated the beginning and ending cash on hand 

balances by $222,357 and $265,267, respectively. The cash on hand balance 

discrepancies for 2019 and 2020 resulted primarily from prior period adjustments, as well 

as minor misstatements of both receipts and disbursements during the audit period. 

B. Interim Audit Report & Audit Division Recommendation

The Audit staff discussed the misstatements for 2019 and 2020 with CWA’s 

representatives during the exit conference and provided schedules detailing the 

information. In response to the exit conference, CWA explained some of the minor 

misstatements of receipts and disbursement during the audit period, identified by the 

Audit staff. For example, CWA explained that it did not report an erroneous wire 

transfer. Additionally, CWA explained that several disbursements identified as 

‘unreported’ were actually reported but the check numbers on the bank statements were 

missing one or more digits due to possible scanning errors or data entry errors by the 

bank. CWA reviewed its records of the actual checks and matched the erroneous check 

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5

numbers on the bank statements to the correct check numbers and provided a spreadsheet 

identifying the recipients of the checks and the date on which CWA reported them, which 

the Audit staff verified. The spreadsheet also explained other immaterial receipt and 

disbursement misstatements, many of which stemmed from prior reporting periods. 

These discrepancies, however, did not resolve the misstated beginning and ending cash 

on hand balances. In fact, the explanations resulted in an increase in the overstatements 

of the 2019 beginning and ending cash on hand balances by $3,000 and $25,675, 

respectively, as compared to the misstated cash on hand balances presented during the 

exit conference,2

 and did not affect the ending cash on hand for 2020 which remained 

overstated by $265,267. In its response to the exit conference, CWA did not address or 

further explain the misstated beginning and ending cash on hand balances.

The Interim Audit Report recommended that CWA amend its most recently filed 

disclosure report to correct the cash on hand balance with an explanation that the change 

resulted from a prior period adjustment. Further, it was recommended that CWA 

reconcile the ending cash on hand balance of its most recent disclosure report and correct 

any subsequent discrepancies. 

C. Committee’s Response to Interim Audit Report

In response to the Interim Audit Report recommendation, CWA corrected the public 

record by amending its cash on hand balance on its 2022 June Monthly Report filed on 

January 26, 2023, annotating that this was a one-time cash adjustment resulting from the 

2019/2020 Commission audit. CWA also amended its subsequent 2022 disclosure 

reports to reflect the corrected cash on hand balance.3 

Finding 2. Disclosure of Occupation and Name of 

Employer 

Summary 

During audit fieldwork, a review of contributions from individuals requiring itemization 

indicated that 18,702 contributions, totaling $670,717, lacked or inadequately disclosed 

the required occupation and/or name of employer information. CWA did not sufficiently 

demonstrate “best efforts” to obtain, maintain and submit the required information. 

During audit fieldwork and in response to the exit conference, CWA provided “best 

efforts” documentation for 16,768 contributions totaling $597,808. However, CWA has 

not filed amended reports to disclose missing or inadequate information. In response to 

the Interim Audit Report recommendation, CWA stated that it intends disclose additional 

occupation and name of employer information obtained for contributions made during the 

audit period by filing Forms 99 (Miscellaneous Electronic Submission) or, alternatively, 

by filing amended Schedules A on future regularly-scheduled disclosure reports or 

amending its 2019-2020 disclosure reports. As of the date of this report, CWA has not 

2

 The 2019 beginning cash on hand balance increase of $3,000 = $244,198 - $241,198; the 2019 ending 

cash on hand balance increase of $25,675 = $222,357 - $196,682. 3

 On January 27, 2023, CWA amended its cash on hand balance on the following 2022 disclosure reports: 

2022 July Monthly; 2022 August Monthly; 2022 September Monthly; 2022 October Monthly; 2022 PreGeneral; 2022 Post-General; and 2022 Year-End. 

