Draft Final Audit Report 

of the Audit Division on 

Jill Stein for President 

(October 11, 2011 - August 31, 2014) 

Why the Audit Was 

Done 

Federal law requires the 

Commission to audit every 

political committee 

established by a candidate 

who receives public funds 

for the primary campaign.' 

The audit determines 

whethw the candidate was 

entitled to all of the 

matching funds received, 

whether the campaign used 

the matching funds in 

accordance with the law, 

whether the candidate is 

entitled to additional 

matching funds, and ^ 

whether the 

otherwise complied • 

the imitations, 

prohibitions, 

disciosure^i 

the ell law. 

Futd 

The 

initiate an 

action, at a 

respect to any of 

matters discusser 

report. 

About the Campaign (p. 2) . ^ 

Jill Stein for President (JSFF) is the ^ . impaign committee for 

Jill Stein, a candidate for the Green nomination for the office of 

President of the United States. is headquartered in 

Lexington, Massachusetts. Foi^reir 

Campaign Organization, 

Financial Acti\ 

• Receipts < 

o Contributions 

o Matching Funds 

o I^gns Received fiorr? 

o Ci IS from P( 

o O ng 

Total 

>, see the chart on the 

r t 

isbursements 

b and Recommendations (p. S) 

m .standing Campaign Obligations (Finding 1) 

Mj lement of Financial Activity (Finding 2) 

Disclosure of DebS and Obligations (Finding 3) 

Reporting of ReceipS (Finding 4) 

• Reporting of Expenditures (Finding S) 

Itemization of Candidate Loans (Finding 6) 

81S,8S1 

372,130 

64,000' 

4,235 

3,368 

S 1,259,584 

$ 1,070,033 

26,803 

20,000 

1,170 

S 1,118,006 

26 U.S..C. §9038(a). 

These figures consin both primary and general activity. The general activity accounS for approximately 

$567,994, or 45% of total receipS, and $269,888, or 24% of tosl disbursemens. See Committee 

Smicture on n. 1. 

The Candidate made loans as follows: $44,000 for primary election activity and $20,000 for general 

election activity. Therefore, the Candidate did not exceed the $50,000 iimitation on expenditures for the 

primary eiection fiom the Candidate's funds.. 26 U.S.C. §903S(a); 11 CFR §9035.2. 
Draft Final Audit Report 

of the Audit Division on 

Jill Stein for President 

(October 11, 2011 - August 31, 2014) 
Table of Contents 

Page 

Part I. Background 

Authority for Audit 1 

Scope of Audit 1 

Inventory of Campaign Records 1 

Committee Structure 1 

Part II. Overview of Campaign ^ 

Campaign Organization ^ 3 

Overview of Financial Activity ' 4 

' X Part III. Summaries ^ ^ 

Findings and Recommendations 

Part IV. Findings and Recommeni ^ 

Finding 1. Net Outstanding Camj nC _ ^ 7 

Finding 2. Misstatement of Finai ^tivity " 10 

Findings. Disclosure of Debts ai ^ 12 

Finding 4. Reporting of Receipts \ . ^ 

Findings. Reporting of Expenditures^ ^ 16 

Finding 6. Lo^p ^ 18 
Parti 

Background 

Authority for Audit 

This report is based on an audit of Jill Stein for President (JSFP), unde^en by the Audit 

Division of the Federal Election Commission (the Commission) as mandated by Section 

9038(a) of Title 26 of the United States Code. That section states, "After each matching 

payment period, the Commission shall conduct a thorough examination and audit of the 

qualified campaign expenses of every candidate and his authorizefeommittees who 

received [matching] payments under section 9037." Also, Sc 

States Code and Section 9038.1(a)(2) of the Commission's 

Commission may conduct other examinations and audit 

necessary. 

•) of the United 

ions state that the 

time as it deems 

Scope of Audit 

This audit examined: * 

1. the campaign's compliance with limitations I 

2. the campaign's compliance with the limitations 

3. the campaign's compliance with f libitionon. 

