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FEDERAL ELECTION COMMISSION

WASHINCTON. D.C. 20463

A81-60

. REPORT OF THE AUDIT DIVISION

ON THE

CONNECTICUT DEMOCRATIC PRESIDENTIAL COMMITTEE

I. Background .;

A. Overview

This report is based on an audit of the Connecticut .-. Democratic Presidential Committee ("the 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").

"1ItThe audit was conducted 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

r: committee required to file a report under Section 434 of this

title. Prior to conducting any audit under this secti~n, the

Commission shall perform an internal review-of reports filed by

r- selected committees to determine if the reports filed by a ..-." particular committee meet the threshold requirements for

substantial compliance with the Act. .

,. The Committee registered with the Federal Election

Commission on October 17, 1980. The Committee maintains its

headquarters in Hartford, co~necticut.

The audit covered the period September 1, 1980 through

December 31, 1980. The Committee reported a cash balance on

September 1, 1980 of $-0-; total receipts of $85,016.00; total

expenditures of $83,435.48; and a cash balance on December 31,

1980 of $1,580.52.

This audit is based on documents and work papers which

support each of its factual statements. They form part of the

record upon which th~'Commmission based its decisions on the

matters in the report and were available to the Commissioners and e appropriate staff for review.
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B. Key Personnel

The Treasurer for the Committee during the period

covered by the audit was Mr. Raymond J. Devlin, Jr.

C. Scope

The audit included such tests as verification of total

reported receipts and expenditures and individual transactionsf

review of required supporting documentationf analysis of

Committee debts and obligationsf and such other audit procedures

as deemed necessary under the circumstances• ... II. Audit Findings and Recommendations

A. Disclosure of Contributor Information

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

Code states, in part, that each report shall disclose the

identification of each person who makes a contribution 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.

In addition, Section 104.3{a) (4) of Title 11 of the Code of

C' Federal Regulations requires the committee to disclose the

identification of each contributor 'and the aggregate year-to-date' total for such contributor. -.

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Section 43l(13) (A) of Title 2 of the United States Code

states, in part, that the term "identification" means, in the

case of an individual, the name and mailing address.

During the review of the Committee's disclosure

reports, it was noted that the Committee did not provide the date

of receipt, tpe aggregate year-to-date total for 115

contributions totaling $70,200.00 or 100% of the total number and

total dollar value of itemizable contributions. In addition, the

Committee failed to provide the mailing addresses for 14

contributors whose contributions totaled $8,750.00 or 12.2% of

the total number and 12.5% of the total dollar value of

itemizable contributions. The Committee stated that this was an

result of an oversight, and has agreed to amend its reports.

The Audit Division

within 30 days of receipt of

reports to disclose the date

aggregate year-to-date total

recommended that the Committee,

the interim report, amend its

of receipt, mailing address,

for the contributions noted above.
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An amended report from the Committee was received on

March 15, 1982. The Committee SUbstantially complied with the

recommendations in the interim report.

Recommendation

The Audit staff recommends no further action with respect to

disclosure of contributor information.

B. Disclosure of Expenditure Information

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

Code states, in part, that each report shall disclose 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 by the reporting committee to meet a candidate or committee

operating expense, together with the date, amount, and purpose of

such operating expenditure. -

Section 104.3(b) (3){B) of Title 11 of the Code of .,., Federal Regulations states, in part, that examples of statements r or descriptions which meet the requirements of 11 C.F.R.

·-·el04.3(b) (3) for the "purpose" of why a disbursement was made .~ include the following:.dinner expenses, media, salary, polling, travel, party fees, phone banks, travel expenses, travel expense ('~ r'eimbursement, and catering costs. However, statements or

descriptions such as "advarice" , "ex'pense reimbursement-",

"miscell'aneous", "outside services", "get-out-the-vote", and

r "voter registration", would not meet the requirements of 11

C.F.R. 104.3(b) (3) for reporting the purpose of an expenditure.

During the review of the Committee's disclosure

reports, it was noted that the Committee did not provide the

address of the payee and the date of the disbursement for 54

disbursements totaling $67,139.07 or 100% of -the total number and

the total dollar value of itemizable disbursements. In addition, the Committee disclosed descriptions for the "purpose" of

disbursements which did not satisfy the provisions of 11 C.F.R.

104.3(b) (3) for 12 disbursements totaling $7,360.90. This

represents 22.2% of the number of itemizable disbursements and

11% of the dollar value. The Committee stated that this was a

result of an oversight and a misunderstanding of the Regulation. The Committee agreed to amend its reports in accordance with the

Regulation.

The Audit Division recommended that the Committee, .. within 30 days of receipt of the interim report, amend its .. reports to disclose the addresses of the payees, the date of the

disbursements and descriptions, for the "purpose" in accordance

with 11 C.F.R. 104.3(b) (3) for the disbursements noted above.