• FEDERAL ELECTION COMMISSIO~

\\ ASHI'ICTON, 0 C 20463

A93-83

REPORT OF THE AUDIT DIVISION

ON THE

WESTERN INTERMOUNTAIN NETdORK

POLITICAL ACTION COMMITTEE

I. Background

A. Overview

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This report is based on an audit of the Western

Intermountain Network Political Action Committee (lithe

Committee") undertaken by the Audit Division of the Federal

Election Commission in accordance 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 Act"). The audit was conduct~d pursuant to Section

438(b) of Title 2 of the United States Code which states, in

part, that the Commission may conduct audits and field

investigations of any political committee r~quired to file a

report under section 434 of this title. Prior to conducting any

audit under this subsection, the Commission shall perform an

internal review of reports filed by selected committees to

determine if ~he reports filed by a particular committee meet the

threshold requirements for substantial co~pliance with the Act.

The Committee registered with the Federal Election

Commission on November 22, 1976, and maintains its headquarters

in Bozeman, Montana.

The audit covered the period January 1, .1981 through

December 31, 1982. The Committee reported an opening cash

balance on January 1, 1981 of $24,762.25: total receipts for the

period of $142,048.S4~ total disbursements for the period of

$165,741.771 and a closing cash balance on December 31, 1982 of

$4,049.10. _/

This audit report is based on documents and working papers

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 the Commissioners

and appropriate staff for review.

• 1/ Certain report totals were misstated.
• B. Key Personnel

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The Treasurer of the Committee during the period of

audit was Mr. Donald C. Burger.

c. Scope

The audit included such tests as verification of total

reported receipts, disbursements and individual transactionsJ

review of required supporting documentation, analysis of

Committee debts and obligationsl and such other audit procedures

as deemed necessary under the circumstances. Becaus£ the

Committee did not maintain adequate contributor records, this

audit did not include the standard audit procedure of

verification of individual contributions to such records.

II. Audit Findings and Recowmendations

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

Code requires disclosure of the identifica:ion of each person who

makes a contribution to the reporting co~mittee during the

reporting period, whose contribution or contributions have an

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

year, together with the date and amount of any such contribution • Section 431(13) (A) of Title 2 of the United States Code states

the term "identification" means, in the case of any individual,

the name, the mailing address, and the occupation of such

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

Section 432(i) of Title 2 of t~e United States Code

states, in 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 this hct for the political committee, any report or any records of such committee shall be

considered in compliance with this Act.

The Audit staff's comparison 0: available contribution

lacords with reports filed revealed that t~e Committee did not

itemize at least 29 contributions from individuals totaling $5,460. This represents 60.42% of the nu~ber and 27.08% of the

dollar amount of contributions requiring i~emization and for

which records were available. Further, th~ Committee did not

disclose 27.45% of the occupations and 29.41% of the names of

employers for contributors itemized in t~e reports•

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A. Itemization of Contributions and Disclosure

of Contributor Information
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•....

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With respect to the occupations, the Audit staff

determined that contributions were received in response to

written solicitations. These solicitations reauested the occu~ation but not the name of the employer. •

In the interim audit report, the Audit staff

recommended that the Committee file comprehensive amendments for

1981 and 1982 itemizing the contributions. Further, the Audit

staff recommended that the Committee amend its fundraising procedures so that, in the future, the names of contributors'

employers are requested. Finally, the Audit staff noted that the

Committee had demonstrated its best~rts to obtain and

disclose the contributors' occupations.

On May 3, 1984, the Committee filed amendments to its

reports of receipts and disbursements itemizing the contributions

as recommended. Further, the Committee provided a list of

contributors which they stated were sent letters on April 20,

1984 requesting the contributors' occupation and name of

employer. The Committee stated that as of April 30, 1984, no

responses were received from these contributors.

Recommendation

No further action is recommended on the matter.

B. Itemization of Expenditures

Section 434(b) (5) (A) of Title 2 of the United States

Code requires the itemization of the name and address of each

person to whom an expenditure in an aggregate amount or value in

excess of $200 within the calendar year is made, together with

the date, amount, and purpose of any such expenditure.

The Audit staff's review of the exoenditure records

revealed that 69 expenditures, in an aggregate amount or value in

excess of $200, totaling $14,866.94 had not been itemized. These

expenditures represent 25.37% of the total number and 9.23% of

the total amount of expenditures requiring itemization.

The Treasurer indicated that he was unfamiliar with the

aggregation requirement regarding such ite~ization.

In the interim audit report, t~e Audit staff

recommended that the Committee file co~prehensive amendments for

1981 and 1982 itemizing the expenditures.

On May 3, 1984, the Committee filed amendments to its

reports of receipts and disbursements itemizing the expenditures•

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Recommendation •

No further action is recommended on the matter.

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c. Matters Referred to Office of General Counsel

Certain matters noted during the audit were referred to

the Commission's Office of General Counsel on March 26, 1984 and

May 24, 1984 •