4. the disclosure of contributions ani 

5. the disclosure of disbursements, del 

6. the consistency between reported fi; 

7. the accuracy of the ~ afNetO 

8. the campaign's ^. ispendinl 

9. the completenp^i ~ ord I 

10. other campaign 0| 

date contributions and loans; 

I prohibited contributions; 

ign Obligations; 

Invei^ii II C 

The Aum st^ rou 

aw 3rk. JSFP 

thereafi 

Recorurf 

'entory of campaign records before it begins 

iterially complete and fieldwork commenced 

Commitfi • Si mci i.ie 

JSFP was the on! committee authorized by Jill Stein (the Candidate) for the 

2012 Presidential and conducted both primary and general election activity for 

the Candidate. JSF^pened four bank accounts; three primary accounts and a general 

account. In practice, JSFP deposited nearly all contributions received before thie 

Candidate's nomination into Ae primary accounts, and most contributions received after 

the nomination into the primary accounts, unless otherwise designated and deposited into 

the general account. JSFP received matching funds for its primary campaign and this 
audit covered the JSFP's primary election activity to determine if expenses were qualified 

campmgn expenses defrayed in coimection with the primary election.^ 

* Under Title 26, this audit includes an examination of JSFP's Statement of Net Outstanding Campaign 

Obligations (Finding 1) based soieiy on JSFP's primary eiection activity for the purpose of determining 

the extent to which the Candidate is entitled to primary matching funds. This audit aiso covers an 

examination of JSFP's reporting under Title S2 which includes general election activity. For 

clarification, the Audit staff has indicated in Finding 2 - Misstatement of Financial Activitv and Finding 

6-1 
Part II 

Overview of Campaign 

Campaign Organization 

Important Dates 

Date of Registration November 14,2QJ 

Eligibility Period 

Audit Coverage^ 

August 22,2Q.^^ September 6,2012 

October 11^ August 31,2014 

Headquarters 

Bank Information 

Bank Depositories 

• Bank Accounts 

Treasurer 

general account 

• Treasurer When Audit Was 

• Treasurer During Period Covered by 

Management Informatioi 

• Attended CommissioQi? 

Seminar ^ 

• Who Handled Accouii^i' d 

Recordkeeping Tasks 

Jam> 

Tames Morli ler 23,2012 - Present 

Qdre^ 6,2012 - October 22,2012 

>fevember 14,2011 - July S, 2012 

On July 9,2012, the Candidate submitted a signed letter to the Commission, which was amended on July 12, 

2012, seeking to become eligible to receive Presidential primary nutching &nds and agreeing that she and her 

authorized committee would comply with the conditions set forth in 11 CFR §9033.1(b). A threshold submission 

was submitted on July 16,2012, and the Commission certified the Candidate as eligible to receive matching fimds 

on August 22,2012. The period during which the Candidate wiu eligible for matching funds ended on September 

6,2012, the date of ineligibility. 

The Audit staff conducted limited reviews of receipts and expenditures after December 31,2012, to determine 

whether the Candidate was eligible to receive additional matching funds. 
Overview of Financial Activity 

(Audited Amounte)'' 

Cash-on-hand @ October 11,2011 SO 

Receipts 

o Contributions from Individuals" 815,851 

o Matching Funds Received'' 72,130 

o Loans Received from the Candidate ^.000'" 

o Contributions from Political Parties 4.235 

o Offsets to Operating Expenditures .3.368 

Total Receipts 

Disbursements 

o Operating Expenditures ^ 1.07" _ 

o Fimdraising Disbursements 26,803^ 

o Loan Repayments 20,000 

o Contribution Refunds 1.170 

Total Disbursements Sb. r,118,006 

Casb-on-band @ December 31,2012 ^ f S 141,578 

A 

^ These figures contain both primary and general activity. See Committee Structure on p. 1. 

' JSFP received approximately 8,400 contributions from approximately 6,000 individuals. 

' As of the Candidate's date of ineligibility, September 6,2012, JSFP had received matching funds totaling 

$100,000. JSFP received an additional $272,130 by December 3,2012, for a total of $372,130. 

"* See Footnote 3. 
Part III 

Summaries 

Findings and Recommendations 

Finding 1. Net Outstanding Campaign Obligations 

The Audit staff's review of JSFP's financial activity through August 31,2014, and 

estimated winding down costs indicated that the Candidate did ij^g^eive matching fund 

payments in excess of her entitlement. 

In its response to the Preliminary Audit Report recomm( 

further comment. (For more detail, see p. 7.) 

