Final Audit Report of the 

Commission on Jill Stein for 

President 

(October 11, 2011 - August 31, 2014) 

Why the Audit Was 

Done 

Federal law requires the 

Gommission to audit 

every political committee 

established by a* 

candidate who receives 

public iiinds for the 

primary campaign.' The 

audit determines whether 

the candidate was entitled 

to all of the matching 

funds received, whether 

the campaign used the 

matching funds in 

accordance with the law, 

whether the candidate is 

entitled to additional 

matching funds, and 

whether the campaign 

otherwise cornplied with 

the imitations, 

prohibitions, and 

disclosure requirements 

of the election law. 

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 Campaign (p. 3) 

Jill Stein for President is the principal campaign committee for Jill 

Stein, a candidate for the Green Party nomination for the office of 

President of the United States. The Conimittee is headquartered in 

Lexington, Massachusetts. For more information, see the chart on 

the Campaign Organization, p. 3. 

Financial Activity^ (p. 4) 

• Receipts 

o Contributions from Individuals 

o Matching Funds Received 

o Loans Received from the Candidate 

o Contributions from Political Parties 

o Offsets to Operating Expenditures 

$ 815,851 

372,130 

64,000' 

4,235 

3,368 

Total Receipts $ 1,259,584 

• Disbursements 

o Operating Expenditures $ 1,070,033 

o Fundraising Disbursements 26,803 

o Loan Repayments 20,000 

o Contribution Refunds 1,170 

Total Disbursements $ 1,118,006 

Commission Findings (p. 5) 

• Net Outstanding Campaign Obligations (Finding 1) 

• Misstatement of Financial Activity (Finding 2) 

• Disclosure of Debts and Obligations (Finding 3) 

• Reporting of Receipts (Finding 4) 

• Reporting of Expenditures (Finding 5) 

• Itemization of Candidate Loans (Finding 6) 

26 U.S.C. §9038(a). 

These figures contain both primary and generai activity. The generai activity accounts for approximateiy 

$367,994, or 45% of totai receipts, and $269,888, or 24% of totai disbursements. See Committee Structure on 

p. 1. 

The Candidate made loans as follows: $44,000 for primary election activity and $20,000 for generai election 

activity. Therefore, the Candidate did not exceed the $50,000 limitation on expenditures for the primary 

election from the Candidate's funds. 26 U.S.C. §9035(a): 11 CFR §9035.2. 
Final Audit Report of the 

Commission on Jill Stein for 

President 

(October 11, 2011 - August 31, 2014) 
Table of Contents 

Page 

Parti. Background 

Authority for Audit 1 

Scope of Audit -1 

Inventory of Campaign Records 1 

Committee Structure I 

Audit Hearing 2 

Part II. Overview of Campaign 

Campaign Organization 3 

Overview of Financial Activity 4 

Part in. Summaries 

Commission Findings S 

Part IV. Commission Findings 

Finding 1. Net Outstanding Campaign Obligations 8 

Finding 2. Misstatement of Financial Activity ll 

Findings. Disclosure ofDebts and Obligations 14 

Finding 4. Reporting of Receipts 16 

Finding s. Reporting of Expenditures 18 

Finding 6. Itemization of Candidate Loans 20 
Parti 

Background 

Authority for Audit 

This report is based on an audit of Jill Stein for President (JSFP), undertaken by the Audit 

Division of the Federal Election Commission (the Commission) as mandated by Section 

9038(a) of Title 26 of the United States Code. That section states, "After each matching 

payment period, the Commission shall conduct a thorough examination and audit of the 

qualified campaign expenses of every candidate and his authorized committees who 

received [matching] payments under section 9037." Also, Section 9039(b) of the United 

States Code and Section 9038.1(a)(2) of the Commission's Regulations state that the 

Commission may conduct other examinations and audits from time to time as it deems 

necessary. 

Scope of Audit 

This audit examined: 

1. the campaign's compliance with limitations for contributions and loans; 

2. the campaign's compliance with the limitations for candidate contributions and loans; 

3. the campaign's compliance with the prohibition on accepting prohibited contributions; 

4. the disclosure of contributions and loans received; 

5. the disclosure of disbursements, debts and obligations; 

6. the consistency between reported figures and bank records; 

7. the accuracy of the Statement of Net Outstanding Campaign Obligations; 

8. the campaign's compliance with spending limits; 

9. the completeness of records; and 

10. other campaign operations necessary to the review. 

Inventory of Campaign Records 

The Audit staff routinely conducts an inventory of campaign records before it begins 

audit fieldwork. JSFP's records were materially complete and fieldwork commenced 

thereafter. 

Committee Structure 

JSFP was the only campaign committee authorized by Jill Stein (the Candidate) for the 

2012 Presidential election and conducted both primary and general election activity for 

the Candidate. JSFP opened four bank accounts: three primary accounts and a general 

account. In practice, JSFP deposited nearly all contributions received before the 

Candidate's nomination into Ae primary accounts, and most contributions received after 

the nomination into the primary accounts, unless otherwise designated and deposited into 

the general account. JSFP received matching funds for its primary campaign and this 
audit cpvered JSFP's primary election activity to determine if expenses were qualified 

campaign expenses defrayed in connection with the primary election.^ 

Audit Hearing 

JSFP declined the opportunity for a hearing before the Commission on the matters 

presented in this report. 

