Interim Audit Report of the 

Audit Division on the Caesars 

Entertainment Corporation 

Political Action Committee 

(January 1, 2011 - December 31, 2012) 

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 

Conmiission 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 

conmiittee 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 any matter 

discussed in this report. 

About the Committee (p. 2) 

The Caesars Entertainment Corporation Political Action 

Committee is a non-party separate segregated fund of Caesars 

Entertainment Corporation, headquartered in Las Vegas, Nevada. 

For more information, see the chart on the committee 

organization, p. 2. 

Financial Activity (p. 2) 

• Receipts 

o Contributions from Individuals $ 328,196 

Total Receipts $ 328,196 

Disbursements 

o Contributions to Federal 

Candidates/Other Committees $ 308,430 

o Operating Expenditures 18,909 

o Other Disbursements 20,126 

Total Disbursements $ 347,465 

Finding and Recommendation (p. 3) 

Misstatement of Financial Activity 

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

Division on the 

Caesars Entertainment 

Corporation Political Action 

Committee 

(January 1, 2011 - December 31, 2012) 
Table of Contents 

Page 

Part I. Background 

Authority for Audit 1 

Scope of Audit 1 

Part II. Overview of Committee 

Committee Organization 2 

Overview of Financial Activity 2 

Part III. Siunmary 

Finding and Recommendation 3 

Part IV. Finding and Recommendation 

Misstatement of Financial Activity 4 
Parti 

Background 

Authority for Audit 

This report is based on an audit of the Caesars Entertainment Corporation Political 

Action Committee^ (CECPAC), 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 consistency between reported figures and bank records; 

2. the disclosure of individual contributors' occupation and name of employer; and 

3. other committee operations necessary to the review. 

^ The committee's name during the audit period was Caesars Entertainment Political Action Committee 

and was changed subsequently on June 4,2013. 
Part II 

Overview of Committee 

Committee Organization 

Important Dates 

• Date of Registration December 11,1989 

• Audit Coverage January 1,2011 - December 31,2012 

Headquarters Las Vegas, Nevada 

Bank Information 

• Bank Depositories One 

• Bank Accounts One Federal 

Treasurer 

• Treasurer When Audit Was Conducted Meredith Hartstem 

• Treasurer During Period Covered by Audit Meredith Hartstem 

Management Information 

• Attended Commission Campaign Finance 

Seminar 

Yes 

• Who Handled Accounting and 

Recordkeeping Tasks 

Paid Staff 

Overview of Financial Activity 

(Audited Amounts) 

Cash-on-hand @ January 1,2011 $ 132,248 

Receipts 

o Contributions from Individuals 328.196 

Total Receipts $ 328,196 

Disbursements 

o Contributions to Federal Candidates/Other 

Committees 

308,430 

o Operating Expenditures 18,909 

o Other Disbursements 20,126 

Total Disbursements $ 347,465 

Cash-on-hand @ December 31,2012 $ 112,979 
Part III 

Summary 

Finding and Recommendation 

Misstatement of Financial Activity 

During audit fieldwork, a comparison of CECPAC *s reported financial activity with 

its bank records revealed a misstatement of receipts and the beginning and ending 

cash balances for 2011 and receipts, disbursements, and the beginning and ending 

cash balances for 2012. For 2011, CECPAC understated the beginning cash balance 

by $38,481, understated receipts by $6,701, and understated the ending cash balance 

by $44,997. For 2012, CECPAC understated receipts by $9,995, disbursements by 

$22,265, and the ending cash balance by $32,727. Subsequent to the exit conference, 

CECPAC amended its reports to materially correct these misstatements. The Audit 

staff recommends that CECPAC provide any additional comments it feels are 

necessary with respect to this matter. 

In addition, CECPAC's original reports for 2011 and 2012 materially understated 

receipts and disbursements. Specifically, CECPAC's original reports understated 

receipts by $151,950 and understated disbursements by $91,495. Amended reports 

filed prior to the notification of this audit did not correct the misstated financial 

activity. The Audit staff recommends that CECPAC provide any additional 

comments it feels are necessary with respect to this matter. 

(For more details, see p. 4.) 
Part IV 

Finding and Recommendation 

Misstatement of Financial Activity 

Summary 

During audit fieldwork, a comparison of CECPAC's reported financial activity with 

its bank records revealed a misstatement of receipts and the beginning and ending 

cash balances for 2011 and receipts, disbursements, and the beginning and ending 

cash balances for 2012. For 2011, CECPAC understated the beginning cash balance 

by $38,481, understated receipts by $6,701, and understated the ending cash balance 

by $44,997. For 2012, CECPAC understated receipts by $9,995, disbursements by 

$22,265, and the ending cash balance by $32,727. Subsequent to the exit conference, 

CECPAC amended its reports to materially correct these misstatements. The Audit 

staff recommends that CECPAC provide any additional comments it feels are 

necessary with respect to this matter. 