Finding 2. Misstatement of: 

During audit fieldwork, a comparison of JSI 

records revealed that, for 2012, JSFP understated 

on-hand by $211,949, and $106,128,^spectiveiy; a 

$13,850. Amendments filed subsequi ; audit notil 

correct the identified misstatements. 1 F filed, 

audit fieldwork to materially correct thel 

•rovided no 

tivity f 

ial activity i its bank 

ipts and cmding cashited disbursements by 

. letter did not materially 

reports subsequent to 

In response to the Prel 

complications caus^, 

duplicated variou^^ 

to identify shortcomin 

assistance < ~ i stdll 

11 

t Repor^Korrunencpion, JSFP stated that, due to 

•ookkeep^initial filings lacked certain records and 

ic irther, JSF^te^ed that, during fieldwork, it was able 

"ngmade necessary corrections with the 

' filed amended reports subsequent to 

. the ini^tatements. (For more detail, see p. 10.) 

Fi^!5|j^3. Disc'iis ire i^Sebts and Obligations 

During ludit ^df identified debts totaling $78,043 not disclosed on 

Schedule D ^bts and (Migations) as required. Amendments filed subsequent to the 

audit notificatiSIf r di^^sed some of these debts. JSFP filed amended reports to 

materially disclos ^bts and obligations. 

In response to the P^iminary Audit Rqport recoimnendation, a JSFP representative 

stated that, during the course of audit fieldwork JSFP was able to identify various debts 

and obligations that were previously unreported due to mistakes made by the initial 

bookkeeper. JSFP filed amended reports subsequent to audit fieldwork which materially 

corrected the disclosure of these debts and obligations. (For more detail, see p. 12.) 

Finding 4. Reporting of Receipts 

During audit fieldwork, the Audit staffs review identified contributions from individuals 

totaling $23,071 that JSFP failed to itemize. In addition, receipts totaling $57,622 were not 
adequately disclosed. For most of these contributions, the election cycle-to-date total 

disclosed on Schedules A-P (Itemized Receipts) was incorrect. Amended reports filed 

subsequent to the audit notification letter materially corrected both the itemization and 

disclosure errors. 

In response to the Preliminary Audit Report recommendation, JSFP stated it discovered 

"unspecified" issues with import functions where donor information would not be 

recognized as a potential duplicate, causing various donor aggregates to be inaccurate in 

final reports. These issues have been corrected with the amended reports previously 

filed. (For more detail, see p. 14.) 

Finding 5. Rc^porting of Expenditures 

During audit fieldwork, the Audit staff identified < 

failed to itemize as required. In addition, expend! 

adequately disclosed. For most of these expend! 

was.inadequately disclosed. Amended reports 

letter materially corrected both the itemization 

^ng $49,797 that JSFP 

$W • were not 

lisclosed or 

luent to the i itification 

errors. 

In response to the Preliminary Audit Report reconu an, JSFP indicated that, after 

receiving clarification ftom the Audi^^ision and Re^ -alysis Division staff, it was 

able to identify all expenditures lacki^^^^ itemizatio jui^quate descriptions. 

JSFP filed amended reports which corr^^^ irs. , detail, see p. 16.) 

Finding 6. Iteni:/ 

The Audit staff identi;^ 

reported cpnectly P. 

letter materially c 

• i»n of 

am the 

t ided 

e r^rting of 

^ Idiiii- L^ns 

idate tota^g $40,000 that had not been 

lied subsequent to the audit notification 

In respo: 

date,! 

ommendation, JSFP indicated that, to 

f candidate loans have been corrected. (For more 
Part IV 

Findings and Recommendations 

Finding 1, Net Outstanding Campaign Obligations 

Summary 

The Audit staffs review of JSFP's financial activity through August 31,2014, and 

estimated winding down costs indicated that the Candidate did not^receive matching fimd 

payments in excess of her entitlement. 

In its response to the Preliminary Audit Report reconmu 

further conunent. 

P provided no 

Legal Standard 

A. Net Outstanding Campaign Obligatioi ^IHIO). 

candidate's date of ineligibility (see defmitio the 

statement of "net outstanding -

among other things: ^ 

• The total of all committee asscommittee and capital assets lii 

• The total of all outstanding obli] 

• An estimate of necessarv winding 

B. Dateoflnelig 

occurs first: 

• The day on wl 

• . Th< ill 

(ithin IS da> 

iidate must 

lent must ^ntain, 

amounts owed to the 

paign expenses; and 

?fR §9034.5(a). 

of ineligi |ity is whfchever of the following dates 

end oft' 

/ nominates 

se of a« 

com the 

the call 

active in more than one state; 

ive primary in which the candidate 

of the^pular vote; 

nt period, which is generally the day when the 

r the general election; or 

does not make its selection at a national 

ly of the last national convention held by a major party in 

CFR §§9032.6 and 9033.5. 

n 

ndid. 

