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• ALEX1/061S88

FEDERAL ELECTION COMMISSION

Vl-ASItINGTON 0 C 204b)

A87-28

June 15, 1988

MEMORANDUM

TO:

FROM:

SUBJECT:

FRED EILAND

CHIEF, PRESS OFFICE

ROBERT J. COSTA

ASSISTANT STAFF DIRE~~~ AUDIT DIVISION

PUBLIC ISSUANCE OF THE FINAL AUDIT REPORT

ON ST. LOUISIANS FOR BETTER GOVERNMENT

,. Attached please find a copy of the Final Audit Report on

St. Louisians for Better Government which was approved by the

Commission on June 7, 1988.

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

FEC Library
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ALEX1/060788

FEDERAL ELECTION COMMISSION

WASHINCTON, DC 204&3 A87-28

~PORT OF THE AUDIT DIVISION

ON

ST. LOUISIANS FOR BETTER GOVERNMENT

I. Background

A. Overview

This report is based on an audit of St. Louisians for

Better Government (Wthe CommitteeW), undertaken by the Audit

Division of the Federal Blection Commission in accordanc~ 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 ~ct·). The audit was conducted in

accordance with Section 438(b) of Title 2 of the United States

Code which permits the Commission to conduct audits 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 the reports filed by a

particular committee meet the threshold requirements for

substantial compliance with the Act.

The Committee registered with the Federal Election

Commission on December 23, 1981, and maintains its headquarters in St. Louis, Missouri.

The audit covered the period January 1, 1985 through December 31, 1986. The Committee reported a cash balance on

January 1, 1985 of $4,755.497 total receipts for the period of $143,943.4l~ total disbursements for the period of $149,846.04

and a closing cash balance of $(1,147.14) on December 31, 1986.

This report is based on documents and workpapers

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.

B. Key Personnel

The Treasurer of the Committee during the period covered by the audit was Mr. Eugene Weissman. The current

Treasurer is Mrs. Bunny Goldwasser.
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C. Scope

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The audit included such tests as verification of total

reported receipts and disbursements and individual transactions,

review of required supporting documentation and such other audit

procedures as deemed necessary under the circumstances. Since

the Committee's contribution records consisted for the most part of internally generated documents, the auditors were precluded from performing any substantive testing relative to contributions

received from individuals.

II. Audit Findings and Recommendations

A. Misstatement of Financial Activity

The Act, at 2 U.S.C. S5 434(b)(1), and (4), requires that each report shall disclose tho amount of cash on hand at the

beginning of the reporting period~ nnd the total amount of all

disbursements for the reporting p~riod and the calendar year.

On the 1986 Year-end report and the 1986 30 day Postgeneral report, negative ending cash-on-hand balances were

reported by the Committee of $(1,159.86) and $(1,147.14),

respectively. The Audit staff performed a reconciliation of

activity per Committee bank accounts to reports filed for the

period January 1, 1986 through December 31, 1986, and found that

the reported disbursements were overstated by $3,500 and ending

cash-on-hand was understated by a like amount. It was noted that

checks representing two reported contributions to candidate

committees, totaling $3,500 disbursed on October 9, 1986 had not

been cashed. The Treasurer determined at some point that these

checks would not be cashed and issued replacement checks. The

replacement checks were reported, as required, however, negative entries were not included in the Committee's report to account

for the original checks. Therefore, the negative cash-on-hand

balances discussed above were the result of reporting errors and

not an indication of undisclosed liabilities.

It should be noted that the Committee's 1987 Mid-Year

Report disclosed the voiding of the original checks, thereby correcting the reported cash-on-hand baJance. At the exit

conference, the Committee Treasurer agreed that the way the

matter had been handled was inappropriate and indicated it would

be handled correctly in the future for similar situations.

Recommendation II

Since the discrepancies noted above have been corrected, no

further action is recommended.
As am~ndments were filed by the Committee, the Audit staff • recommends no further action on this matter.

The Act, at 2 U.S.C. 5 434(b)(3) requires disclosure of

the identification of each per&on who makes a contribution during the reporting period, whose contribution or contributions have an

aggregate amount or value in excess of $200 within the calendar

year.

At the exit conference, the Committee supplied the

Audit staff with copies of amended schedules, properly disclosing the deficient items, that were subsequently filed with the

Commission on September 14, 1987.

Recommendation 12

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Omission of Disclosure Information (Occupation) for Contributions From Individuals

B.

The Audit staff's review of the 1985 Mid-year and Yearend reports revealed that the occupation was omitted for 60 of 67

contributors. Reports filed relative to 1986 activity contained

the identification of all contributors as required.

During the entrance conference, the Audit staff

discussed this matter with the Treasurer. It was ascertained

that requests for this information from the contributor were made

verbally and no evidence exists to document whether or not best

efforts had been made to obtain the missing information. During this conference, and subsequent discussions, the Audit staff

explained what was required of the Treasurer to resolve this

matter.

Identification is defined at 2 U.S.C. 5 431(13) (A) to

include, in the case of any individual, the occupation of such

individual, as well as the name of his or her employer.

The Regulations, at 11 C.F.R. 5 104.7, state, in

relevant 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 the Act for the political committee, any report of such committee shall be considered in

compliance with the Act. with regard to reporting the

identification of each person, the treasurer will not be deemed r to have exercised best efforts to obtain the required information

unless he or she has made at least one effort per solicitation ~. either by a written request or by an oral request documented in

writing to obtain such information from the contributor.

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C.

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Failure to Itemize Other Receipts (Interest)

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Section 434(b)(3) (G) of Title 2 of the United States

Code states that each report under this section shall disclose

the identification of each person who provides any dividend,

interest, or other receipt to the reporting committee in an

aggregate value or amount in excess of $200 within the calendar

year, together with the date and amount of any such receipt. In

addition, 2 U.S.C. S 431(13) defines identification to include

the full name and address of such person.

The Audit staff's review of interest received by the

Committee indicated that of the 22 receipts, totaling $5,275.34,

required to be itemized, none were.

The Treasurer was provided with a schedule of these

items. Amendments were filed on October 16, 1987 disclosing

these receipts.

Recommendation 13

As amendments were filed by the Committee, the Audit staff

recommends no further action.

D. Matter Referred to the Office of General Counsel

A certain matter was referred to the Commission's

Office of General Counsel •
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