FEDERAL ELECTION COMMISSION 

WASHINGTON, D.C. 20463 

December 28,2010 

MEMORANDUM 

To: The Commission 

Through: Alec Palmer 

Actmg Staff Durector 

From: Patricia Carmona 

Chief Compliance Officer 

Joseph F. Stoltz { 

Assistant Staff Director i 

. Audit Division 

Thomas J. Nurdien 

Audit Manager 

By: Lezhi W. Irving 

Lead Auditor 

Subject: Audit Division Recommendation Memorandum on tfae Office and 

Professional Employees Intemational Union - Voice of the Electorate 

(A09-29) 

Pursuant to Commission Directive No. 70 (FEC Directive on Processing Audit 

Reports), the Audit Division recommends the Conunission approve the finding as 

presented in die attached Draft Final Audit Repon (DFAR). The Office of General 

Counsel has reviewed this memorandum and concurs widi die recommendation. 

The Committee declined the opponunity for an audit hearing and made no fimfaer 

response to the finding in the Draft Final Audit Repon. If this memorandum is approved,: 

a Proposed Final Audit Repon will be prepared widiin 30 days of the Commission's vote. 

Should an objection be received. Directive No. 70 states that the Audit Division i 

Recommendation Memorandum will be placed on the next regularly scheduled open 

session agenda. 
Documents related to this audit repon can be viewed on Voting Ballot Matters. 

Should you have any questions, please contact Lezhi Irving or Tom Nurdien at 694-1200. 

Attachment: 

- Draft Final Audit Repon on the Office and Professional Employees Intemational 

Union - Voice of the Electorate 

cc: Office of General Counsel 
Draft Final Audit Report of the 

Audit Division on the 

Ofiice and Professional 

Employees International Union -

Voice of the Electorate 

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 repons 

under the Federal 

Election Campaign Act 

(die Act). The 

Commission generally 

conducts such audits 

when a committee 

appears not to have met 

the threshold 

requirements {or/ 

substantial compliance 

with the Act.' The audit 

determines whether the 

cominittee complied with 

the limitations, 

prohibitions ahd 

disclosure requirements 

ofthe Act. 

About the Committee (p. 2) 

The Office and Professional Employees International Union -

Voice of the Electorate is a separate segregated fund of the Office 

and Professional Employees International Union headquartered in 

Washington, DC. For more information, see:idiai;|i:W die 

Committee Organization, p. 2. \ " jV/ 

Financial Activity (p. 2) 

• Receipts 

o Contributions jfrom Individuals $456,043 

o Offsets to Operating Expenditures 1,000 

o Refunds from Federal Candidates 2,567 

o Other Receipts 4,064 

Total Receipts $463,674 

• Disbursements 

. o Operating Expenditures $ 69,086 

Contributions to Federal Candidates 323,500 

o Other Disbursements 126,156 

Total Disbursements $518,742 

Finding and Recommendation (p. 3) 

Misstatement of Financial Activity 

Future Action 

The Commission may 

initiate an enforcement 

action, at a later time, 

with respect to any of the 

matters discussed in this 

report. 

2 U.S.C. §438(b). 
Draft Final Audit Report of the 

Audit Division on the 

Ofiice and Professional 

Employees International Union -

Voice of the Electorate 

January 1, 2007 - l!),ecemtld|]31, 2008 

• • • \ I 

V.-: .f.. 
Table of Contents 

Part I. Background 

Authority for Audit 

Scope of Audit 

.-•ms-'i;-: 

Part III. Summary f-s ^ 

Finding and Recommendation 

Part IV. Finding and Recommendation 

Misstatement of Financial Activity •;: 

Page 

1 

1 

Part II. Overview of Committee 

Committee Organization ..^ ^ 2 

Overview of Financial Activity Ar^ ^ \ ^ ' ^ ^ 
Part I 

Background 

Authority for Audit 

This report is based on an audit of the Office and Professional Employees Intemational 

Union - Voice of the Electorate (OP-VOTE), ^ 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 ]^!|por|;i(mder 2 U.S.C. 