C. Qualified Camp^^ Expense. Each of the following expenses is a qualified 

campaign expense. 

• An expense that is: 

o Incurred by or on behalf of the candidate (or his or her campaign) during the 

period beginning on the day the individual becomes a candidate and 

continuing through the last day of the candidate's eligibility under 11 CFR 

§9033.5; 

o Made in connection with the candidate's campaign for nomination; and 

o Not incurred or paid in violation of any federd law or the law of the state 

where the expense was incurred or paid. 11 CFR §9032.9. 
• An expense incurred for the purpose of determining whether an individual should 

become a candidate, if that individual subsequently becomes a candidate, 

regardless of when that expense is paid. 11 CFR §9034.4. 

• An expense associated with winding down the campaign and terminating political 

activity. 11 CFR §9034.4(a)(3). 

i). Entitlement to Matching Payments after Date of Ineligibility. If, on the date of 

ineligibility (see above), a candidate has net outstanding campaign obligations as defined 

under 11 CFR §9034.5, that candidate may continue to receive matching payments 

provided that he or she still has net outstanding campaign debts i ' s day when the 

matching payments are made. 11 CFR §9034.1(b). ^ 

E. Winding Down Costs. A primary election candidate 

election may receive and use matching funds after noti 

of the candidate's withdrawal from the campaign 

party's nominating convention, if the candidate 

A primary election candidate who runs in the 

after the general election before using any 

regardless of whether the candidate receives mate 

11 CFR §9034.11(d). ^ 

not run in the general 

the 0"" ission in writing 

iono ,^iE^thedateofthe 

it withdrawn be^ convention, 

elec^ must wai apdays 

dSi^l^nding dov^^sts, 

s for the generafelection. 

Facts and Analysis 

A. Facts 

The Candidate's date 

reviewed JSFP's 

down costs and pn^ 

appears on the next pa] 

ly (DOI)^p Septem, 6,2012. The Audit staff 

through Aqmst 31,2014, analyzed estimated winding 

nent of Net^^jtatanding Campaign Obligations that 
Jill Stein for President 

Statement of Net Outstanding Campaign Obligations 

As of September 6,2012 

Prepared August 31,2014la] 

Cash in Bank 

Apcounts Receivable 

Total Assets 

Liabilities 

Accounts Payable for Qualified Campaign Expenses at 

Loans Payable to Candidate 

Winding Down Costs: 

Actual Winding Down Costs Paid (12/7/12 - 8/3 

Estimated Winding Down Costs (9/1/14 - 3/ g 

Total Liabilities 4 

Net Outstanding Campaign Obligations (Deficit) 

$ 57,302 

31,443 

$ 88,745 

.500 

55x 

b]" 

![c] 

10,640 

[a] The latest report filed by JSFP covered ai 

[b] Loans payable at DOI. 

[c] The General election was November 6,2012. 

General election on Deo 312. 

[d] Estimated winding : compared 

accordingly. 

Shown below are adju 

6,2012 til oe 

payment^ 

tember6.2012 $f421.89S) 

;ust31. 

i^begins 31 days after the 

wind^ down costs and adjusted 

ler the Candidate's DOI on September 

T received its last matching fund 

^^ndingCa _ ^ ons (Deficit) as of ($421,895) 

Less: Coii|^^ons Reeved (September 7,2012 through 

December 37l|^) M 

98,753 

Less: Matchinp^ i^eceived September 7,2012 through 

December 3,201' 

272,130 

Remaining Net Outstanding Campaign Obligations 

(Deficit) as of December 3,2012 

S (51,012) 

As presented above, JSFP has not received matching fund payments in excess of the 

amount to which the Candidate was entitled. 

'' This total represents all loans payable at DOI. Loan repayments of $20,000 each were paid to the 

Candidate on September 11,2012, and March 20,2013, totaling $40,000. The outstanding balance due 

on the loan is $4,000. 
10 

The Audit staff presented a preliminaiy NOCO statement and related work papers to the 

JSFP representatives at the exit conference. After the exit conference, the representatives 

provided additional documentation as requested to update the NOCO statement. 

B. Preliminary Audit Report Recommendation 

The Preliminary Audit Report recommended that JSFP demonstrate any adjustments it 

believed were required in connection with any part of the NOCO statement or provide 

any other additional comments. 