DRAFT
6

done so. Absent the filing of amended 2019-2020 reports, Forms 99, or amended memo 

Schedules A on its next regularly scheduled disclosure reports, CWA has not corrected 

the public record for 16,768 contributions totaling $597,808 for which it received “best 

efforts” documentation. Additionally, for 1,542 contributions totaling $55,185, CWA has 

not provided “best efforts” documentation or disclosed the adequate occupation and/or 

name of employer for these contributions. Lastly, CWA may provide any comments it 

deems relevant for 392 contributions totaling $17,724 for which the “best efforts” 

notifications were sent untimely.

Legal Standard 

A. Itemization Required for Contributions from Individuals. A political committee 

other than an authorized committee must itemize any contribution from an individual 

if it exceeds $200 per calendar year, either by itself or when combined with other 

contributions from the same contributor. 52 U.S.C. §30104(b)(3)(A).

B. Required Information for Contributions from Individuals. For each itemized

contribution from an individual, the committee must provide the following 

information: 

• the contributor’s full name and address (including zip code); 

• the contributor’s occupation and the name of his or her employer; 

• the date of receipt (the date the committee received the contribution);

• the amount of the contribution; and 

• the calendar year-to-date total of all contributions from the same individual. 52 

 U.S.C. §30104(b)(3)(A) and 11 CFR §§100.12 and 104.3(a)(4)(i). 

C. Best Efforts Ensure Compliance. When the treasurer of a political committee

shows that the committee used best efforts (see below) to obtain, maintain, and 

submit the information required by the Act, the committee’s reports and records will

be considered in compliance with the Act. 52 U.S.C. §30102(i) and 11 CFR 

§104.7(a). 

D. Definition of Best Efforts. The treasurer and the committee will be considered to 

have used “best efforts” if the committee satisfied all of the following criteria:

• All written solicitations for contributions included:

 A clear request for the contributor's full name, mailing address, 

occupation, and name of employer; and 

 The statement that such reporting is required by Federal law. 

• Within 30 days after the receipt of the contribution, the treasurer made at least 

one effort to obtain the missing information, in either a written request or a 

documented oral request. 

• The treasurer reported any contributor information that, although not initially 

provided by the contributor, was obtained in a follow-up communication or 

was contained in the committee’s records or in prior reports that the 

committee filed during the same two-year election cycle. 11 CFR §104.7(b). 

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7

E. Reporting Missing Information. If any of the contributor information is received 

after the contribution has been disclosed on a regularly scheduled report, the political 

committee shall either:

• File with its next regularly scheduled report, an amended memo Schedule A 

listing all contributions for which contributor identifications have been 

received and an indication of the previous report(s) to which the memo 

Schedule A relates; or

• File amendments which include the contributor identifications together with 

 the dates and amounts of the contributions. 11 CFR §104.7(b)(4)(i). 

Facts and Analysis 

A. Facts

CWA did not disclose or inadequately disclosed the required occupation and/or name of 

employer information for contributions requiring itemization on its FEC reports, as of the 

date of the audit notification letter. 

Contributions Requiring Itemization - 

Missing or Inadequate Occupation and/or Name of Employer Disclosure

Number of Contributions 18,702 

Dollar Value of Contributions $670,717 

Percent of Contributions 58% 

For contributions requiring itemization on Schedule A (Itemized Receipts), CWA 

disclosed the following 18,702 unacceptable entries totaling $670,717: 

• “Information Requested” or “N/A” for 18,373 contributions totaling $660,430; and

• Inadequate occupation and/or name of employer for 329 contributions totaling 

$10,287. 

1. Contributor Information Obtained but Not Disclosed: 

During audit fieldwork, the Audit staff reviewed the contribution documentation 

provided by CWA to determine if it utilized the “best efforts” to obtain, maintain and 

submit the required disclosure information. The Audit staff identified 16,768 

contributions, totaling $597,808, for which CWA obtained the required contributor 

occupation and/or name of employer information but did not disclose the information: 

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8

2. Best Efforts Not Demonstrated: 

CWA did not provide the Audit staff records to document “best efforts” for the 

following: 

B. Interim Audit Report & Audit Division Recommendation

4

 CWA’s receipt database for the audit period contained the occupation and name of employer information 

for 7,147 contributions totaling $267,628. 5

 Based on mail merge files submitted by CWA in response to the exit conference. 6

 See supra footnote 5. 7

 Based on an Occupation/Name of Employer Spreadsheet submitted by CWA in response to the exit 

 conference.

