MEMORANDUM

TO:

FROM:

SUBJECT:

fEDERAL ELECTION COMMISSION

WASHINCTON 0 C ~n4f)J

August 19, 1991

FRED EILAND

CHIEF, PRESS OFFICE

~~r ~~~~~iA~T ~~~~~ DIREtTO~ AUDIT DIVISION

PUBLIC ISSUANCE OF THE FINAL AUDIT

REPORT ON CURRY FOR CONGRESS

MJ000202

Attached please find a copy of the Final Audit Report on

Curry for Congress, which was approved by the Commission on August - --13-; --1991. ___ __

Informational copies of the report have been received by all

parties involved and the report may be released to the public.

Attachment as stated

cc: Office of General Counsel

Office of Public Disclosure

Reports Analysis Division

FEe Library
MJ000141

fEDERAL ELECTION COMMISSION

\\'ASHtNC TON 0 C Z04bl

REPORT OF THE AUDIT DIVISION

CURRY FOR CONGRESS

I. Background

A. Overview

This report is based on an audit of Curry for

Congress (the Committee), undertaken by the Audit Division of

the Federal Election 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 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 -file-d by selected cOllUlitt-e-es----to

determine if the reports filed by a particular comaittee meet

the threshold requirements for substantial compliance with the

Act.

The Committee registered with the u.s. House of

Representatives on Kay 19, 1988 as the principal caapaign

committee of Jerry R. Curry, Republican candidate for the u.s.

House of Representatives from the state of Virginia. The

Committee maintains its headquarters in Virginia Beach,

Virginia ..

The audit covered the period from the Committee's

inception through December 31, 1988, the closing date for the

latest report filed at the time of the audit. The Committee

reported a beginning cash balance of $0; total receipts for the

period of $194,005.66; total disbursements for the period of

$189,394.74; and a closing cash balance on December 31, 1988 of $4,726.92.~/

This report is based on documents and workpapcrs

which support each of its factual statements. They form part

of the record upon which the Commission based its decisions on

the matters in the report and were available to the

Commissioners and appropriate staff for review.

:1 The reported totals do not foot due to mathematical errors.
2

B. Key Personnel

The Treasurer of the Committee during the period

covered by the audit was Mr. Vincent G. Thomas.

c. Scope

The audit included such tests as verification of

total reported receipts and disbursements and individual

transactions; review of required supporting documentation;

analysis of Committee debts and obligations; and such other

audit procedures as deemed necessary under the circumstances.
3

II. Audit Findings and Recommendations

A. Misstatements of Financial Activity

Sections 434(b}(1), (2) and (4) of Title 2 of the

United states Code require a committee to report the amount of

cash on hand at the be9inning of each reporting period and the

total amount of all receipts and disbursements for the

reportin9 period and calendar year.

The Audit staff's reconciliation of the Committee'.

reported activity to its bank activity revealed the following

misstatements:

1. Receipts

The Committee's reported receipts were

understated by a net amount of $351.77. The components of the

misstatement are as follows:

1988 Reported Receipts

Unreported In-Kind Contributions

from political Committees

Contributions from Candidate

reported twice

Internal transfer included in

total of unitemized contributions

(200.00)

(4,750.00)

$194,005.66

Total of itemized contributions fro.

Political Committees not included

in report total 5,890.00

Uniteaized contributions overstated (4,700.00)

unexplained difference

Correct reportable receipts

(210.64) 351.77

$194,357.43
2 ..

4

Disburseaents

The Committee's reported disbursements were

understated by a net amount of $841.82. The components of the

misstatement are as follows:

1988 Reported Disbursements $189,394.74

Unreported In-Kind Contributions

from Political Committees $4,322.41

unreported disbursements 1,010.18

Addition error on Schedule B 1,199.84

Reported disbursements not made (1,334.06)

Duplicate reporting of disbursements (39.99)

Unitemized disbursements overstated

Correct reportable disbursements

(4,317 .. 16) 841.82

$190.236.56

C"' 3 .. Ending Balance

The reported ending balance at December 31, 1988

was overstated by a net amount of $606.05, resulting fro. the

misstatements detailed above and an addition error on the

reported totals of $116.00. The correct ending balance was

$4,120.87.

Copies of schedules detailing the differences

were prOVided to the Committee at the exit conference. The

Committee official stated that she would file the appropriate

amendment to correct the misstatement.

In the interim audit report, the Audit staff

recommended that the Committee file a comprehensive amendment

for calendar year 1988 correcting reported receipts,

disbursements and cash on hand. In response to the interim

audit report, the Candidate filed such an amendment.

Recommendation II

The Audit staff recommends no further action on this

matter.
5

B. Itemization of Contributions/Disbursements

Section 434(b)(3)(B) of Title 2 of the United states

Code states that each report under this section shall disclose

the identification of each political committee which makes a

contribution during the reporting period together with the date

and amount of any such contribution.

under 11 C.P.R. S100.7(a)(1), the term "contribution"

includes a gift, loan, advance, deposit of money or anything of

value made by any person for the purpose of influencing any

election for Federal office. For purposes of 11 C.F.R.

SlOO.7(a)(1}, the term "anything of value" includes all in-kind

contributions.

In addition to the unreported in-kind contributions

totaling $4,322.41 noted in Finding II.A., the Committee failed

to itemize 13 contributions received from political committees

totaling $5,075.66.

The Committee was provided with schedules of the

contributions requiring itemization at the exit conference.

In the interim audit report the Audit staff

recommended that the Committee include in the comprehensive

-----allendmen-t -requ-ested in -Reco11lmendation t1 j--an--ame-nded---Schedule A-

(Iteaized Receipts), itemiZing the $5,075.66 in contributions

fro. political committees ~s well as Schedule A and Schedule B

(Iteaized Disbursements) reporting the $4,322.41 in in-kind

contributions.

The comprehensive amendment filed by the Candidate in

response to the interia report included amended Schedules A and

B which itemized correctly the contributions noted above.

Recommendation 12

The Audit staff recommends no further action on this

matter.

C. Other Matters

Other matters noted during the audit have been

referred to the Commission's Office of General Counsel.