C. Committee Response to Preliminary Audit Report 

In its response to the Prelimiiuuy Audit Report recommends 

further comment. 

Finding 2. Misstatement of Fina: 

Summary ^ 

During audit fieldwork, a comparison of JSFP's 

records revealed that, for 2012, JSFP understated its 

on-hand by $211,949, and $106,li28,^^mectively; anc 

$13,850. Amendments filed subsequ^r no 

correct the identified misstatements. Ho 

audit fieldwork to materially correct the 

provided no 

- filed an 

activity its bank 

I receipts and ending cashed disbursements by 

er did not materially 

reports subsequent to 

In response to the 

complications cai 

duplicated vari 

to identify shortcoming.' 

assistancec^i^ a 

audit 'f^rk tc 

its in 

m 

lit Report 

book 

'urther, JS: 

r 

.n( 

on, JSFP stated that, due to 

itial filings lacked certain records and 

that, during fieldwork, it was able 

id made necessary corrections with the 

SFP filed amended reports subsequent to 

e misstatements. 

Legal 1 

Contents of - ts. Ea port must disclose: 

• theamoii!^ ~ hand at the beginning and end of the reporting period; 

• the total am 1'receipts for the reporting period and for the election cycle; 

• the total amo^t of disbursements for the reporting period and for the election 

cycle; and 

• certain transactions that require itemization on Schedule A-P (Itemized Receipts) or 

Schedule B-P (Itemized Disbursements). 52 U.S.C. § 30104 ^)(1), (2), 3), (4) and 

(5). 
11 

Facts and Analysis 

A. Facts 

The Audit staff reconciled JSFP's reported financial activity with its bank records and 

determined that there was a misstatement of beginning and ending cash-on-hand, receipts 

and disbursements. The following chart outlines the discrepancies and succeeding 

paragraphs explain, to the extent possible, the reasons for the misstatements. 

2012 Activity" 

Reported Bank Re^rds Discrepancy 

Beginning Ca.sh-on-hand 

Balance ® January 1.2012 

$19,000 $328 

Understated 

Receipts $1,018,273 " „^222 $211,949" 

Understated 

Disbursements $1,121, ,^$1,107,5^ $13,850"' 

Overstated 

Ending Cash-on-hand Balance 

(SI December 31.2012 

%35^ 

•s , 

$141,578 ^6,128'" 

1 J^derstated 

The beginning cash-on-hand was ove 

discrepancies. 

The understatement of receipts resulted 

tedby$32i< : to prior period 

mg: 

Matching Funds not reported 

Contributions duals not i 

In-kind contri^^n ported 

Loans fron^ did lOt i 

Offsets not rej , 

Re es not reported 

l^i. id by a deposit/credit 

identified * 

\ iderstatei fR .ts 4^ 

$ 100,000 

89,647 

2,539 

40,000 " 

1,509 

4,235 

(23,772) 

(2,209) 

The overstatemei 

• Inter-accoun ifers reported as disbursements $ (17,000) 

" This activity represents both general and primary election activity. See Footnote 6. 

" General election activity represents S86,083, or 41% of the understated receipts totals. 

General election activity represents (S7.803), or 36% of the overstated disbursements totals. 

JSFP's reported ending cash-on-hand balance does not calculate correctly due to a fiiilure to cany 

forward the ending cash-on-hand balance of (S7S,680) from its 2012 September Monthly report as the 

beginning cash-on-hand on its 2012 October Monthly report Absent this error, the conect ending cash 

balance as of December 31,2012 should have been ^84,349). 

" See Footnote 10. 

The unrepoited loans fiom the Candidate, totaling $40,000, were comprised of $20,000 loaned for the 

primary election and $20,000 loaned for the general election (see Finding 6). 
12 

Reported voided checks 

Over-reported payroll disbursements 

Double risporting of Candidate loan repayment 

Disbursements reported not supported by a check/debit 

Operating expenditures report^ twice 

Bank reversing entries reported as disbursements 

Operating expenditures not reported 

In-kinds not reported 

Refund not reported and other reporting errors 

Unidentified Difference 

Net Overstatement of Disbursements 

The understatement of ending cash-on-hand in the amou^ 

misstatements described above. 