Contributor Information Obtained but Not Disclosed

Contributor Information in CWA’s records at the Start of the Audit4

Dollar Value of Contributions 

7,147

$267,628

Contributor Information Obtained from Untimely “Best Efforts” Letters5

Dollar Value of Contributions 

505

$18,733 

Contributor Information Obtained from Timely “Best Efforts” Letters6

Dollar Value of Contributions 

159

$6,256 

Contributor Information in CWA’s Records (no record of when the 

information was obtained)7

Dollar Value of Contributions 

8,957

$305,191 

Total Number of Contributions

Total Dollar Value of Contributions 

16,768 

$597,808 

 Best Efforts Documentation Not Provided by CWA 

Number of Contributions 1,542 

Dollar Value of Contributions $55,185 

Best Efforts Notification Sent Untimely by CWA with No Responses Obtained

Number of Contributions 392 

Dollar Value of Contributions 

DRAFT

$17,724 
9

The Audit staff discussed this matter with the CWA representatives during audit 

fieldwork and at the exit conference and provided the schedule detailing these disclosure 

errors. In response to the exit conference, CWA stated that it searched its contribution 

and membership records for the 2,1708 individuals who lacked the required disclosure 

information, as identified by the Audit staff. Of the 2,170 individuals, CWA stated that 

it had “complete [occupation and name of employer] information for 1,7749– more than 

80% of the individuals whose contributions were identified as requiring “best efforts” 

documentation.” In response to the exit conference, CWA also provided the following 

documentation: 

1. Sample Best Efforts Letter – A sample "best efforts" letter which was also

provided during audit fieldwork. 

2. Mail Merge Files – Mail merge files which contained the complete and adequate 

occupation and/or name employer information for 148 contributors who made 664 

contributions totaling $24,989.10 CWA did not submit the contributor 

information on its disclosure reports. 

3. Occupation/Name of Employer Spreadsheet – CWA provided a committee 

spreadsheet that included the occupation and name of employer information for 

1,598 contributors whose 8,957 contributions totaled $305,191.11 CWA did not 

submit the contributor information on its disclosure reports. 

CWA acknowledged that the additional information provided in response to the exit 

conference did not “constitute direct evidence that the Committee made “best efforts” to 

obtain missing information from all contributors during the audit period....” However, 

8

 CWA’s reference to 2,170 individuals is a reference to the number of contributors who made the 18,702 

contributions totaling $670,717 described in the first table on page 7 of this report; many of CWA’s 

contributors made multiple contributions. The Audit staff presented a schedule at the exit conference 

that detailed disclosure errors for 2,161 contributors that were not on the receipt database with complete 

occupation and name of employer information and nine contributors that were on the receipt database 

with complete occupation and name of employer information. These nine contributors did not have their 

occupation and/or name of employer information disclosed on the disclosure reports. 9

 The 1,774 individuals CWA references appear to refer to a subset of contributors that make up the 16,768 

contributions, totaling $597,808, as described in the second table on page 7 of this report. Specifically, 

the 1,774 contributors CWA identifies appear to refer to those contributions represented in the bottom 

three rows of the aforementioned table: contributor information obtained from timely and untimely “best 

efforts” letters, and contributor information in CWA’s records for which there was no record of when 

that information was obtained. This subset represents the records CWA provided to the Audit staff 

during fieldwork and represents 9,621 (505 + 159 + 8,957) contributions totaling $330,180 ($18,733 + 

$6,256 + $305,191). In addition to this, however, the Audit staff’s review also identified contributor 

information already in CWA’s records at the start of the audit, representing 7,147 contributions totaling 

$267,628, as reflected in the first row of the table. Taken together, therefore, CWA did not disclose 

contribtuor information for 16,768 contributions totaling $597,808. Finally, although CWA refers in its 

response to “1,774” contributors, the Audit staff’s analysis shows that this number is actually 1,746 

contributors. 

