THE

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TABLE OF CONTENTS

THE MARY LANDRIEU FOR SENATE COMMITTEE.. INC.

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0 Executive Summary 7

• Audit Report 3

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2 Background 3

5 Findings S

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2 Transmittal to Committee 15 If

3 Chronology 16 5
FEDERAL ELECTION COMMISSION

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FINA~L AUDIT REPORT

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THE MARY LANDRIEU FOR SENATE COMMITrEE. INC.

EXECUTIVE SUMMAR\'

The Committee registered with the Secretary ofthe Senate on April 18~ J996.. as

the principal campaign committee for Mary L. Landrieu., Democratic candidate for the

U.S. Senate from the state ofLouisiana. Mrs. Landrieu filed a Statement ofCandidacy for

the 1996 election on April 1, 1996.

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 lhe

threshold level ofcompliance set by the Commission.

The findings ofthe audit were presented to the C,ommittee at an exit conference

held at the end of audit fieldwork and later in an interim audit repon. The Committee's

responses have been included in the findings set fonh in this summary.

The following is an overview ofthe findings contained in the final audit report.

MISSTATEMENT OF FINANCIAL AcrlVl1Y - 2 U.S.C. §434(b)( 1)~(2) and

(4). The Comminee-s reponed receipts were understated by 532,866 and its reponed

dIsbursements were understated by 5226..950. The reported ending cash on hand at

December 31, 1996 was overstated by 54..884, resulting from the misstatements and an

error in the beginning cash on the t996 Year End Repon. The correct ending cash on hand

was ($3,971). The Committee responded by filing amended repons~ which materially

corrected these misstatements.

ApPARENT EXCESSIVE CONTRIBUTIONS - INDIVIDUALS -2 U.S.C.

§44 18(8)(1)(A). Contributions from 62 individuals were identified that exceeded the

contribution limitation by $41,015. In addition, four registered political action committees

and one unregistered organization exceeded the contribution limitations by a total of

512,,000. In response to the interim audit repon, the Committee demonstrated that one

$250 contribution was not excessive. The remaining excessive contributions are reponed

as deb15 ofthe Committee.

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48 HOUR NOTICES - INDIVIDUAL AND POLmCAL COMMI1TEES - 2

U.S.C. §434(a)(6). The Committee did not file the required 48 hour notice for 34

contributions. totaling $43.500. In addition. the Committee filed inaccurate 48 hour

notices for contributions, totaling $22.000. Except for one PAC.. these notices either

disclosed the wrong name ofthe contributor or contained the \Wong amount. The

Committee stated the errors were inadvenent and the result ofinadequate controls.

DISCLOSURE OF CONTRIBUTIONS FROM INDIVIDUALS -:! IT.S.C.

§434(b)(3)(A). The occupation and/or name of employer was not disclosed for a

material number ofthe contributions. As recommended in the interim audit repon. the

Committee either filed Schedules A disclosing the information or where the information

could not be obtained.. provided copies ofletters sent to contributors attempting to gather

the necessary information. The amended Schedules A and the letters demonstrate

untimely. but material compliance \\ith the regulatory requirements.

"DISCLOSURE OF CONTRIBUTIONS FROM POLITICAL COMMITTEES - 2

U.S.C. §434(b)(3)(B). Contributions in the amount of565200 were not properly

disclosed on the Committee's repons. The errors included contributions itemized under

the \\Tong name, contributions itemized with missing or incorrect addresses, and

contributions entries with incorrect aggregate year-to-date ·totals. In response to the

interim audit repon. the Committee filed amended disclosure repons which materially

corrected the disclosure problems.

DISCLOSURE OF DISBURSEMENTS-- 2 U.S.C. §434(b)(5)(A). A number

the dIsbursement entnes on the Committee·s disclosure repons were inaccurate or

incomplete. The errors involved inadequate or omitted purposes.. incomplete.. wrong. or

omItted addresses and wrong amounts. The Committee filed amended Schedules B which

corrected several ofthe errors. In addition.. the Committee described its efTons to obtain

the miSSIng information. The amended schedules and other efTons ofthe Committee to

locate the missing information, although untimely. bnng it into material compliance with

the regulatory requirements.

