FEDERAL ELECTION COMMISSION

WASHINCTON. D.C. 20463

REPORT OF THE AUDIT DIVISION

ON THE

LIFE AMENDMENT POLITICAL ACTION COMMITTEE

The Committee registered with the Federal Election

Commission on November 7, 1977. The Committee maintains its

headquarters in Washington, D.C.

The audit cove'red the period January 1, 1980 through

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

January 1, 1980 of $4,380.79i total receipts for the period of

$394,2l2.6Si total expenditures for the period of $395,628.66i

and a cash balance on December 31, 1980 of $2,964.78.

Release Date 5/3/82

This audit report is based on documents and work papers

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

the record upon which the Commission based its decisions on the

matters in the report and were available to the Commissioners and

appropriate staff for review.

A81-24

I. Background

A. Overview

......

,....

.... This report is based on an audit of the Life Amendment

Political Action Committee ("the Committee"), undertaken by the

Audit Division of the Federal Election Commission in accordance wi~h 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

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

committee required to file a report under Section 434 of this

title. Prior to conducting any audit under this section, the

Commission shall perform an internal 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.
"

f

I

-2-

B. Key Personnel

Recommendation

Based on the Committee's response, the Audit Division

recommends no further action.

" During the audit, the Committee was requested to

provide complete bank records for the audit period. On August 26, 1981, a written request for the missing records was made to

the Committee. The Committee did not provide bank statements and

associated debit and credit memoranda covering part of December,

1980 and five of eight loan agreements.

On February 23, 1982, the Commission made a

determination that the Committee provide the records noted above

within 30 days of receipt of the interim audit report. The

Committee responded on March 25, 1982 providing a substantial

amount of the records.

II. Audit Findings and Recommendations

A. Missing Records

C. Scope

The audit included such tests as verification of total

reported receipts and expenditures and individual transactionsJ

review of required supporting documentationJ and analysis of

Committee debts and obligationsJ and such other audit procedures

as deemed necessary under the circumstances. However, although the contribution records provided by the Committee met the

recordkeeping requirements of 2 U.S.C. 432(c) and 11 C.F.R.

l02.9(a), they did not include any material prepared ou~side.of

the Committee. Therefore, no verification of individual

contribution transactions was performed.

The Treasurer for the Committee during the period covered by the audit was Mr. Paul Brown.

C"

:'." Section 432(d) of Title 2 of the United States Code

states, in relevant pa~t, that the treasurer shall preserve all ,~~ records required to be kept by this section for 3 years after the - report is filed.
B.

-3-

Checks Made Payable to "Cash"

Section 102.9(b) (1) (i) and (ii) of Title 11 of the Code

of Federal Regulations states that an account shall be kept of

all disbursements made by or on behalf of the political committee. Such account shall consist of a record of: the name

and address of every person to whom any disbursement is madeJ the

date, amount, and purpqse of the disbursement.

During the review of disbursements, it was determined

that the Committee issued six checks, totaling $3,339.21, payable

to "cash". The Committee did not provide documentation to

support these expenditures.

On February 23, 1982, the Commission made a

determination that the Committee provide documentation for the

disbursements noted above within 30 days of receipt of tpe

interim audit report. The Committee provided the documentation

on March 25, 1982.

Recommendation

Based on the Committee's response, ~~~ recommends no further action.

C. Itemization of Contributions

the Audit Division

Section 434(b) (3) of Title 2 of the Vnited States Code

requires, in part, a committee to disclose the identification of

each person who makes a contribution to the reporting committee,

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.

Our review of the Committee's contribution records

revealed that the Committee did not itemize 134 contributions

totaling $13,282.28 which were in excess of, or aggregated in

excess of $200.00. These contributions represent approximately

69% of the total number and 31% of the total dollar amount of

contributions requiring itemization.

On February 23, 1982, the Commission made a

determination that the Committee amend its reports to itemize

the contributions noted above within 30 days of receipt of

the interim audit report. The Committee filed amendments on

March 25 and April 13, 1982 adequately itemizing the

contributions•

•
-4-

• Recommendation

Tbe Audit Division recommends no further action.

D. Other Matters

Certain otber matters noted during the audit were

referred to the Commission's Office of General Counsel on February 23, 1982•

.. .. .....

'.

•