B. Preliminary Audit Report Recommenda 

At the exit conference held at the end of 

misstatements and subsequently provided JSFP re 

these discrepancies. In response, the representatives 

The representatives offered no additiS^ iments. 

the audit notification letter had not nu cted 

However, additional amended reports fi 

corrected these misstatements. 

The Preliminary Au^^ 

information or 

(3.765) 

(2,585) 

(20,000) 

(9,399) 

(23,108) 

(285) 

61,082 

2,539 

825 

(2,154) 

(t 

resulted from the 

.udit staff . I^d the 

ith schedu^ detailing 

to amend JSFP's reports, 

filed subsequent to 

^fied misstatements. 

3 the conference materially 

: JSFP ^vide any additional 

omei at it consi^red relevant to this matter. 

C. Com^^^^yspon.' 

comp '^ns cans ^ ii 

dup^ arious expeSS 

to ident jgrtcomings r 

audit fieldwo: iteria 

dt Report 

commendation, JSFP stated that, due to 

, initial filings lacked certain records and 

s. wsmcr, JSFP stated that, during fieldwork, it was able 

i tojus finding and made necessary corrections with the 

noted above, JSFP filed amended reports subsequent to 

>nect the misstatements. 

Finding 3. Disclosure of Debts and Obligations 

Summary 

During audit fieldwork, the Audit staff identified debts totaling $78,043 not disclosed on 

Schedule D-P (Debts and Obligations), as required. Amendments filed subsequent to the 

audit notification letter disclosed some of these debts. JSFP filed amended reports to 

materially disclose these debts and obligations. 
13 

In response to the Preliminary Audit Report recommendation, a JSFP representative 

stated that, during the course of audit fieldwork, JSFP was able to identify various debts 

and obligations that were previously unreported due to mistakes made by the initial 

bookkeeper. JSFP filed amended reports subsequent to audit fieldwork which materially 

corrected the disclosure of these debts and obligations. 

Legal Standard 

A. Continuous Reporting Required. An authorized committee must disclose the 

amount and nature of outstanding debts and obligations until those debts are 

extinguished. 52 U.S.C. §30104(b)(8) and 11 CFR §§104.3(d) and.104.11(a). 

B. Separate Schedules. An authorized committee must fi 

owed by and to the conunittee with a statement expl 

conditions under which each debt and obligation was i 

11 CFR §104.11(a). 

C. Itemizing Debts and Obligations. 

• Once it has been outstanding 60 days 

less must be reported on the next regularly 

• A debt exceeding $500 must 1, iclosed in the' 

which the debt was incurred, i ixmrring 

rent) shall not be reported as a pa 

11 CFR §104.11(b). 

Facts and AnalysBi 

A. Facts ^ 

During audit fieldworl. 

the sxcova^j^, 

servic ' Ihe 

tele^ Ivertising, 

debbi these venae 

as require 

u-ate schedules for debts 

•stances and 

lished. 

,adel ^ 1500 or 

report. 

that covers the date on 

ive expenses (such as 

date. 

ai sn 

01 

lie disbursement records to reconcile 

vendors provided JSFP maiidy with 

ballot access petitioning, legal services, printing, 

convention services. The Audit staff identified 

>78,043 '* that were not disclosed on Schedule D-P, 

B. Prelimina , Import Recommendation 

The Audit staff pi nws matter to JSFP representatives at the exit conference and 

provided schedules {jl!ailing the unreported debts for each reporting period. The 

representative agreed to file amendments, but offered no additional comments during the 

exit conference. The Audit staff reviewed amended reports filed after the audit 

notification letter and concluded that debts totaling $4,501 have not yet been disclosed. 

The Preliminary Audit Report recommended that JSFP provide documentation 

denionstrating that the remaining $4,501 in expenditures did not require reporting on 

Each debt amount was counted once, even if it required disclosure over multiple reporting periods. 
14 

Schedule D-P. Absent such documentation, it was further recommended that JSFP 

amend its reports to disclose the remaining outstanding debts. 

C. Committee Response to Preliminary Audit Report 

In response to the Preliminary Audit Report recommendation, a JSFP representative 

stated that, during the course of audit fieldwork, JSFP was able to identify various debts 

and obligations that were previously unreported due to mistakes made by the initial 

bookkeeper. JSFP filed amended reports subsequent to audit fieldwork which materially 

corrected the disclosure of these debts and obligations. 