DEBTS AND OBLICATIQNS---:! U.S.C. §434(b)(8) and 11 CFR

§I04.11 (a) and (b) Committee obligations totaling S8:!.836 were not disclosed on its

repons. Ofthis amount. $28,568 should have been included on the Committee's Year

End 1996 repon which did not include debt schedule. The Committee filed amended

Schedules D, correcting the errors.

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FEDERAL ELECTION COMMISSION

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REPORT OF THE AUDITDIVISION

ON

THE MARY LANDRJEU FOR SENATE COMM/1TEE. INC.

BACKGROIJND

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A. AUDIT AU11IORITI'

This repon is based on an audit ofThe Mary Landrieu For SenaTe

Committee.. Inc. (the Committee), undenaken by the Audit Division ofthe Federal

Election Commission in accordance with the provisions ofthe Federal Election

Campaign Act of 1971 .. as amended (the Act). The audit was conducted pursuant to

Section 438(b) ofTitle 2 ofthe United States Code which states., in part.. that the

Commission may conduct audits and field investigations ofany political committee

required to file a repon under Section 434 ofthis title. Prior to conducting any audit

under this subsection, the Commission shall perform an internal review ofrepons filed

by selected committees to detennine ifthe repo~ filed by a panicular committee meet

the threshold requirements for substantial compliance with the Act.

B. AUDIT COVERAGE

The audit covered the period from March 28., ]996 through December 31.,

1996. The Committee reponed a beginning cash balance ofSO: total receipts for the

period of$2,857,984: total disbursements for the period of52..667,872: and an ending

cash balance of$913. I

c. CAMPAIGN ORGANIZATION

The Committee registered with the Secretary ofthe Senate on April 18,

1996.. as the principal campaign commIttee for Mary L. Landrieu, Democratic candidate

for the U.S. Senate from the state oflouiSIana. Mrs. Landneu filed a Statement of

Candidacy for the 1996 election on April 1, 1996.

The totaJs do not foot because the Comnuttee did not carry the encbng cash baJance ofthe Post

General repon 10 the beginnang cash balance ofthe Year End repon Csee Finding II A) All

amourns in this repon have been rounded to the nearest dollar

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The Treasurer ofthe Committee for the period is Thomas C. Delahaye.

To manage its finane.ial activity, the campaign maintained four checking

accounts. From these accounts the campaign made approximately 2.100 disbursements.

About 7,900 contributions. totaling S1..892.000'1 were received from individuals and

approximately 300 contributions" totaling 5546.000'1 were received from political

committees and other committees.

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D. AUDIT SCOPE AND PROCEDURES

The audit included testing ofthe following general categories:

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The receipt of contributions or loans in excess ofthe statutory

limitations (see Finding 11.8.);

the receipt ofcontributions from prohibited sources. such as those

from corporations or labor organizations;

proper disclosure of contributions from individuals. political

committees and other entities. to include the itemization of

contributions when required" as well as.. the completeness and

accuracy ofthe infonnation disclosed (see Findings II.C.. D.O. and

II.E. )~

4. proper disclosure ofdisbursements including the itemization of

disbursements when required, as wen as the completeness and

accuracy ofthe infonnation disclosed (see Finding I~.F.);

s. proper disclosure of campaign debts and obligations (see Finding

II.G. ):

6. the accuracy oftotal reponed receipts. disbursements and cash

balances as compared to campaign bank records (see Finding

IlA. ):

7. adequate recordkeeping for campaign uansactions: and

8. other audit procedures that were deemed necessary in the situation.

Unless specifically discussed below9 no material non-compliance was

detected. It should be noted that the Commission may pursue any ofthe matters

discussed in this report in an enforcement action.

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D. FINDINGS AND RECOMMENDAnONS

A. MISSTATEMENT OF FINANCIAL ACflVnY

Sections 434(b)(1). (2) and (4) ofTitle 2 ofthe United States Code state..

in that a political committee shall disclose the amount ofcash on hand at the

beginning ofthe reponing period and the total amount ofaJ Ireceipts and all

disbursements for the reponing period and the calendar year.