Under Title 26, this audit includes an examination of JSFP's Statement of Net Outstanding Campaign 

Obligations (Finding 1) based solely on JSFP's primary election activity for the purpose of determining 

the extent to which the Candidate is entitled to primary matching funds. This audit also covers an 

examination of JSFP's reporting under Title S2 which includes general election activity. For 

clarificatiori, the Audit staff has indicated in Finding 2 - Misstatement of Financial Activitv and Finding 

6 - Itemization of Candidate Loans those transactions related to general election activity. 
Part II 

Overview of Campaign 

Campaign Organization 

Important Dates 

• Date of Registration November 14,2011 

• Eligibility Period® August 22,2012 - September 6,2012 

• Audit Coverage® October 11,2011 - August 31,2014 

Headquarters Lexington, Massachusetts 

Bank Information 

• Bank Depositories Two 

• Bank Accounts Three primary accounts and one general account 

Treasurer 

• Treasurer When Audit Was Conducted James Moran 

• Treasurer During Period Covered by Audit James Moran: October 23,2012 - Present 

John Andrews: July 6,2012 - October 22,2012 

John Portelli: November 14,2011 - July 5,2012 

Management Information 

• Attended Commission Campaign Finance 

Seminar 

No 

• Who Handled Accounting and 

Recordkeeping Tasks 

Paid Staff 

On July 9,2012, the Candidate submitted a signed letter to the Commission, which was amended on July 12, 

2012, seeking to become eligible to receive Presidential primary matching iiinds and agreeing that she and her 

authorized committee would comply with the conditions set forth in 11 CFR §9033.1(b). A threshold submission 

was submitted on July 16,2012, and the Commission certified the Candidate as eligible to receive matching funds 

on August 22,2012. The period during which the Candidate was eligible for matching funds ended on September 

6,2012, the date of ineligibility. 

The Audit staff conducted limited reviews of receipts and expenditures after December 31,2012, to determine 

whether the Candidate was eligible to receive additional matching funds. 
Overview of Financial Activity 

(Audited Amounts)'' 

Cash-on-hand @ October 11,2011 SO 

Receipts 

o Contributions from Individuals" 815,851 

o Matching Funds Received' 372,130 

6 Loans. Received from the Candidate 64,000'" 

o Contributions from Political Parties 4,235 

o Offsets to Operating Expenditures 3,368 

Total Receipts $ 1,259,584 

Disbursements 

o Operating Expenditures 1,070,033 

o Fundraising Disbursements 26,803 

o Loan Repayments 20,000 

o Contribution Refunds 1,170 

Total Disbursements $ 1,118,006 

Cash-on-hand @ December 31,2012 S 141,578 

^ These figures contain both primary and general activity. See Committee Structure on p. 1. 

' JSFP received approximately 8,400 contributions from approximately 6,000 individuals. 

' As of the Candidate's date of ineligibility, September 6,2012, JSFP had received matching funds totaling 

S100,000. JSFP received an additional S272,130 by December 3,2012, for a total of $372,130. 

See Footnote 3. 
Part III 

Summaries 

Commission Findings 

Finding 1. Net Outstanding Campaign Obligations 

The Audit staffs review of JSFP's financial activity through August 31,2014, and 

estimated winding down costs indicated that the Candidate did not receive matching fund 

payments in excess of her entitlement. 

In its response to the Preliminary Audit Report recommendation, JSFP provided no 

further comment. 

The Commission approved a finding that the Candidate did not receive matching funds in 

excess of her entitlement. (For more detail, see p. 8.) 

Finding 2. Misstatement of Financial Activity 

During audit fieldwork, a comparison of JSFP's reported financial activity with its bank 

records revealed that, for 2012, JSFP understated its reported receipts and ending cashon-hand by $211,949, and $106,128, respectively; and overstated disbursements by 

$13,850. Amendments filed subsequent to the audit notification letter did not materially 

correct the identified misstatements. However, JSFP filed amended reports subsequent to 

audit fieldwork to materially correct the misstatements. 

In response to the Preliminary Audit Report recommendation, JSFP stated that, due to 

complications caused by its initial bookkeeper, initial filings lacked certain records and 

duplicated various expenditures. Further, JSFP stated that, during fieldwork, it was able 

to identify shortcomings related to this finding and made necessary corrections with the 

assistance of the Audit staff. As noted above, JSFP filed amended reports subsequent to 

audit fieldwork to materially correct the misstatements. 

The Commission approved a finding that JSFP misstated its financial activity for calendar 

year 2012. (For more detail, see p. 11.) 

Finding 3. Disclosure of Debts and Obligations 

During audit fieldwork, the Audit staff identified debts totaling $78,043 not disclosed on 

Schedule D-P (Debts and Obligations) as required. Amendments filed subsequent to the 

audit notification letter disclosed some of these debts. JSFP filed amended reports to 

materially disclose these debts and obligations. 

In response to the Preliminary Audit Report recommendation, a JSFP representative 

stated that, during the course of audit fieldwork JSFP was able to identify various debts 

and obligations that were previously unreported due to mistakes made by the initial 
bookkeeper. JSFP filed amended reports subsequent to audit fieldwork which materially 

corrected the disclosure of these debts and obligations. 

The Commission approved a finding that JSFP did not disclose debts and obligations 

totaling. $78,043. (For more detail, see p. 14.) 