10 Most of the 148 contributors made multiple contributions. 664 contributions totaling $24,989, consisted 

of 505 untimely “best efforts” letters ($18,733) and 159 timely “best efforts” letters ($6,256). See the

Contributor Information Obtained but Not Disclosed chart on page 7. 11 Most of the 1,598 contributors made multiple contributions.

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10

CWA believed that its record of outreach to the contributors named in the “mail merge” 

files and the fact that it obtained the complete information for the “overwhelming 

majority of contributors” identified during the audit, demonstrates its compliance with the 

Commission’s “best efforts” requirements. 

Additionally, CWA stated that it modified its procedures for documenting its “best 

efforts” to obtain missing occupation and name of employer information in early 2021. 

CWA has centralized the printing and mailing of all letters requesting the occupation 

and/or name of employer information through its in-house print shop. CWA explained 

that, during the audit period, each member of its compliance personnel team sent letters 

to the contributors whose contributions they had been assigned to process, whereas now, 

its compliance personnel create, on a monthly basis, one centralized list of missing 

occupation and/or name of employer information which is used to generate one file for 

letters to contributors. Bypassing its administrative divisions, CWA now sends these 

letters immediately after filing the monthly report. 

Based on contributor documentation provided by CWA during fieldwork and in response 

to the exit conference, CWA obtained the occupation and name of employer information 

for a total of 16,768 contributions totaling $597,80812, however CWA did not submit the 

obtained information on its disclosure reports.

To correctly disclose this information, the Interim Audit Report recommended that CWA: 

• Amend its 2019-2020 disclosure reports; 

• File a Form 99 (Miscellaneous Electronic Submission)13; or 

• File an amended memo Schedule A (Itemized Receipts) on its next regularly 

scheduled disclosure report listing all the contributions for which it received 

additional information.

The Interim Audit Report further recommended that CWA provide documentation that 

would demonstrate “best efforts” for the 1,542 contributions totaling $55,185, and/or 

disclose the adequate occupation and/or name of employer information for these 

contributions using one of the methods outlined above. Finally, the Interim Audit Report 

recommended that CWA provide any comments it deemed relevant for the 392 

contributions, totaling $17,724, for which “best efforts” notifications were sent untimely.

C. Committee’s Response to Interim Audit Report

In response to the Interim Audit Report recommendation, CWA stated that, in the near 

future, it intends to file Forms 99 (Miscellaneous Electronic Submission) to disclose the 

occupation and name of employer information obtained during the audit period. 

However, since Form 99 can only accommodate filing information in a text format, CWA 

stated it may need to file amended disclosure reports instead. 

12 See the Contributor Information Obtained but Not Disclosed chart on page 7. 13 CWA was advised by the Audit staff if it chose to file a Form 99, instead of amending its disclosure 

reports, the form must contain all pertinent information that is required on the schedule.

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11

Regarding the 1,934 contributions totaling $72,90914, for which CWA was neither able to 

provide the adequate occupation and name of employer information, nor provide 

documentation demonstrating timely “best efforts”, CWA stated that its “efforts to locate 

the missing name and employer information ... are ongoing.’ As a result, CWA 

anticipates that its filings in response to the Interim Audit Report recommendations 

“...may disclose information for contributors beyond those which [CWA] provided to the 

Audit Division in the course of the audit.” Finally, CWA noted that it is also “in the 

process of reviewing its internal procedures for recording and reviewing occupation and 

employer information when payroll deduction contributions are authorized initially.” 

CWA expects these combined efforts to yield significant improvements in the 

completeness of its contribution records in reports filed after the audit period. 

Absent the filing of amended 2019-2020 reports, Forms 99, or amended memo Schedules 

A on its next regularly scheduled disclosure reports, the Audit staff maintains that CWA 

has not corrected the public record for 18,702 contributions totaling $670,717, that lacked 

or inadequately disclosed the required occupation and/or name of employer information. 

14 These contributions are enumerated in section A.2. Best Efforts Not Demonstrated, on page 8, above.

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