The Audit staff's reconciliation ofreponed financial activity to bank

records for the calendar year )996 revealed the following misstatements:

1. Receipts

.. The Committee~s reponed receipts were understated by $32..866.

The components ofthe misstatement are as follows:

Reponed Receipts $2..857.984

In-Kind Contributions Not Reponed 59..357 ..

Contributions Reponed Twice (3.000)

PAC Contributions Not Reponed 11.250

PAC Contributions Reponed Not (1.200)

Received

Individual Contributions Not Reponed 5..800

Loan Proceeds Not Reponed 7..392

Miscellaneous (1.637)

Reconciling Item $4,904 32,866

Correct Reponable Receipts 52.890.850

2. Disbursements

The Committee's reponed disbursements were understated

by 5226..950. The components ofthe mi551alement are as follows:

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Reported Disbursements 52..667.872

Disbursements Not Reponed $108,442

Bank Charges Not Reponed 60.975

Wire Transfers to Vendors Not 54,000

Reponed

<; Payroll Checks Not Reponed 8.762

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• In-Kind Contributions Not Reponed 19..506

" • 7 Disbursements Repo~ but (27,303)

• - No Payment Was Issued 0

2 Incorrect Disclosure Amounts (2.536) 5

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• Miscellaneous 1.472 r

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4- Reconciling Amount 53,632 226,950

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Correct Reponable Disbursements 51,894, 822

3. Ending Cash On Hand

The reponed ending cash on hand at ~ember 31. 1996

was overstated by $4.884. resulting from the misstatements detailed above and an error in

the beginning cash on the 1996 Year End Repon. The Committee accountant stated he

had to derive the beginning cash balance for the 1996 Year End Rcpon in order to

reconcile it to the December 31. 1996 correct ending cash on hand. The correct ending

cash on hand was(53.971).

At the exit conference. the Treasurer was provided schedules

detailing both the bank activity and the noted adjustments.

In the interim audit the Audit staffn:commended that the

Committee file a comprehensive amended report for the calendar year 1996 correcting

the misstatements noted above. The Committee complied with the staffs

recommendation.

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B. APPARENT EXCESSIVE CONTRIBlmONS

Section 441a(aXI)(A) ofTitle 2 ofthe United States Code states that no

person shall make contributions to any candidate and his authorized political committees

with respect to any election for Federal office which, in the aggregate, exceed S1..000.

Subsection (b)(2)(ii) of II CFR §IIO.1 explains that with respecllo election means

that jfthe contribution is not designated in writing by the contributor for a particular

election then the contribution applies to the next election for that Federal office after the

contribution is made (emphasis added). A contribution is considered to be made

(subsection (6) ofthis section) when the contributor relinquishes control over the

contribution by delivering the contribution to the candidate, the political committee.. or

an agent ofthe committee. A mailed contribution is considered made on the date ofthe

~ad. •

. Section 110.J(b)(S)(i) and (ii) ofTitle 11 ofthe Code ofFederal

Regulations states.. in relevant part.. that the treasurer ofan authorized political committee

may request a written redesignation ofa contribution by the contributor for a different

election if:

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the contribution was designated in writing for a particular election and the

contribution.. either on its face or when aggrepted with other

contributions from the same contributor for the same election.. exceeds the

limitation on contributions set fonh in 11 CFR §110.1(b)(1)~

the conbibution was designated in writing for a particular election and the

contribution was made after that election and the contribution cannot be

accepted under the net debts outstanding provisions of 11 CFR

§l JO.I(b)(3):

the contribution was not designated in writing for a particular election~

and the contribution exceedsthe limitation on contributions set fonh in 11

CFR §110. t(b)( l,~ or

the contribution was not designated in writing for a panicular election..

and the contribution was received after the date ofan election for which

there are net debts outstanding on the date the contribution is received.

Further, a contribution shall be considered to be redesignated for another

election jfthe treasurer ofthe recipient authorized political committee requests that the

contributor provide • written redesignation ofthe contribution and infonns the

contributor that the contributor may request the refund ofthe contribution as an

alternative 10 providins a written redesignation and within sixty days from the date ofthe

treasurer·s receipt oftile contribution.. the contributor provides the treasurer with a

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....._...__.e--.._" _........ ..... IUUUV.. AVI CUIUlIn;;. 1C1~IOn.. WDleD IS SlgneO oy tfte

contributor.