Finding 4. Reporting of Receipts 

During audit .fieldwork, the Audit staffs review identified contributions fixim individuals 

totaling $23,071 that JSFP failed to itemize. In addition, receipts totaling $57,622 were not 

adequately disclosed. For most of these contributions, the election cycle-to-date total 

disclosed on Schedules A-P (Itemized Receipts) was incorrect. Amended reports filed 

subsequent to the audit notification letter materially corrected both the itemization and 

disclosure errors. 

In response to the Preliminary Audit Report recommendation, JSFP stated it discovered 

"unspecified" issues with import fimctions where donor information would not be 

recognized as a potential duplicate, causing various donor aggregates to be inaccurate in 

final reports. These issues have been corrected with the amended reports previously 

filed. 

The Conunission approved a finding that JSFP did not itemize contributions from 

individuals totaling $23,071, and did not adequately disclose receipts totaling $57,622. 

(For more detail, see p. 16.) 

Finding 5. Reporting of Expenditures 

During audit fieldwork, the Audit staff identified expenditures totaling $49,797 that JSFP 

failed to itemize as required. In addition, expenditures totaling $314,673 were not 

adequately disclosed. For most of these expenditures, the purpose was not disclosed or 

was inadequately disclosed. Amended reports filed subsequent to the audit notification 

letter materially corrected both the itemization and disclosure errors. 

In response to the Preliminary Audit Report recommendation, JSFP indicated that, after 

receiving clarification from Ae Audit Division and Reports Analysis Division staff, it was 

able to identify all expenditures lacking proper itemization or inadequate descriptions. 

JSFP filed amended reports which corrected these errors. 

The Commission approved a finding that JSFP did not itemize expenditures totaling 

$49,797, and did not ^equately disclose expenditures totaling $314,673. (For more 

detail, seep. 18.) 

Finding 6. Itemization of Candidate Loans 

The Audit staff identified loans from the Candidate totaling $40,000 that had not been 

reported correctly by JSFP. Amended reports filed subsequent to the audit notification 

letter materially corrected the reporting of these loans. 
In response to the Preliminary Audit Report recommendation, JSFP indicated that all 

issues with the itemization of candidate loans have been corrected. 

The Commission approved a finding that JSFP did not correctly report loans from the 

Candidate totaling $40,000. (For more detail, see p. 20.) 
Part IV 

Commission Findings 

Finding 1. Net Outstanding Campaign Obligations 

Summary 

The Audit staffs review of JSFP's financial activity through August 31,2014, and 

estimated winding down costs indicated that the Candidate did not receive matching fimd 

payments in excess of her entitlement. 

In its response to the Preliminary Audit Report recommendation, JSFP provided no 

further comment. 

The Commission approved a finding that the Candidate did not receive matching fimds in 

excess of her entitlement. 

Legal Standard 

A. Net Outstanding Campaign Obligations (NOCO). Within IS days afier the 

candidate's date of ineligibility (see definition below), the candidate must submit a 

statement of "net outstanding campaign obligations." This statement must contain, 

among other things: 

• The total of all committee assets including cash-on-hand, amounts owed to the 

committee and capital assets listed at their fair market value; 

• The total of all outstanding obligations for qualified campaign expenses; and 

• An estimate of necessary winding-down costs. 11 CFR §9034.5(a). 

B. Date of Ineligibility. The date of ineligibility is whichever of the following dates 

occurs first: 

• The day on which the candidate ceases to be active in more than one state; 

• The 30th day following the second consecutive primary in which the candidate 

receives less than 10 percent of the popular vote; 

• The end of the matching payment period, which is generally the day when the 

party nominates its candidate for the general election; or 

• In the case of a candidate whose party does not make its selection at a national 

convention, the last day of the last national convention held by a rriajor party in 

the calendar year. 11 CFR §§9032.6 and 9033.5. . 

C. Qualified Campaign Expense. Each of the following expenses is a qualified 

campaign expense. 

• An expense that is: 

o Incurred by or on behalf of the candidate (or his or her campaign) during the 

period beginning on the day the individual becomes a candidate and 

continuing through the last day of the candidate's eligibility under 11 CFR 

§9033.5; 
o Made in connection with the candidate's campaign for nomination; and 

o Not incurred or paid in violation of any federal law or the law of the state 

where the expense was incurred or paid. 11 CFR §9032.9. 

• An expense incurred for the purpose of determining whether an individual should 

become a candidate, if that individual subsequently becomes a candidate, 

regardless of when that expense is paid. 11 CFR §9034.4. 

• An expense associated with winding down the campaign and terminating political 

activity. 11 CFR §9034.4(a)(3). 

D. Entitlement to Matching Payments after Date of Ineligibility. If, on the date of 

ineligibility (see above), a candidate has net outstanding campaign obligations as defined 

under 11 CFR §9034.5, that candidate may continue to receive matching payments 

provided that he or she istill has net outstanding campaign debts on the day when the 

matching payments we made. 11 CFR §9034.1(b). 

E. Winding Down Costs. A primary election candidate who does not run in the general 

election may receive and use matching funds after notifying the Commission in writing 

of the candidate's wnthdrawal fix)m the campaign for nomination or after the date of the 

party's nominating convention, if the candidate has not withdrawn before the convention. 