In addition, CECPAC's original reports for 2011 and 2012 materially understated 

receipts and disbursements. Specifically, CECPACs original reports understated 

receipts by $151,950 and understated disbursements by $91,495. Amended reports 

filed prior to the notification of this audit did not correct the misstated financial 

activity. The Audit staff recommends that CECPAC provide any additional 

comments it feels are necessary with respect to this matter. 

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 calendar year; 

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

year; and 

• 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 

A. Misstatement of Financial Activity - 2011 and 2012 

1. Facts 

As part of this audit, the Audit staff reconciled CECPAC's reported financial 

activity with its bank records for calendar years 2011 and 2012. The following 

charts outline the discrepancies between CECPAC's disclosure reports and its 

bank records. Succeeding paragraphs explain why the discrepancies occurred. 
2011 Committee Activity 

Reported Bank Records Discrepancy 

Beginning Cash Balance @ 

January 1,2011 

$93,767 $132,248 $38,481 

Understated 

Receipts $155,900 $162,601 $6,701 

Understated 

Disbursements $181,258 $181,443 $185 

Understated 

Ending Cash Balance 

@ December 31, 2011 

$68,409 $113,406 $44,997 

Understated 

The beginning cash balance was understated by $38,481 and the discrepancy is 

unexplained, but it likely resulted from prior period discrepancies. 

The $6,701 understatement of receipts was a result of the contributions from 

individuals, totaling $6,681, that were not reported and an unexplained difference 

of $20. 

The $44,997 understatement of the ending cash balance was a result of the 

reporting discrepancies described above as well as the $185 understatement of 

disbursements. 

2012 Committee Activity 

Reported Bank Records Discrepancy 

Beginning Cash Balance @ 

January 1,2012 

$68,409 $113,406 $44,997 

Understated 

Receipts $155,600 $165,595 $9,995 

Understated 

Disbursements $143,757 $166,022 $22,265 

Understated 

Ending Cash Balance 

@ December 31, 2012 

$80,252 $112,979 $32,727 

Understated 

The understatement of receipts was the result of contributions from individuals, 

totaling $9,995, that were not reported. 

The $22,265 net understatement of disbursements was a result of the contributions 

to federal candidates/other committees, totaling $22,500, that were unreported and 

an unexplained difference of ($235). 

The $32,727 understatement of the ending cash balance was a result of the 

reporting discrepancies noted above. 

CECPAC filed amended reports on February 20 and 21,2013, subsequent to the 

Audit Notification Letter dated December 4,2012. These reports disclosed 

previously unreported contributions from individuals totaling $9,995. However, 
the amended reports disclosed only $5,000 of the previously unreported 

contributions to federal candidates and/or other committees totaling $22,500. 

Thus, the disbursements remained materially misstated for calendar year 2012. 

2. Interim Audit Report and Audit Division Recommendation 

The Audit staff discussed the misstatements for 2011 and 2012 with CECPAC's 

representative during the exit conference and provided copies of relevant work 

papers detailing the misstatements. In response, CECPAC filed amended reports 

that materially corrected the misstatements. 

The Audit staff recommends that, within 30 calendar days of service of this 

report, CECPAC provide any additional comments it feels are necessary with 

respect to this matter. 

B. Misstatement of Financial Activity - Increased Activity 

1. Facts 

In addition to examining CECPAC's most recent reports filed prior to the audit 

notification, the Audit staff compared CECPAC's originally filed reports with 

bank records and discovered a $151,950 understatement of receipts and a $91,495 

understatement of disbursements over the two-year period (2011 and 2012). 

These figures include the $6,701 understatement of receipts from 2011 and the 

$9,995 and $22,265 understatement of receipts and disbursements, respectively, 

from 2012 discussed in Section A (Misstatement of Financial Activity - 2011 and 

2012). The latest amendments filed prior to this audit did not correct all the 

understated financial activity for the two-year period. 

2. Interim Audit Report and Audit Division Recommendation 

The Audit staff discussed the understatement of receipts and disbursements on its 

original reports filed with the CECPAC representative during the exit conference 

and provided copies of relevant work papers detailing the receipts and 

disbursements not reported. In response, the CECPAC representative stated that 

the management was unaware that original reports contained only partially 

reported receipts and/or disbursements. As a result, CECPAC management has 

implemented more rigorous intemal reviews as well as periodic financial 

reconciliations. 

The Audit staff recommends that, within 30 calendar days of service of this 

report, CECPAC provide any additional comments it feels are necessary with 

respect to this matter.