Section IIO.l(k) ofTitle 11 ofthe Code ofFede~1 Regulations states., any

contribution made by more than one person.. except for a conuibution made by a

partnerShip, shall include the signature of eaCh contributor on the chec~ money order.. or

other negotiable instrument or in a separate writing. Furthermore.. a contribution made

by more than one person that does not indicate the amoWlt to be attributed to each

contributor.. the contribution shall be attributed equally to each contributor.

Ifa contribution to a candidate.. either on its face or when aggregated with

other contributions from the same contributor.. exceeds the limitations on contributions

set forth in 11 CFR §110.1(b) or (d).. as appropriate. the treasurer may ask the contributor

whether the contribution was intended to be a joint contribution by more than ene person.

A contribution shall be considered to be reattributed to another contributor ifthe

treasurer ofthe recipient political committee asks the contributor whether the

contribution is intended to be a joint contribution by more than one person.. and infonns

the contributorthat he or she may request the return ofthe excessive ponion ofthe

contribution ifit is not intended to be a joint contributio~ and within sixty days from the

date ofthe treasurer"s receipt ofthe contribution, the contributors provide the treasurer

with a written reanribution ofthe contribution.. which is signed by each contributor.. and

which indicates the amount to be attributed to each contributor ifequal attribution is not

intendelt

Section 441a(a)(2 )(A) ofTitle 2 ofthe United States Code states, that no

multicandidate political committee shall make contributions to any candidate and his

authorized political committees with respect to any election for Federal office which, in

the aggregate. exceed 55.000.

Section 110.9(a) ofTitle 11 ofthe Code ofFederal Regulations states that

no candidate or political comminee shall accept any contribution or make any

expenditure in violation ofthe provisions of pan 110. No officer or employee of a

political committee shaH accept a contribution made for the benefit or use ofa candidate..

or make any expenditure on behalfof a candidate. in violation ofany limitation imposed

on contributions and expenditures under this pan 110.

The Audit stafTreviewed the Committee's receipts data file, available

check copies. deposit tickets.. and disclosure repons relating to contributions from

individuals and identified contributions from 62 individuals.. which exceeded the

contribution limitation by $41..015. Ofthis amount. 515..140, from 26 individuals.. was

excessive for the General Election; the balance (S25,87S) was excessive for the Primary

Election. In 45 instances.. the Comminee apparently reattributed or redesignated

contributions without lldequate documentation.

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In addition.. four registered political action committees and one

unregistered organization exceeded the contribution limitations by a total of512..ooo. Of

this amount, 511..000, from two PACs and one unregistered committee.. was excessive for

the General Election; the balance (51000).. from two PACs, wa~ excessive for the

Primary.

A schedule ofthe excessive conttibutions was presented to the Treasurer

at the exit conference. The Committee s accountant stated he would contact the

"contributors to obtain redesigDationslreattribution letters. The Committee was informed

that these reattributiowredesignation letters would be untimely and that refunds ofthe

contributions would be recommended.

In the interim audit repon, the Committee was requested to demonstrate

that the contributions noted above were not in excess ofthe contribution IimitVion.

Absent such evidence, the Committee was to refund the remaining excessive

contributions'and provide evidence ofsuch funds. Ifsufficient funds were not available,

those contributions requiring refunds would be disclosed as debts on Schedule D (Debts

and Obligations) until such time as funds became available.

In response to the interim audit repo~ the Committee demonstrated that

one contribution, totaling 5250, was not excessive.:! The remaining excessive

contributions. totaling $40.765, were itemized on Schedule D (Debts and Obligations).

In addition to itemizing the excessive contributors as debts, the

Committee stated that:

[the] Committee in no way purposely attempted to evade campaign

contribution limits. Rather. we maintain and the record suppons that the

excessive contributions... were the simple result ofbookkeeping errors.