A primary election candidate who runs in the general election must wait until 31 days 

after the general election before using any matching funds for winding down costs, 

regardless of whether the candidate receives matching funds for the general election. 

11 CFR §9034.11(d). 

Facts and Analysis 

A. Facts 

The Candidate's date of ineligibility (DOI) was September 6,2012. The Audit staff 

reviewed JSFP's financial activity through August 31,2014, analyzed estimated wnnding 

down costs and prepared the Statement of Net Outstanding Campaign Obligations that 

appears on the next page. 
10 

Jill Stein for President 

Statement of Net Outstanding Campaign Obligations 

As of September 6,2012 

Prepared August 31,2G14|a] 

Cash in Bank 

Accounts Receivable 

Total Assets 

$ 57,302 

31,443 

$ 88,745 

Liabilities 

Accounts Payable for Qualified Campaign Expenses at 9/6/12 

Loans Payable to Candidate 

Winding Down Costs: 

Actual Winding Down.Costs Paid (12/7/12 - 8/31/14) 

Estimated Winding Down Costs (9/1/14 - 3/31/15) 

Total Liabilities 

$ 307,500 

44,00b[b]" 

103,240 [c] 

55.900 rdi 

Net Outstanding Campaign Obligations (Deflcit) as of September 6,2012 

510,640 

iS^421.895^ 

[a] The latest report filed by JSFP covered activity through August 31,2014. 

[b] Loans payable at DOl. 

[c] The General election was November 6,2012. The winding down period begins 31 days after the 

' General election on December 7,2012. 

[d] Estimated winding down costs will be compared to actual winding down costs and adjusted 

accordingly. 

Shown below are adjustments for funds received after the Candidate's DOI on September 

6,2012 through December 3,2012, the date JSFP received its last matching fund 

payment, 

Net Outstanding Campaign Obligations (Deficit) as of 

September 6,2012 

($421,895) 

Less: Contributions Received (September 7,2012 through 

December 3,2012) 

98,753 

Less: Matching Funds Received September 7,2012 through 

December 3,2012 

272,130 

Remaining Net Outstanding Campaign Obligations 

(Deficit) as of December 3,2012 

$(51,012) 

As presented above, JSFP has not received matching fund payments in excess of the 

amount to which the Candidate was entitled. 

" This total represents all loans payable at DOI. Loan repayments of S20,000 each were paid to the 

Candidate on September 11,2012, and March 20,2013, totaling $40,000. The outstanding balance due 

on the loan is $4,000. 
11 

The Audit st^ presented a preliminary NOCO statement and related work papers to the 

JSFP representatives at the exit conference. After the exit conference, the representatives 

provided additional documentation as requested to update the NOCO statement. 

B. Preliminary Audit Report Recommendation 

The Preliminary Audit Report recommended that JSFP demonstrate any adjustments it 

believed were required in connection with any part of the NOCO statement or provide 

any other additional comments. 

C. Committee Response to Preliminary Audit Report 

In its response to the Preliminary Audit Report recoirunendation, JSFP provided no 

ftirther comment. 

D. Draft Final Audit Report 

The Draft Final Audit Report acknowledged that the Candidate had not received 

matching ftmd payments in excess of entitlement. 

E. Committee Response to Draft Final Audit Report 

In response to the Draft Final Audit Report recommendation, JSFP provided no further 

comment. 

Commission Conclusion 

On October 9,2015, the Commission considered the Audit Division Recommendation 

Memorandum in which the Audit staff recommended the Commission adopt a finding 

that the Candidate did not receive matching fund payments in excess of her entitlement. 

The Commission approved the Audit staffs recommendation. 

Finding 2. Misstatement of Financial Activity 

Summary 

During audit fieldwork, a comparison of JSFP's reported financial activity with its bank 

records revealed that, for 2012 j JSFP understated its reported receipts and ending cashon-hand by $211,949, and $106,128, respectively; and overstated disbursements by 

$13,850. Ameiidments filed subsequent to the audit notification letter did not materially 

correct the identified misstatements. However, JSFP filed amended reports subsequent to 

audit fieldwork to materially correct the misstatements. 

In response to the Preliminary Audit Report recommendation, JSFP stated that, due to 

complications caused by its initial bookkeeper, initial filings lacked certain records and 

duplicated various expenditures. Further, JSFP stated that, during fieldwork, it was able 

to identify shortcomings related to this finding and made necessary corrections with the 

assistance of the Audit staff. As noted above, JSFP filed amended reports subsequent to 

audit fieldwork to materially correct the misstatements. 
12 

The Commission approved a finding that JSFP misstated its financial activity for calendar 

year 2012. 

Legal Standard 

Contents of 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 election cycle; 

• the total amount of disbursements for the reporting period and for the election 

cycle; and 

• certain transactions that require itemization on Schedule A-P (Itemized Receipts) or. 

Schedule B-P (Itemized Disbursements). 52 U.S.C. § 30104 0>)(1). (2), 3), (4) and 

(5). 

Facts and Analysis 

A. Facts 

The Audit staff reconciled JSFP's reported financial activity with its bank records and 

determined that there was a misstatement of beginning and ending cash-on-hand, receipts 

and-disbursements. The following chart outlines the discrepancies and succeeding 

paragraphs explain, to the extent possible, the reasons for the misstatements. 

