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FEDERAL ELECTION COMMISSION

WASHINGTON DC 20463

November 14 . 2001

Mr. Richard Runbeck, Treasurer
Runbeck for Congress

P. O. Box 291

Circle Pines, MN 55014

Dear Mr. Runbeck:

Attached please find the Final Audit Report on Runbeck for Congress. The
Commission approved the report on November 9, 2001.

The Commission approved Final Audit Report will be placed on the public record
on November 21, 2001. Should you have any questions regarding the public release of the
report, please contact the Commission's Press Office at (202) 694-1220. Any questions
you have related to matters covered during the audit or in the report should be directed to
Deanne McClintock or Wanda Thomas of the Audit Division at (202) 694-1200 or toll free
at (800) 424-9530.

Sincerely,

Robert J a

Deputy Staff Director
for Audit and Review

Attachment as stated

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To manage its financial activity, RFC maintained four bank accounts.
From these accounts, 439 disbursements were made. RFC’s reported receipts were
comprised of contributions from individuals totaling $551,002; 193 contributions from
political committees, totaling $303,368; contributions from the Candidate totaling
$11,000; and, a loan from the Candidate in the amount of $20,000. Accounting and
recordkeeping functions were performed by paid campaign staff, which utilized
commonly available campaign management and accounting software.

D. AUDIT SCOPE AND PROCEDURES

Following Commission-approved procedures, the Audit staff evaluated
various risk factors and as a result. the scope of this audit was limited to the following:
(1) the accuracy of total reported receipts, disbursements and cash balances as compared
to bank records; and, (2) the completeness of RFC’s disclosure of contributors’
occupation and name of employer.

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

Il. AUDIT FINDING AND RECOMMENDATION

Disclosure of Occupation/Name of Employer

Section 434(b)(3)(A) of Title 2 of the United States Code requires, in part,
a political committee to disclose the identification of each person who makes a
contribution during the reporting period to the committee in an aggregate amount or
value in excess of $200 within the calendar year, together with the date and amount of
any such contribution.

Section 431(13)(A) of Title 2 of the United States Code defines the term
“identification” to mean, in the case of any individual, the name, the mailing address, and
the occupation of such individual, as well as the name of his or her employer.

Section 432(i) of Title 2 of the United States Code states, in part, that
when the treasurer of a political committee shows that best efforts have been used to
obtain, maintain, and submit the information required by this Act for the political
committee, any report or any records of such committee shall be considered in
compliance with this Act.

Section 104.7(b) of Title 11 of the Code of Federal Regulations states, in
relevant part, that the treasurer will only be deemed to have exercised best efforts to
obtain, maintain and report the required information if for each contribution received
aggregating in excess of $200 per calendar year which lacks required contributor
information, the treasurer makes at least one effort after the receipt of the contribution to
obtain the missing information. Such effort shall consist of either a written request sent
to the contributor or an oral request to the contributor documented in writing. The

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FEDERAL ELECTION COMMISSION AOT-1S

WASHINGTON DC 20465

REPORT OF THE AUDIT DIVISION
ON THE
RUNBECK FOR CONGRESS

I. BACKGROUND

A AUDIT AUTHORITY

This report is based on an audit of Runbeck for Congress (RFC)
undertaken by the Audit Division of the Federal Election Commission (the Commission)
in accordance 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 that 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 utle. Prior to conducting any audit under this subsection, the Commission shal}
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.

B. AUDIT COVERAGE

The audit covered the period from January 1, 1999 through December 31,
2000. RFC reported a beginning cash balance of $32.975; total receipts of $913,541;
total disbursements of $905,857; and a closing cash balance of $45,690.!

Cc COMMITTEE ORGANIZATION

RFC registered with the Commission on January 22, 1997 as the principal
campaign committee for Linda Runbeck (the Candidate), Republican candidate for the
U.S. House of Representatives from the state of Minnesota. Sixth Distnct. RFC
maintains its headquarters in Circle Pines. MN and its treasurer both currently and during
the audit period is Mr. Richard Runbeck.

‘all figures in this report have been rounded to the nearest dollar. In addition, these figures do not foot
as the result of a $5,058 error carrying forward ending cash on hand from the 2000 July 15" Quanerly
Teport to beginning cash on hand of the next report.

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Approved November 9, 2001



FEDERAL ELECTION COMMISSION
WASHINGTON, DC 20463

November 26, 2001

MEMORANDUM

TO: RON M. HARRIS
PRESS OFFICER
PRESS OFFICE

FROM: ROBERT J. COSTA
DEPUTY STAFF DIRECTOR

SUBJECT: PUBLIC ISSUANCE OF THE FINAL AUDIT REPORT ON
RUNBECK FOR CONGRESS

Attached please find a copy of the final audit report and related documents on
Runbeck for Congress that was approved by the Commission on November 9, 2001.

Informational copies of the report have been received by all parties involved and
the report may be released to the public on November 26, 2001.

Attachment as stated

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


CHRONOLOGY

RUNBECK FOR CONGRESS
Audit Fieldwork August 23 -
October 18, 2001
Final Audit Report
to the Committee November 14, 2001
Final Audit Report Approved November 9, 2001

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Approved November 9, 2001


written or oral request must be made no later than thirty days after receipt of the
contribution. The written or oral request shall not include material on any other subject
or any additional solicitation, except that it may include language solely thanking the
contributor for the contribution.

RFC disclosed 866 contributions from individuals on Schedules A. The
Audit staff reviewed these reported entries, along with amendments thereto that included
additional contributor information, to determine if the RFC had disclosed the
contributors’ occupation and/or name of employer. We determined that for 234 of the
866 items (27%), the required information was not disclosed.

The Audit staff reviewed amended Schedules A (itemized receipts) filed
subsequent to notification of the audit and concluded that RFC had disclosed additional
contributor information to materially correct the public record.

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FEDERAL ELECTION COMMISSION
WASHINGTON. DC 20463

REPORT OF THE AUDIT DIVISION
ON
RUNBECK FOR CONGRESS
EXECUTIVE SUMMARY

Runbeck for Congress (RFC) registered with the Federal Election Commission on
January 22,1997 as the principal campaign committee for Linda Runbeck, Republican
candidate for the U.S. House of Representatives from the state of Minnesota, Sixth Distnct
RFC maintains its headquarters in Circle Pines, MN and its treasurer both currently and during
the audit period is Mr. Richard Runbeck.

The audit was conducted pursuant to 2 U.S.C. §438(b), which states that the
Commission may conduct audits of any political committee whose reports fail to meet the
threshold level of compliance set by the Commission.

The finding of the audit report was presented to the Committee at the completion of
fieldwork on October 18, 2001. The following is an overview of the finding contained in the
audit report.

DISCLOSURE OF OCCUPATION/NAME OF EMPLOYER -
2 U.S.C 434(b)(3)(A) and (13)(A). The audit revealed that a material number of contributions
had not been disclosed as required. The Audit staff reviewed amended Schedules A (itemized
receipts) filed subsequent to notification of the audit and concluded that RFC had disclosed
additional contributor information to matenally correct the public record.

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TABLE OF CONTENTS

RUNBECK FOR CONGRESS
PAGE
Executive Summary 1
Final Audit Report 3
Background 3
Finding 4
Transmittal to Committee 5

Chronology 9


REPORT OF THE AUDIT DIVISION
ON

RUNBECK FOR CONGRESS

Approved November 9, 2001

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