To support this conclusion.. we note that the excessive contributions

identified by the audit total 552..765 amounting to 2% oftotal

contributions received by the Committee.

C. CONTRIBurlONS SUBJECf TO 48 HOUR DISCLOSURE NarlCES

Section 434(8)(6) ofTitle 2 ofthe United States Code requires that each

treasurer ofthe princi'" campaign committee ofa candidate shall notify the Clerk.. the

Secretary.. or the Commission.. and the Secretary ofState. as appropriate. in writing.. of

any contribution ofS1,000 or more received by any authorized committee ofsuch

candidate after the 20th day.. but more than 48 hours before. any election. This

This contribution chedc wu made out to lhe ReElect Committee (for the 2002 election). bur was

inadYenently deposited in this Committee'sbenk account. On December 23. 1997. the Committee

trasferred fUnds 10 the ReElect Committee to compensate for the check being deposiled in the wrons

account

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notification shall be made within 48 hours after the receipt ofsuch contribution and shall

include the name ofthe candidate and the office sought by the candidate9 the

identification ofthe contributor9 and the date ofreceipt and the amount ofthe

contribution. The notification required under this paragraph s"'l1 be in addition to all

other reponing requirements under this Act.

The Audit staffreviewed all contributions received by the Committee

within two and twenty days ofthe Primary Election (September 29 1996 to September 18..

1996) and the General Election (October 17., 1996 to November 2.. 1996) to identify all

contributions of51.,000 or more. The Audit staffdetennined the Committee did not file

the required 48 hour notice for 34 contributions., totaling 543.,500.

In addition, the Comminee failed to correctly file 48 hour notices for

contributions totaling 522.,000 received from both individuals and PACs. Exc~ for one

PAC., these notices either disclosed the wrong name ofthe contributor or contained the

wrong amount.

At the exit conference9 the Committee was provided with a schedule of

these items. No explanation was provided by the Comminee.

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In the interim audit repon., the Audit staffrecommended the Comminee

submit evidence that all required 48 notices were filed or submit any wrine-.n comments it

believes relevant to this issue.

In its response the committee conceded it had failed to file the notices

noted above. The Committee stated in relevant pan:

[the] errors were inadvertent and the result ofinadequate internal controls

which so often plagued harried campaigns.

The error noted by the audit disclosed that the Committee failed to include

in the 48 hour repons 43 contributions. totaling $64.000. In light oftotaJ

campaign contributions of52..541.114. we respectfully submit that the 48

hour reponing lapse while regrettable.. are not material.

D. DISCLOSURE OF CONTRIBlTflONS FROM INDIVIDUALS

Section 434(bX3)(A) ofTitle 2 ofthe United States Code requires. in pan9

a political committee to repon the identification of each person who makes a

contribution to the committee in an aggregate amount or value in excess of$200 per

calendar year together with the date and amount ofany such contribution.

Section 431(13)(A) ofTitle 2 ofthe United Slates Code defines the tenn

"identification" to be. in the case ofany individual, the name, the mailing address, and

the occupation ofsuch individual.. as well as the name ofhis or her employer.

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Sections 104.7(a) and (b) ofTitle 11 ofthe Code ofFederal Regulations

states, in part, that when the treasurer ofa political committee shows that best efTons

have been used to obtain" maintain., and submit the infannation required by the Act for

the political committee, any report ofsuch colmmittee shall be considered in compliance

with the Act. With regard to reporting the identification of each person whose

contributions(s) to the political committee and its affiliated committees aggregate in

excess ofS200 in a calendar year., the treasurer wi)) only be deemed to have exercised

best effons to obtain, maintain and repan the required information if: (1) All written

solicitations for contributions include a clear request for the contributor"s full name..

mailing address., occupation and name of employer" and include the following statement:

uFederal law requires political committees to report the name., mailing address"

occupation and name of employer for each individual whose contributions aggregate in

excess of$200 in a calendar year~'" and (2) For each contribution received agg(.egating in

excess of5200 per calendar year which lacks required contributor infonnation, the

treasurer makes at least one effort afterthe receipt ofthe contribution to obtain the

missing information. Such effort shall consist ofeither a written request sent to the

contributor or an ora) request to the contributor documented in writing. The written or

oral request must be made no later than thiny (30) days after receipt ofthe 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.