2012 Activity" 

Reported Bank Records Discrepancy 

Beginning Cash-on-hand 

Balance @ January 1,2012 

$19,000 $19,328 $328 

Understated 

Receipts $1,018,273 $1,230,222 $211,949'^ 

Understated 

Disbursements $1,121,822 $1,107,972 $13,850"* 

Overstated 

Ending Cash-on-hand Balance 

^December 31,2012 

$35,450 $141,578 $106,128*' 

Understated 

The beginning cash-on-hand was overstated by $328 likely due to prior period 

discrepancies. 

The understatement of receipts resulted from the following: 

• Matching Funds not reported 

• Contributions from individuals not reported 

• In-kind contributions not reported 

$ 100,000 

89,647 

2,539 

12 This activity represents both general and primary election activity. See Footnote 7. 

General election activity represents S86,083, or 41% of the understated receipts totals. 

" General election .activity represents ($7,803), or 56% of the overstated disbursements totals. 

" JSFP's reported ending cash-on-hand balance does not calculate correctly due to a failure to carry 

forward the ending cash-on-hand balance of ($75,680) from its 2012 September Monthly report as the 

beginning cash-on-hand on its 20 i 2 October Monthly report. Absent this error, the con«ct ending cash 

balance as of December 31,2012 should have been ($84,549). 
13 

• Loans from the Candidate not reported 

• Offsets not reported 

• Receipts from political action committees not reported 

• Reported receipts not supported by a deposit/credit 

• Unidentified difference 

Net Understatement of Receipts 

The overstatement of disbursements resulted from the following: 

• Inter-account transfers reported as disbursements 

• Reported voided checks 

• Over-reported payroll disbursements 

• Double reporting of Candidate loan repayment 

• Disbursements reported not supported by a check/debit 

• Operating expenditures reported twice 

• Bank reversing entries reported as disbursements 

• Operating expenditures not reported 

• In-kinds not reported 

• Refund not reported and other reporting errors 

• Unidentified Difference 

Net Overstatement of Disbursements 

40,000 

1,509 

4,235 

(23,772) 

0209) 

$2U.949 

$(17,000) 

(3,765) 

(2,585) 

(20,000) 

(9,399) 

(23,108) 

(285) 

61,082 

2,539 

825 

(2,154) 

f$ 13.850^ 

The understatement of ending cash-on-hand in the amount of $106,128 resulted from the 

misstatements described above. 

B. Preliminary Audit Report Recommendation 

At the exit conference held at the end of audit fieldwork, the Audit staff explained the 

misstatements and subsequently provided JSFP representatives with schedules detailing 

these discrepancies. In response, the representatives agreed to amend JSFP's reports. 

The representatives offered no additional comments. Amendments filed subsequent to 

the audit notification letter had not materially corrected these identified misstatements. 

However, additional amended reports filed subsequent to the exit conference materially 

corrected these misstatements. 

The Preliminary Audit Report recommended that JSFP provide any additional 

information or written comments that it considered relevant to this matter. 

C. Committee Response to Preliminary Audit Report 

In response to the Preliminary Audit Report recommendation, JSFP stated that, due to 

complications caused by its initial bookkeeper, initial filings lacked certain records and 

duplicated various expenditures. Further, JSFP stated that, during fieldwork, it was able 

to identify shortcomings related to this finding and made necessary corrections with the 

assistance of the Audit staff. As noted above, JSFP filed amended reports subsequent to 

audit fieldwork to materially correct the misstatements. 

The unreported loans from the Candidate, totaling S40,000, were comprised of S20,000 loaned for the 

primary election and S20,000 loaned for the general election (see Finding 6). 
14 

D. Draft Final Audit Report 

The Draft Final Audit Report acknowledged that JSFP filed amendments to materially 

correct its financial activity for calendar year 2012. 

E. Committee Response to Draft Final Audit Report 

In response to the Draft Final Audit Report recommendation, JSFP provided no further 

comment. 

Commission Conclusion 

On October 9,2015, the Commission considered the Audit Division Recommendation 

Memorandum in which the Audit staff recommended the Commission adopt a finding 

that JSFP misstated its financial activity for calendar year 2012. 

The Commission approved the Audit staffs recommendation. 

Finding 3. Disclosure of Debts and Obligations 

Summary 

During audit fieldwork, the Audit staff identified debts totaling $78,043 not disclosed on 

Schedule D-P (Debts and Obligations), as required. Amendments filed subsequent to the 

audit notification letter disclosed some of these debts. JSFP filed amended reports to 

materially disclose these debts and obligations. 

In response to the Preliminary Audit Report recommendation, a JSFP representative 

stated that, during the course of audit fieldwork, JSFP was able to identify various debts 

and obligations that were previously unreported due to mistakes made by the initial 

bookkeeper. JSFP filed amended reports subsequent to audit fieldwork which materially 

corrected the disclosure of these debts and obligations. 

The Commission approved a finding that JSFP did not disclose debts and obligations 

totaling $78,043. 

Legal Standard 

A.. Continuous Reporting Required. An authorized committee must disclose the 

amount and nature of outstanding debts and obligations until those debts are 

extinguished. 52 U.S.C. §30104Cb)(8) and 11 CFR §§ 104.3(d) and 104.11(a). 

B. Separate Schedules. An authorized committee must file separate schedules for debts 

owed by and to the committee v^th a statement explaining the circumstances and 

conditions under which each debt and obligation was incurred or extinguished. 