§434. Prior to conducting any audit under this subsection; the Co^^ission must perform 

an intemal review of reports filed by selected committees to deterllill^ if the reports filed 

by a particular committee meet the threshold requirements for substaritiill compliance 

widi die 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: ^4=-!-^!^}; 

1. The disclosure of individual contributors^fipccup^im and name of employer. 

2. The consistency between reported figuresland bi&k repords./ 

3. The completeness of records. k\ 

4. Other committee operations necessary to the r0f\eswJ.. 

^ On September 28,2010, OP-VOTE filed an amended Statement of Organization and changed its name to 

J B Moss Voice ofthe Electorate Fund (VOTE). 
Part II 

Overview of Committee 

Committee Organization 

Important Dates OP-VOTE 

• Date of Registration July 28,1976 

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

Headquarters Washington, DC 

^ y. ' 

• •:. A' y 

Bank Information 

\ • 

• Bank Depositories 

• Bank Accounts 5 

Treasurer y 

• Treasurer When Audit Was Conducted , Mary Mahoney . ' 

• Treasurer During Period Covered by Audit ^ Nancy Wohlforth 

Management Information fy, 

• Attended FEC Campaign Finance^Sem Yes 

• Used Commonly Available Canipai^r • 

Management Software Package \; : v 

Yes 

• Who Handled Accounting and ' . j 

Recordkeeping Tasks 

Paid Staff 

Overview of Financial Activity 

Cash on hand @ January 1,2007 $311,759 

o Contributions firom Individuals 456,043 

o Offsets to Operating Expenditures 1,000 

o Refunds from Federal Candidates 2,567 

o Other Receipts 4,064 

Total Receipts $463,674 

o Operating Expenditures 69,086 

o Contributions to Federal Candidates 323,500 

o Other Disbursements 126,156 

Total Disbursements $518,742 

Cash on hand @ December 31,2008 $256,691 
Part III 

Summary 

Finding and Recommendation 

Misstatement of Financial Activity 

On its reports as originally filed with the Commission, OP-VOTE underreported 

disbursements by $171,938 for calendar years 2007 and 2008. In respoiise to a 

discussion at the exit conference, OP-VOTE provided a detpated explanation of how the 

initial underreporting occurred as well as steps taken toJilmiiiate fijttilre reporting 

problems. In response to the interim audit report, Counjsf 1 for OP-VDTjE? again stated 

that OP-VOTE has implemented or is in the process ofUpl^^i^ting inij)r6ved 

procedures. (For more detail, see p. 4) :\ 

\7 

\'. . . 
Part IV 

Finding and Recommendation 

Misstatement of Financial Activity 

Summary 

On its reports as originally filed with the Commission, OP-VOTE underreported 

disbursements by $171,938 for calendar years 2007 and 2008. In response to a 

discussion at the exit conference, OP-VOTE provided a detailed %planation of how the 

initial underreporting occurred as well as steps taken to eliniihate jiilure reporting 

problems. In response to the interim audit report. Counsel for OP;r^/C>!tE. again stated 

that OP-VOTE has implemented or is in the process of implem^iting improved 

procedures. 

Legal Standard 

Contents of Reports. Each report must disclose: 

• The amount of cash on hand at the beginning-aiid^iiend of the reporting period; 

• The total amount of receipts for the reporting peripd and for. the calendar year; 

• The total amount of disbursements for thie reportmg period im^ for the calendar year; 

and .'7 / . • ' 

• Certain transactions that require itemization on Schedule A (Itemized Receipts) or 

Schedule B (Itemized Disbursements). 2 U.S!c. §434(b) (1), (2), (3), (4) and (5). 

Facts and Analysis 

The original (disclosure reports filed by OP-VOTE with the Commission for calendar 

years 2007 iaiid 2008 underreported. disbursements by $171,938. A major portion of the 

underreporting ($151,000) occurred during the Post-General reporting period for 2008 

(October 16,. to November 24, 2008). OP-VOTE discovered the problem, and on its own 

initiative, filed amended reports which materially corrected the underreporting. 

This matter was discussed at the exit conference. In response, Counsel stated that the 

person in charge of filing reports was on matemity leave from August 2008 to midOctober 2008, and retumed on a part-time basis. She retumed to full-time on January 5, 

2009. The Post-General report was compiled and filed by the then part-time employee 

transitioning back to fiill-time status, and another newly hired but inexperienced 

employee. Counsel believed that the error was the result of the lack of clear assignment 

of responsibilities to, and oversight of, part-time and new employees. In addition. 

Counsel stated that OP-VOTE is currently reviewing their accounting, reporting, intemal 

control, and oversight policies so that they may be brought into accord with the 

Commission's regulations and Best Practices for Committee Management guidelines. 

OP-VOTE is also procuring on-line reporting software, which will have many built-in 

safeguards and compliance checks, to replace its current software. 
Interim Audit Report Recommendation and Committee Response 

The Audit staff recommended that OP-VOTE provide any additional information or 

comments that it considers relevant to this matter. In response. Counsel again stated that 

OP-VOTE has implemented or is in the process of implementing the improved 

procedures described above. 

/•-••' 

'•! \.--