The Audit staffreviewed contributions from individuals on a sample basis

and detennined that the occupation and/or name of employer was not disclosed as

required for a material number ofthe contributions requiring itemization and disclosure

on the Committee's reports. Some ofthe infonnation was available in the·Committee"s

records, but was not disclosed. A sample form requesting this information was sent to

the Commission in response to an inquiry from the Reports Analysis Division~ however"

the Committee could not produce evidence that they used the form. Committee records

contained very little evidence of attempts to obtain occupation or name of employer after

receipt ofthe contribution.

At the exit conference" the Audit staffinfonned the Committee ofthe

problem and advised them to document all future attempts to obtain any required

information. The Treasurer concurred with our recommendation and agreed to fiIe any

necessary amended repons. The Committee"s accountant stated that efforts were being

made to obtain the missing infonnation.

In the interim audit report, the Audit staffrecommended that the

Committee file amended Schedules A to disclose the necessary occupation and name of

employer information or provide evidence ofcontacts with contributors to obtain the

missing infonnation.

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In response to the interim audit report. the Committee filed Schedules A

disclosing the information that was either in Committee's records or bad been obtained

in n..-sponse to the audit. Where the infonnation could not be obtajne~ the Committee

submitted copies ofletters sent to contributors attempting to gather the necessary

information. The amended Schedules A and the letters requesting occupation and name

ofemployer information demonstrate untimely, but material compliance with the

regulatory requirements.

E. REPORTING OF REcEIPTS FROM POLmCAL COMMI1TEES

Sections 434(b)(2)(D) and (b)(3)(B) ofTitle 2 ofthe United States Code

state that each report under this section shall disclose for the reponing period and

calendar year the total amount ofaU contributions from other political committees and

the identification ofeach political committee which makes a contribution to reponing

committee during the reponing peri~ together with the date and amount ofany such

contribution. -

The Audit staffreviewed receipts~ totaling SS44.772. from political

committees and unregistered organizations. From this review. contributions in the

amount of $6S,2OO were identified that were not properly disclosed on the Committee;s

repons. Included were contributions itemized under the wrong name. and contributions

itemized with missing or incorrect addresses, or inconect aggregate year-to-date totals.

A schedule ofthe disclosure errors was presented to the Treasurer at the

exit conference. The Committee did not comment.

In the interim audit repan the Audit staffrecommended the-Committee

file amended Schedules A disclosing the required infonnation. The Committee filed the

requested schedules which materially corrected the errors and omissions.

F. DISCLOSURE OF DISBURSEMENTS

Section 434(b)(S)(A} ofTitle 2 ofthe United States Codes states. in pan..

that each repon under this section shall disclose the name and address ofeach person to

whom an expenditure in an aggregate amount or value in excess of5200 within the

calendar year is made by the reponing committee to meet a candidate operating expense.

together with the date. amount. and purpose ofsuch operating expenditure.

Section 104.7(a) ofTitle 11 ofthe Code ofFedcraI ResuJation states,

when the treasurer ofa political committee shows that best efforts have been used to

obtain, maintain and submit the infonnation required by the Act for the political

committee, any repon ofsuch committee shall be considered in compliance with the Act.

Section 104.3(b)(3)(i)(A) and (B) ofTitle II ofthe Code ofFederal

Regulation states. in part. that purpose means a briefstatement or description of why the

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disbursement was made. Examples ofstatements or descriptions which meet the

requirements include the following: dinner expenses, media, salary, pollin& travel, pany

fees, phone banks. travel expense reimbursement.. and catering costs. However..

statements or descriptions such as advance, election day expen~s. other expenses..

expenses.. expense reimbursement.. miscellaneous.. outside services, get-out-the-vote.. and

voter registtation would not meet the requirements of 11 CFR 104.3(b)(3) for the

reponing purpose of an expenditure.

The Committee"s disbursements itemized on Schedules B were tested to

detennine if all required information had been included and to evaluate the accuracy of

the information. The test established that the Schedules were deficient. The errors

involved inadequate or omitted purposes: incomplete, wrong. or omitted addresses: and..

wrong amounts.