Finding 4. Reporting of Receipts 

Summary 

During audit fieldwork, the Audit staffs review i^^SHSd cbntribul ^ ^m individuals 

totaling $23,071 that JSFP failed to itemize. In^pition, ^ipts totalin ^2 were not 

adequately disclosed. For most of these contai^ , the^^tion cycle % total 

disclosed on Schedules A-P (Itemized Receipts) ^ i ^^Amended remits filed 

subsequent to the audit notification letter materially ^ i both the itemization and 

disclosure errors. ^ 

In response to the Preliminary Audit R 

"unspecified" issues' 

recognized as a potentii ite, causin' 

final reports. These sen com 

filed. A 

Legal Standard 

A. Itemiz 

lendatioii^^jP stated it discovered 

^mtion would not be 

lus ( _ gregates to be inaccurate in 

with the^mended reports previously 

1 cycle, eit 

ributor. 52"^ 

[from Individuals. An authorized 

ribution from an individual if it exceeds $200 per 

£bn combined with other contributions from the 

:§3„ (b)(3)(A). 

B. Election 

previous ge^ 

contributions i 

election cycle bej 

. IICFR §100.3 

The ( on cycle begins on the first day following the date of the 

nd ends on the date of the next general election. If 

itures are designated for another election cycle, then the 

when the first contribution is received or expenditure is made. 

C. Required Informatiou for Contributions from Individuals. For each itemized 

contribution from an individual, the committee must provide the following 

information; 

• The contributor's full name and mailing address; 

• The contributor's occupation and the name of his or her employer; 

• The date of receipt (the date the committee received the contribution); 

• The amount of the contribution; and 
15 

• The election cycle-to-date total of all contributions from the same individual. 11 

CFR §§100.12 and 104.3(a)(4) and 52 U.S.C§30104(b)(3)(A). 

Facts and Analysis 

A. Facts 

During audit fieldwork, the Audit staff reviewed all contributions from individuals whose 

contributions agjgregat^ in excess of $200. These reviews identified the following: 

1. Contributions Not Itemized - There were 268 contri 

totaling $23,071that JSFP failed to itemize on 

Receipts), as required. 

ions from individuals 

.-? (Itemized 

Contributions Not Adeauatelv Disclose^j ^ere v 

from individuals totaling $57,622, for y^^tjp^lectioi 

amounts and/or contributor names ^ '^ther incorrectly 

missing. ^ 

conhibutions 

-to-date 

or 

These itemization and disclosure errors resulted m: 

• Multiple contributor identific^n numbers' 

the same individual mainly re«^ m incorre 

information. For example, the ^ esLlastnamei 

for contributions that were appar^ly m ine! 

The Audit 

irithe 

the 

omitted. All 

ed in JSFP's database for 

of contributor 

entered incorrectly 

ividual; 

ipts di lase provided by JSFP resulted 

1,780^" receipts had been omitted from 

explain why these receipts had been 

Items did not require itemization, the 

^ __regate election-to-date amounts on 

ibutions fi:om the same individuals to be incorrect. 

B. Fi ry Audit tR« mendatiou 

At the ex ence h he md of audit fieldwork, the Audit staff explained the 

errors and SI jjentlypn ed JSFP representatives with schedules detailing these 

discrepancies. ^ ons^^e representatives agreed to amend JSFP's reports. The 

representatives o I Is^ditional comments during the exit conference. 

Subsequent to the exit conference, the Audit staff reviewed amended reports filed after 

the audit notification letter and concluded that the amendments materially corrected both 

the itemization and disclosure errors noted above. 

" Of this amount, S6,272 is included in Finding 2, Misstatement of Financial Activity, as part of the 

receipts adjustment of S89,647 for contributions from individuals not reported. 

TM These items are included in the adjustments for receipts presented at Finding 2, Misstatement of 

Fitimpiai Activity. 
16 

The Pteliminary Audit Report recommended that JSFP provide any additional 

information or written comments that it considered relevant to this matter. 

C. Committee Response to Preliminary Audit Report 

In response to the Preliminary Audit Report recommendation, JSFP stated it discovered 

"unspecified" issues with its FECFile import functions where donor information was not 

recognized as a potential duplicate, causing various donor aggregates to be inaccurately 

reported. JSFP filed amended reports which corrected these errors. 

I Finding 5. Reporting of Expenditures A 

Summary 

During audit fieldwork, the Audit staff identified 

totaling $49,797 that JSFP failed to itemize as 

primary election totaling $314,673 were not 

expenditures, the purpose was not disclosed o 

reports filed subsequent to the audit notificatii 

itemization and disclosure errors. 

