Final Audit Report of the 

Commission on Hillary Clinton 

for President 

January 1, 2007 - December 31, 2008 

Why the Audit 

Was Done 

Federal law permits the 

Commission to conduct 

audits and field 

investigations of any 

political committee that is 

required to file reports 

under the Federal 

Election Campaign Act 

(the Act). The 

Commission generally 

conducts such audits 

when a committee 

appears not to have met 

the threshold 

requirements for 

substantial compliance 

with the Act.^ The audit 

determines whether the 

committee complied with 

the limitations, 

prohibitions and 

disclosure requirements 

of the Act. 

Future Action 

The Commission may 

initiate an enforcement 

action, at a later time, 

with respect to the matter 

discussed in this report. 

About the Campaign (p. 2) 

Hillary Clinton for President (HCFP) is the principal campaign 

committee for Hillary Clinton, candidate for the Democratic 

Party's nomination for the office of President of the United 

States. HCFP is headquartered in Washington, D.C. For more 

information, see the chart on the Campaign Organization, p.2. 

Financial Activity (p. 2) 

• Receipts 

o Contributions from Individuals 

o Other Political Committees 

o From Affiliated Committees 

o Candidate Loans 

o Offsets to Expenditures & 

Other Receipts 

Total Receipts 

• Disbursements 

o Operating Expenditures 

o Transfers to Affiliates 

o Contribution Refunds 

o Other Disbursements 

Total Disbursements 

$ 217,686,817 

1,610,538 

10,000,000 

13,750,000 

9,678,788 

$ 252,726,143 

$ 223,080,262 

6,466,215 

21,935,595 

75,403 

$251,557,475 

Commission Finding (p. 3) 

• Receipt of Contributions that Exceed Limits 

2 US.C. §438(b). 
Final Audit Report of the 

Commission on 

Hillary Clinton for President 

January 1, 2007 - December 31, 2008 
Table of Contents 

Page 

Part I. Background 

Authority for Audit 1 

Scope of Audit 1 

Audit Hearing 1 

Part II. Overview of Campaign 

Campaign Organization 2 

Overview of Financial Activity 2 

Part III. Summary 

Commission Finding 3 

Part IV. Commission Finding 

Receipt of Contributions that Exceed Limits 4 
Parti 

Background 

Authority for Audit 

This report is based on an audit of Hillary Clinton for President, undertaken by the Audit 

Division of the Federal Election Commission (the Commission) in accordance with the 

Federal Election Campaign Act of 1971, as amended (the Act). The Audit Division 

conducted the audit pursuant to 2 U.S.C. §438(b), which permits the Commission to 

conduct audits and field investigations of any political committee that is required to file a 

report under 2 U.S.C. §434. Prior to conducting any audit under this subsection, the 

Commission must perform an intemal 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. 2 U.S.C. §438(b). 

Scope of Audit 

Following Commission-approved procedures, the Audit staff evaluated various risk 

factors and as a result, this audit examined: 

1. The receipt of excessive contributions and loans. 

2. The receipt of contributions from prohibited sources. 

3. The disclosure of contributions received. 

4. The disclosure of debts and obligations. 

5. The consistency between reported figures and bank records. 

6. The completeness of records. 

7. Other committee operations necessary to the review. 

Audit Hearing 

HCFP declined the opportunity for a hearing before the Commission on the matter 

presented in this report. 
Part II 

Overview of Campaign 

Campaign Organization 

Important Dates 

• Date of Registration January 22,2007 

• Audit Coverage January 1,2007 - December 31,2008 

Headquarters Washington, D.C. 

Bank Information 

• Bank Depositories Two 

• Bank Accounts Eight 

Treasurer 

• Treasurer When Audit Was Conducted Shelly S. Moskwa 

• Treasurer During Period Covered by Audit Shelly S. Moskwa 

Management Information 

• Attended FEC Campaign Finance Seminar Yes 

• Who Handled Accounting and 

Recordkeeping Tasks Paid Staff 

Overview of Financial Activity 

(Audited Amounts) 

Cash on hand @ January 1,2007 $0 

o Contributions from Individuals 217,686,817 

o Other Political Committees 1.610.538 

o From Affiliated Committees 10.000.000 

0 Candidate Loans 13.750.000 

o Offsets to Expenditures & Other Receipts 9.678.788 

Total Receipts $252,726,143 

o Operating Expenditures 223.080.262 

o Transfers to Affiliates 6.466.215 

o Contribution Refunds 21.935.595 

o Other Disbursements 75.403 

Total Disbursements $251,557,475 

Cash on hand @ December 31,2008 $ 1,168,668 
Part III 

Summary 

Commission Finding 

Receipt of Contributions that Exceed Limits 

The Audit staffs review of contributions from other political committees indicated that 

HCFP failed to timely resolve excessive contributions totaling $21,400. The 

contributions were either designated to the general election by the contributing committee 

or presumptively redesignated by HCFP. 