11 CFR §104.11(a). 

C. Itemizing Debts and Obligations. 

• Once it has been outstanding 60 days from the date incurred, a debt of $500 or 

less must be reported on the next regularly scheduled report. 
15 

• A debt exceeding $500 must be disclosed in the report that covers the date on 

which the debt was incurred, except reoccurring administrative expenses (such as 

rent) shall not be reported as a debt before the payment due date. 

11 CFR §104.11(b): 

Facts and Analysis 

A. Facts 

During audit fieldwork, the Audit staff used available disbursement records to reconcile 

the accounts of JSFP's largest vendors. These vendors provided JSFP mainly with 

services for the primary election such as ballot access petitioning, legal services, printing, 

television advertising, and national party convention services. The Audit staff identified 

debts owed to these vendors totaling $78,043'^ that were not disclosed on Schedule D-P, 

as required. 

B. Preliminary Audit Report Recommendation 

The Audit staff presented Ais matter to JSFP representatives at the exit conference and 

provided schedules detailing the unreported debts for each reporting period. The 

representatives agreed to file amendments, but offered no additional comments during the 

exit conference. The Audit staff reviewed amended reports filed after the audit 

notification letter and concluded that debts totaling $4,501 have not yet been disclosed. 

The Preliminary Audit Report recommended that JSFP provide documentation 

demonstrating that the remaining $4,501 in expenditures did not require reporting on 

Schedule D-P. Absent such documentation, it was further recommended that JSFP 

amend its reports to disclose the remaining outstanding debts. 

C. Committee Response to Preliminary Audit Report 

In response to the Preliminary Audit Report recommendation, a JSFP representative 

stated that, during the course of audit fieldwork, JSFP was able to identify various debts 

and obligations that were previously unreported due to mistakes made by the initial 

bookkeeper. JSFP filed amended reports subsequent to audit fieldwork which materially 

corrected the disclosure of these debts and obligations. 

D. Draft Final Audit Report 

The Draft Final Audit Report acknowledged that JSFP filed amendments to materially 

correct its reporting of debts and obligations. 

E. Committee Response to Draft Final Audit Report 

In response to the Draft Final Audit Report recommendation, JSFP provided no further 

comment. 

" Each debt amount was counted once, even if it required disclosure over multiple reporting periods. 
16 

Commission Conclusion 

On October 9,2015, the Commission considered the Audit Division Reconunendation 

Memorandum in which the Audit staff recommended the Commission adopt a finding 

that that JSFP did not disclose debts and obligations totaling $78,043. 

The Commission approved the Audit staffs recommendation. 

I Finding 4. Reporting of Receipts 

Summary 

During audit fieldwork, the Audit staffs review identified contributions from individuals 

totaling $23,071 that JSFP failed to itemize. In addition, receipts totaling $57,622 were not 

adequately disclosed. For most of these contributions, the election cycle-to-date total 

disclosed on Schedules A-P (Itemized Receipts) was incorrect. Amended reports filed 

subsequent to the audit notification letter materially corrected both the itemization and 

disclosure errors. 

In response to the Preliminary Audit Report recommendation, JSFP stated it discovered 

"unspecified" issues with import functions where donor information would not be 

recognized as a potential duplicate, causing various donor aggregates to be inaccurate in 

final reports. These issues have been corrected with the amended reports previously 

filed. 

The Commission approved a finding that JSFP did not itemize contributions fixim 

individuals totaling $23,071, and did not adequately disclose receipts totaling $57,622. 

Legal Standard 

A. Itemization Required for Contributions from Individuals. An authorized 

committee must itemize any contribution from an individual if it exceeds $200 per 

election cycle, either by itself or when combined with other contributions from the same 

contributor. 52 U.S.C§30104(b)(3)(A). 

B. Election Cycle. The election cycle begins on the first day following the date of the 

previous general election and ends on the date of the next general election. If 

contributions and expenditures are designated for another election cycle, then the election 

cycle begins when the first contribution is received or expenditure is made. 11 CFR 

§1.00.3(b). 

C. 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 mailing address; 

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

• The date of receipt (the date the committee received the contribution); 
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• The amount of the contribution; and 

• The election cycle-to-date total of all contributions from the same individual. 11 

CFR §§100.12 and 104.3(a)(4) and 52 U.S.C§30104(b)(3)(A). 

Facts and Analysis 

A. Facts 

During audit fieldwork, the Audit staff reviewed all contributions from individuals whose 

contributions aggregated in excess of $200. These reviews identified the following: 

1. Contributions Not Itemized - There were 268 contributions from individuals 

totaling $23,071" that JSFP failed to itemize on Schedule A-P (Itemized 

Receipts), as required. 

2. Contributions Not Adeauatelv Disclosed - There were 250 contributions 

from individuals totaling $57,622, for which the election cycle-to-date 

amounts and/or contributor names were either incorrectly disclosed or 

missing. 

These itemization and disclosure errors resulted mainly from: 

• Multiple contributor identification numbers were created in JSFP's database for 

the same individual mainly resulting from incorrect data entry of contributor 

information. For example, the first and/or last name had been entered incorrectly 

for contributions that were apparently from the same individual; 

• The Audit staffs reconciliation of the receipts database provided by JSFP resulted 

in the determination that approximately 1,780'^ receipts had been omitted from 

the database. JSFP representatives could not explain why these receipts had been 

omitted. Although most of these omitted items did not require itemization, the 

omission of these items result in the aggregate election-to-date amounts on 

Schedules A-P for other contributions from the same individuals to be incorrect. 

