Draft Final Audit Report of the 

Audit Division on Spike Maynard 

for Congress 

(February 17, 2010 - December 31, 2010) 

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 metj0 

the threshold ^ 

requirements for 

substantial compliance 

with the Act.]«ilhe»iaudit 

About the Campaign 

Spike Maynard for Congress l§iHe principal campaign committee for 

Elliott Edward Maynard, RQ^^H^iean candidate for the House of 

Representatives from the^ate of^i^^t Virginia, 3"* District, 

headquartered in Williamson, Wesn^Mnia. For more information, 

see the chart on thj^ampaign Organize^n, p. 2. 

Financia l 

• Receipts 

o ^ Contributions 

o ^^^ntributions 

^mmit^es and Othdfi^M^^ipts 

Individuals 

litical 

'w*\ Disburseihents 

^fg\ o OperatSp Expenditures 

"""^'o RefundsUo^ndividuals 

ktal Disburaements 

determines^v^ltietnetwej^ 

committe compliedlVatrL 

the .limipt|,ons, 

prohibitionl^d 

$ 954,961 

76,253 

$ 1,031,214 

$ 967,005 

60,000 

$ 1,027,005 

disclosure r^^^ijgments 

of the Act. 

Future Actioii 

The Commission miy 

initiate an enforcement 

action, at a later time, 

with respect to the matter 

discussed in this report. 

ing and Recommendation (p. 3) 

Disclosure of Disbursements 

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

Audit Division on 

Spike Maynard fo^Dongress 

(February 17, 2010 - D^ei!%r 31, 2010) 
Tabl

e of Contents 

Page 

Part I. Background 

Authority for Audit 

Scope of Audit 

Part II. Overview of Campaign 

Campaign Organization 

Overview of Financial Activity 

Part III. Summary 

Finding and Recommendation 

Part IV. Finding and Recom 

Disclosure of Disbursements 
Part I 

Background 

Authority for Audit 

This report is based on an audit of Spike Maynard for Congress (SMFC), 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 Commissio^to conduct audits and 

field investigations of any political committee that is required to fH^^ort under 2 U.S.C. 

§434. Prior to conducting any audit under this subsection, the C^mission must perform an 

internal review of reports filed by selected committees to detgmnirS&the reports filed by a 

^ff^wu|ited various^risk factors and 

particular committee meet the threshold requirements for suD^antial c<^pliance with the Act. 

U.S.C. §438(b). ^I^^'** 

Scope of Audit 

Following Commission-approved procedures, the 

as a result, this audit examined: 

1. the disclosure of individual contribut^sloccupation 

2. the disclosure of disbursements, debts^^^^jigations; 

3. the consistency between reported figure^^ll^N^i^cords; 

4. the completeness of records; and % ^^feti 

5. other committee operationssnecessary to tl%;gpew. 

of employer; 
Part II 

Overview of Campaign 

Campaign Organization 

Important Dates 

• Date of Registration February 26,2jg#Q^' 

• Audit Coverage February December 31, 2010 

Headquarters Williamsdnil Wesi^irginia 

Bank Information 

• Bank Depositories OnjT "^^^ 

• Bank Accounts checking ^'^^liw.^ 

Treasurer A. W 

• Treasurer When Audit Was Conducted 

• Treasurer During Period Covered by ^^H^it Robert 

Management Information ^^8^1^ 

• Attended FEC Campaign Finance Semil^a^?^ 

• Who Handled Accounting and % 

^ w 

Recordkeeping Tasks A. \au 

Ovi^l^eiif of Finiiicial Activity 

Cash-omtiiid ^ Februaifli^, 201^^' ^ $ 0 

Receipts "'"^^L "Wk .F 

o ContributidrTs^pm IndividMUls 954,961 

o Contributions^^nPolitica^l/Committees and 

Other Receipts ^ll x ^# 

76,253 

Total Receipts $ 1,031,214 

Disbursements ^' 