HCFP provided documentation indicating the contributions have been refunded. In 

response to the Interim Audit Report recommendation, HCFP's legal counsel noted that 

the amount was a small part of the total receipts and explained that the excessive 

contributions were due to three minor database errors inadvertently overlooked by HCFP. 

When the contributions were brought to HCFP's attention, it took appropriate steps to 

retum the funds. 

The Commission approved this finding. (For more detail, see p. 4) 
Part rv 

Commission Finding 

Receipt of Contributions that Exceed Limits 

Summary 

The Audit staffs review of contributions from other political committees indicated that 

HCFP failed to timely resolve excessive contributions totaling $21,400. The 

contributions were either designated to the general election by the contributing committee 

or presumptively redesignated by HCFP. 

HCFP provided documentation indicating the contributions have been refimded. In 

response to the Interim Audit Report recommendation, HCFP's legal counsel noted that 

the amount was a small part of the total receipts and explained that the excessive 

contributions were due to three minor database errors inadvertently overlooked by HCFP. 

When the contributions were brought to HCFP's attention, it took appropriate steps to 

retum the fimds. 

The Commission approved this finding. 

Legal standard 

A. Authorized Committee Limits. An authorized committee may not receive more 

than a total of $2,300 per election from any one person or $5,000 per election from a 

multicandidate political conunittee. 2 U.S.C. §441a(a)(l)(A), (a)(2)(A), and (f); 11 CFR 

§§110.1(a) and (b), 110.2(b), and 110.9. 

B. Handling Contributions That Appear Excessive. If a committee receives a 

contribution that appears to be excessive, the committee must either: 

• Retum the questionable check to the donor; or 

• Deposit the check into its federal account and: 

o Keep enough money in the account to cover all potential refimds; 

o Keep a written record explaining why the contribution may be illegal; 

o Include this explanation on Schedule A if the contribution has to be 

itemized before its legality is established; 

o Seek a reattribution or a redesignation of the excessive portion, following 

the instructions provided in the Commission regulations; and 

o If the committee does not receive a proper reattribution or redesignation 

within 60 days after receiving the excessive contribution, refund the 

excessive portion to the donor. 11 CFR §§103.3(b)(3), (4) and (5) and 

110.10c)(3)(ii)(B). 

C. General Election Contributions. If a candidate is not a candidate in the general 

election, any contributions made for the general election shall be refunded to the 

contributors or redesignated in accordance with 11 CFR §§ 110.1(b)(5) or 110.2(b)(5), as 

appropriate. 11 CFR § 102.9(e)(3). 
Facts and Analysis 

A. Facts 

A review of contributions from other political committees revealed HCFP received 

excessive contributions from 10 political conunittees totaling $21,400, which were 

unresolved. The contributions were either designated to the general election by the 

contributing committee or presumptively redesignated to the general election by HCFP. 

Since the Candidate did not run in the general election, these contributions were required 

to be refimded. HCFP maintained sufficient fimds to make die necessary refimds. 

B. Interim Audit Report & Audit Division Recommendation 

The Audit staff discussed this matter at the exit conference and provided HCFP 

representatives with a schedule of the apparent excessive contributions. In response to 

the exit conference, HCFP submitted copies of refund checks totaling $21,400. The 

refimd checks have been negotiated and were traced to the appropriate bank account. 

The Audit staff reconunended that HCFP provide any comments it deemed necessary 

with respect to this matter. 

C. Committee Response to Interim Audit Report 

HCFP's legal counsel noted that the amount was a small part of total receipts and 

explained that excessive contributions were due to three minor database errors that were 

overlooked inadvertendy. Counsel noted that the contributions were refimded when 

brought to HCFP's attention. 

D. Draft Final Audit Report 

The Draft Final Audit Report acknowledged HCFP's efforts in resolving this matter. 

Comndssion Conclusion 

The Commission approved this finding.