• At the exit conference, the Committee was informed ofthese errors.. but

offered no comment.

In the interim audit repon, the Audit staffrecommended that the

Comminee file amended Schedules B. disclosing the required infonnation. ..

In the response to the interim audit repon, the Committee filed amended

Schedules B which corrected severa) ofthe error~ noted above. In addition.. the

Committee described its efforts to obtain the missinWinadequate information. These

effons consisted oflooking in the telephone book and on the Internet. The amended

schedules and other efTons ofthe Committee to locate the missing infonnation. although

untimely.. bring it into material compliance with the regulatory requirements.

G. DEBTS AND OBLIGATIONS

Section 434(b)(8) ofTitle 2 ofthe United States Code. states.. in pan.. that

each repon filed under this section shall disclose the amount and nature ofoutstanding

debts and obligations owed by a political comminee.

Sections 104.11(8) and (b) ofTitle 11 ofthe Code of Federal Regulations

state.. in pan.. that debts and obligations owed by or to a political committee which

remain outstanding shall be continuously reponed until extinguished. These debts and

obligations shall be reponed on separate schedules together with a statement explaining

the circumstances and conditions under which each debt and obligation was incurred or

extinguished. A debt or obligation, the amount of which is SSOO or less.. shall be reponed

as ofthe time payment is made or not later than 60 days after such obligation is incurred,

whichever comes first. A debt or obligation which is over SSOO shall be reponed as of

the date on which the debt or obligation is incurred, except that any obligation incurred

for rent. salary.. or other regularly reoccurring administrative expense shall not be

reponed as a debt before the payment due date.

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The Audit stafTreviewed disbursements to detennine ifthe Committee

comedy reponed debts and obligations owed to vendors. The review identified

obligations totaling 582,836 (July 1S Quanerly through Year-end. onlyl.. which the

Committee did not disclose. Ofthis amoun~ 528,568 should have been included on the

Committee'5 YearEnd Repon which did not include a Schedule D (Debts and

Obligations). .

The Committee also reponed incotTeCt beginning balances.. amounts

incurred, payments made and ending balances for a number ofobligations beginning with

the July 15 Quanerly Repon through the Post General Report. Debts and obligations

with reponed ending balances of587.552 were incorrectly reponed.

At the exit conference the Committee was provided with schedules

detailing the issues discussed above. but offered no comment. •

In the interim audit repo~ the stafTrecommended that the Committee file

amended Schedules D for the July IS Quanerly Repon through the YearEnd Repon to

correctly disclose outstanding obligations.

In response to this recommendation. the Committee filed amended

Schedules D.. correcting all disclosure errors for tile noted vendors.

Page 14
FEDERAL ELECTION COMMISSION

WASHINCTO". 0 C 204b.~

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August 24, 1998

Mr. Thomas Delahaye~ Treasurer

The Mary Landrieu For Senate Committee.. Inc.

58156 Coun Street

Plaquemine.. LA 70764

.. Dear Mr. Delahaye:

Attached please find the Repon ofthe Audit Division on The Mary Landrieu For

Senate Committee, Inc.. The Commission approved the repon on August 21. 1998.

The Commission approved Final Audit Repon will be placed on the public recQrd

on August 31 .. 1998. Should you have any questions regarding the public release ofthe

repon, please contact the Commission's Press Office at (202) 694-1220. Any questions

you have related to maners covered during the audit or :n the repon should be directed to

Erica D Holder or Russ Bruner ofthe Audit Division at (202) 694-1200 or toll free at (800)

424-9530.

Sincerely, .,,; , . / , ;, __., / I

~"-" 1'./

-/l -- - ;-<,'"'-

Roben!Costa

Assistant Staff Director

Audit Division

Attachment as stated

Page 15
CHRONOLOGY

THE MARY LANDRIEU FOR SENATE COMMITTEE.. INC.

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Audit Fieldwork

Interim Audit Report to

the Committee

Response Received to the

Exit Conference Memorandum

Audit Repon Approved.

Page 16

08/04/97-10122/97

04/06/98

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