B. Preliminary Audit Report Recommendation 

At the exit conference held at the end of audit fieldwork, the Audit staff explained the 

errors and subsequently provided JSFP representatives with schedules detailing these 

discrepancies. In response, the representatives agreed to amend JSFP's reports. The 

representatives offered no additional comments during the exit conference. 

Subsequent to the exit conference, the Audit staff reviewed amended reports filed after 

the audit notification letter and concluded that the amendments materially corrected both 

the itemization and disclosure errors noted above. 

" Of this amount, $6,272 is included in Finding 2, Misstatement of Financial Activity, as part of the 

receipts adjustment of S89,M7 for contributions firom individuals not reported. 

" These items are included in the adjustments for receipts presented at Finding 2, j Financial Activity. 
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The Preliminary Audit Repprt recommended that JSFP provide any additional 

information or written comments that it considered relevant to this matter. 

C. Committee Response to Preliminary Audit Report 

In response to the Preliminary Audit Report recommendation, JSFP stated it discovered 

"unspecified" issues with its FECFile import functions where donor information was not 

recognized as a potential duplicate, causing various donor aggregates to be inaccurately 

reported. JSFP filed amended reports which corrected these errors. 

D. Draft Final Audit Report 

The Draft Final Audit Report acknowledged that JSFP did not itemize contributions from 

Individuals totaling $23,071, and did not adequately disclose receipts totaling $57,622. 

E. Committee Response to Draft Final Audit Report 

In response to the Draft Final Audit Report recommendation, JSFP provided no further 

comment. 

Commission Conclusion 

On October 9,2015, the Commission considered the Audit Division Recorrunendation 

Memorandum in which the Audit staff recommended the Commission adopt a finding 

that JSFP did not itemize contributions from individuals totaling $23,071, and did not 

adequately disclose receipts totaling $57,622. 

The Commission approved the Audit staffs recommendation. 

Finding 5. Reporting of Expenditures 

Summary 

During audit fieldwork, the Audit staff identified expenditures totaling $49,797 that JSFP 

failed to itemize as required. In addition, expenditures for the primary election totaling 

$314,673 were not adequately disclosed. For most of these expenditures, the purpose 

was not disclosed or was inadequately disclosed. Amended reports filed subsequent to 

the audit notification letter materially corrected both the itemization and disclosure errors. 

In response to the Preliminary Audit Report recommendation, JSFP indicated that, after 

receiving clarification fi-om the Audit Division and Reports Analysis Division staff, it was 

able to identify all expenditures lacking proper itemization or inadequate descriptions. 

JSFP filed aiiiended reports which corrected these errors. 

The Commissiqn approved a finding that JSFP did not itemize expenditures totaling 

$49,797, and did not adequately disclose expenditures totaling $314,673. 

Legal Standard 

A. Reporting Operating Expenditures. When operating expenditures to the same 

person exceed $200 in an election cycle, the committee must report the: 

• Amount; 
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• Date when the expenditures were made; 

• Name and address of the payee; and 

• Purpose (a brief description of why the disbursement was made—see below). 

52 U.S.C§30104(b)(5)(A) and 11 CFR §104.3(b)(4)(i). 

B. Examples of Purpose. 

• Adequate Descriptions. Examples of adequate descriptions of "purpose" include 

the following: dinner expenses, media, salary, polling, travel, party fees; phone 

banks, travel expenses, travel expense reimbursement, catering costs, loan 

repayment, or contribution refund. 11 CFR § 104.3(b)(4)(i)(A). 

• Inadequate Descriptions. The following descriptions do not meet the requirement 

for reporting "purpose": advance, election day expenses, other expenses, expense 

reimbursement, miscellaneous, outside services, get-out-the-vote, and voter 

registration. 11 CFR §104.3(b)(4)(i)(A). 

C. Election Cycle. The election cycle begins on the first day following the date of the 

previous general election and ends on the date of the next general election. If 

contributions and expenditures are designated for another election cycle, then the election 

cycle begins when the first contribution is received or expenditure is made. 11 CFR 

§100.3(b). 

Facts and Analysis 

A. Facts 

During audit fieldwork, the Audit staffs review of all itemizable operating expenditures 

for the primary election identified the following. 

1. Qperatine Expenditures Not Itemized - There were 67 expenditures totaling 

$49,797TM that JSFP failed to itemize on Schedule B-P (Itemized 

Disbursements). 

2. Qperatine Expenditures Not Adeauatelv Disclosed - JSFP did not adequately 

disclose 166 expenditures totaling $314,673 on Schedule B-P. The majority 

of the disclosure errors were caused by not disclosing a purpose or disclosing 

inadequate purposes, such as "consulting", "contract labor" and "professional 

fees", for operating expenditures. Other errors included incorrectly reporting 

payroll expenditures, ^ong with the failure to disclose memo entries relating 

to expenditures for reimbursements to individuals. 