o Operating Expenditures 967,005 

o Refunds to Individuals 60,000 

Total Disbursements $ 1,027,005 

Cash-on-hand ^ December 31,2010 $ 4,209 
Part III 

Summary 

Finding and Recommendation 

Disclosure of Disbursements 

The Audit staff identified 84 disbursements, totaling $261,999, with missing or 

inadequately disclosed purposes. Subsequent to the exit confereg^^^MFC filed 

amended reports that materially corrected the disclosure of th^aisbursements. In its 

response to the Interim Audit Report, SMFC stated it had s|^^^torily amended the 

affected reports and offered no additional comments on t!^ma^^|(For more detail, see 

p. 4) 
Part IV 

Finding and Recommendation 

I Disclosure of Disbursements 

Summary 

The Audit staff identified 84 disbursements, totaling $261,999, with missing or 

inadequately disclosed purposes. Subsequent to the exit conference, SMFC filed 

amended reports that materially corrected the disclosure of these^^b|jrsements. In its 

response to the Interim Audit Report, SMFC stated it had sati^ctorily amended the 

affected reports and offered no additional comments on thi^ 

same 

Legal Standard 

A. Reporting Operating Expenditures. WherLs^ierating expenditi 

person exceed $200 in an election cycle, the co^nittee mi^t report the: 

• Amount; 

• Date when the expenditures were made; 

• Name and address of the paye^^nd 

• Purpose (a brief description of^^| ^ disbursemS^^^s made—see below). 

• 11 CFR§104.3(b)(4)(i). 

B. Examples of Purpose..,,.,^ 

• Adequate Des^^ptfoii^^xamples o^idequate descriptions of "purpose" include 

the followmg^inner i^^enses, medi^^alary, polling, travel, party fees, phone 

banks, travell^Wses, t||vel expense r^^bursement, catering costs, loan 

repayment, or c^^M©^|^d . l^F R §104.3 (b)(4)(i)(A). 

• Ina^^^^^^ripFi^^Th e folToiv^ing descriptions do not meet the requirement 

^rreporti^^gnpose^^^ance, election-day expenses, other expenses, expense 

^^^IP^"^^^'^^"^^^^''^^^^^"^^'^ ^ services, get-out-the-vote and voter 

"^"^tstration. 11 ^^§104|^)(4)(i)(A). 

Facts and jflmalysis 

A. Facts 

During audit fieldw^plc, the Audit staff identified 84 disbursements for salary payments 

and payments to media vendors for television ads totaling $261,999 with either missing 

or inadequately disclosed purposes. SMFC disclosed 55 of these disbursements totaling 

$213,696 without purposes in its reports filed with the Commission. SMFC reported the 

remainder of these disbursements using inadequate purposes such as "reimbursement" or 

"collateral." When the Audit staff presented this matter during fieldwork, SMFC 

representatives responded that they had attempted to amend their reports prior to 

fieldwork, but were unable to do so due to technical difficulties. 
B. Interim Audit Report & Audit Division Recommendation 

During the exit conference held at the conclusion of fieldwork, the Audit staff provided 

SMFC representatives with a schedule detailing items reported with inadequate or 

undisclosed purposes. The Audit staff recommended that SMFC file amended Schedules 

B (Itemized Disbursements) to correct the disclosure of these transactions. SMFC 

representatives agreed that amended reports should be filed to fully disclose the purposes 

of the disbursements in question. 

Subsequent to the exit conference, SMFC filed amended reports that materially corrected 

the disclosure of the disbursements noted above. 

The Interim Audit Report recommended that SMFC provide^ 

felt were relevant to this matter. 

additional comments it 

C. Committee Response to Interim Audit Repoi 

In its response to the Interim Audit Report, SMF^f^tedlhat the repoi%^|^|d it had 

satisfactorily amended the affected reports andg^ered no-'aidditional comm'^ntS:£)n this 

matter. '^^^ k I k '^IP^