B. Preliminary Audit Report Recommendation 

At the exit conference held at the end of audit fieldwork, the Audit staff explained the 

expenditure reporting errors and subsequently provided JSFP representatives with 

schedules detailing these discrepancies. In response, the JSFP representatives agreed to 

Of this amount, S4S,200 is included in Finding 2, Misstatement of Financial Activity, as part of the 

adjustments for disbursements not reported. 
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amend the reports. The representatives offered no additional comments during the exit 

conference. 

Subsequent to the exit conference, the Audit staff reviewed amended reports filed after 

the audit notification letter and concluded that the amendments materially corrected both 

the itemization and disclosure errors noted above. 

The Preliminary Audit Report recommended that JSFP provide any additional 

information or written comments that it considered relevant to this matter. 

C. Committee Response to Preliminary Audit Report 

In response to the Preliminary Audit Report recommendation, JSFP indicated that, after 

receiving clarification from the Audit staff, it was able to identify and correct all 

expenditures lacking proper itemization or inadequate descriptions with the amended 

reports previously filed. 

D. Draft Final Audit Report 

The Draft Final Audit Report acknowledged that JSFP did not itemize expenditures 

totaling $49,797, and did not adequately disclose expenditures totaling $314,673. 

E. Committee Response to Draft Final Audit Report 

In response to the Draft Final Audit Report reconunendation, JSFP provided no further 

comment. 

Commission Conclusion 

On October 9,2015, the Commission considered the Audit Division Recommendation 

Memorandum in which the Audit staff recommended the Commission adopt a finding 

that JSFP did not itemize expenditures totaling $49,797, and did not adequately disclose 

expenditures totaling $314,673. 

The Commission approved the Audit staffs recommendation. 

Finding 6. Itemization of Candidate Loans 

Summary 

The Audit staff identified loans from the Candidate totaling $40,000 that had not been 

reported correctly by JSFP. Amended reports filed subsequent to the audit notification 

letter materially corrected the reporting of these loaiu. 

In response to the Preliminary Audit Report recommendation, JSFP indicated that all 

issues with the itemization of candidate loans have been corrected. 

The Commission approved a finding that JSFP did not correctly report loans from the 

Candidate totaling $40,000. 
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Legal Standard 

A. Reporting Loans. All loans received by a committee must be itemized on Schedule 

A-P (Itemized Receipts) and continuously reported until repaid. All repayments made on 

a loan must also be itemized. 11 CFR §§104.3(a)(4)(iv), (b)(4)(iii) and §104.11. 

B. Schedule C-P. Both the. original loan and payments to reduce principal must be 

reported each reporting period until the loan is repaid. The committee must report the 

following: 

• The source of the loan; and 

• The type of loan the candidate received (i.e. bank loan, brokerage account, credit 

card, or home equity line of credit) either in the first box for endorsers and 

guarantors with a notation for loan type or in the box for "Loan Source" after the 

candidate's name. 11 CFR § 104.3(d) and § 104.11. 

C. Schedule C-1. When a candidate obtains a loan from an advance on the candidate's 

brokerage account, credit card, home equity line of credit or other line of credit for use in 

connection with the candidate's campaign, the candidate's principal campaign committee 

must disclose in the report, covering the period when the loan was obtained, the 

following information on Schedule C-1 or C-P-1: 

• The date, amount, and interest rate of the loan, advance, or line of credit; 

• The name and address of the lending institution; and 

• The type and value of collateral or other sources of repayment that secure the 

loan, advance, or line of credit, if any. 11 CFR § 104.3(d)(4). 

Facts and Analysis 

A. Facts 

The Audit staff identified loans from the Candidate totaling $40,000 that were not 

itemized correctly by JSFP. On June 22,2012, JSFP received loans from the Candidate 

for the primary election in the amounts of $14,000 and $6,000 that were disclosed 

correctly on Schedule C-P but not itemized on Schedule A-P. In addition, on September 

11,2012, the Candidate made a loan for the general election in the amount of $20,000 

which was not itemized on either Schedules A-P or C-P. 

It should be noted that the Audit staffs bank reconciliation for 2012 determined that the 

Candidate loans totaling $40,000 discussed here were also not included in reported 

activity totals on the Detailed Summary Page of their respective reports (see Finding 2). 

B. Preliminary Audit Report Recommendation 

At the exit conference, the Audit staff provided JSFP representatives with schedules 

detailing these discrepancies. In response, the representatives agreed to amend JSFP's 

reports. The representatives offered no addition^ comments during the exit conference. 

Subsequent to the exit conference, the Audit staff reviewed amended reports filed after 

the audit notification letter and concluded that the loans from the Candidate were 

properly itemized on these amendments. 
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The Preliminary Audit Report recommended that JSFP provide any additional 

information or written comments that it considered relevant to this matter. 

C. Committee Response to Preliminary Audit Report 

In response to the Preliminary Audit Report recommendation, JSFP indicated that all 

issues with the itemization of these Candidate loans have been corrected. 

D. Draft Final Audit Report 

The Draft Final Audit Report acknowledged that JSFP did not correctly report loans from 

the Candidate totaling $40,000. 

E. Committee Response to Draft Final Audit Report 

In response to the Draft Final Audit Report recommendation, JSFP provided no further 

comment. 

Commission Conclusion 

On October 9,2015, the Commission considered the Audit Division Recommendation 

Memorandum in which the Audit staff recommended the Commission adopt a finding 

that JSFP did not correctly report loans from the Candidate totaling $40,000. 

The Commission approved the Audit staffs recommendation.