In response to the Preliminary Audit 1 

receiving clarification from the Audit 

able to identify all expenditures lacking ^ 

JSFP filed amended rei* :h coi 

Legal Standa. 

A. Reporting Operas^ 

person exceed $200 

• A 

• te when 

^ ^e and addi 

• n (a brief 

52 U. 

^j .^rnimary election 

addition^W' litures for the 

iosed. For ese 

y discloses ided 

corrected the 

indicated that, after 

Division staff, it was 

[equate descriptions. 

expenditures to the same 

committee must report the: 

^re made; 

ifand 

Sf why the disbursement was made—see below). 

'4(b)(5)(|| and 11 CFR §104.3(b)(4)(i). 

B. Examples 01 

• Adequate I . ons. Examples of adequate descriptions of "purpose" include 

the following dinner expenses, media, salary, polling, travel, party fees, phone 

banks, travel expenses, travel expense reimbursement, catering costs, loan 

repayment, or contribution refund. 11 CFR §104.3(b)(4)(i)(A). 

• Inadequate Descriptions. The following descriptions do not meet the requirement 

for reporting "purpose": advance, election day expenses, other expenses, expense 

reimbursement, miscellaneous, outside services, get-out-the-vote, and voter 

registration. 11 CFR §104.3(b)(4)(i)(A). 

C. Election Cycle. The election cycle begins on the first day following the date of the 

previous general election and ends on the date of the next general election. If 
17 

contributions and expenditures are designated for another election cycle, then the 

election cycle begins when the first contribution is received or expenditure is made. 

llCFR§100.3(b). 

Facts and Anal3r8is 

A. Facts 

During audit fleldwork, the Audit staffs review of all itemizable operating expenditures 

for the primary election identified the following. 

1. Ooeratinp Expenditures Not Itemized - There wer§j^%^.enditures totaling 

$49,797^' that JSFP failed to itemize on Schedu (Itemi^ 

Disbursements). 

2. Operating ExpendUures NotAdequatei 

disclose 166 expenditures totaling $3 

of the disclosure errors were 

inadequate purposes, such as "coiisuli 

fees", for operating expenditures. Othe 

payroll expenditures, dona with the failure 

to expenditures for reimbi^'' to indivii 

serf - JSP ot adequately 

i73 oil Schedule e majority 

it discing a purpo aiftclosing 

coJwsA labor'' and professional 

limed incorrectly reporting 

lose memo entries relating 

B. Preliminary Audit Repor -

At the exit conference held at the end of i 

expenditure reporting ^l^^^ubseqi 

schedules detailin 3 dis^^ncies. Ini 

amend its reports sei 

conference. 

ives of 

fAudit staff explained the 

f^rovided^^P representatives with 

, the JSFP representatives agreed to 

i'l additional comments during the exit 

itification 

n and disc 

^the Audit staff reviewed amended reports filed after 

id ^ ied that the amendments materially corrected both 

em ited above. 

The Prelim 

information or^ 

Vudit Re recommended that JSFP provide any additional 

coi Its that it considered relevant to this matter. 

C. Committee Res : to Preliminary Audit Report 

In response to the P^liminary Audit Report recommendation, JSFP indicated that, after 

receiving clarification from the Audit staff, it was able to identify and correct all 

expenditures lacking proper itemization or inadequate descriptions with the amended 

reports previously filed. 

" Of this amount, $45,200 is included in Finding 2, Misstatement of Financial Activity, as part of the 

adjustments for disbursements not reported. 
18 

Finding 6. Itemization of Candidate Loans 

Summary 

The Audit staff identified loans from the Candidate totaling $40,000 that had not been 

reported correctly by JSFP. Amended reports filed subsequent to the audit notification 

letter materially corrected the reporting of these loans. 

hi response to the Preliminary Audit Report recommendation, JSFP indicated that all 

issues with the itemization of these Candidate loans have been i 

Legal Standard 

A. Reporting Loans. All loans received by a commi 

A-P (Itemized Receipts) and continuously 

made on a loan must also be itemized. 11 C 

§104.11. 

4 

B. Schedule C-P. Both the original loan and p , 

reported each reporting period until the loan is 

following: 

• The source of the loan; and 

• The type of loan the candidate 

card, or home equity line of credi^it u 

guarantors with a.aiBtetion for loan 

candidate's 04.3(d' 

reps 

:a)(4)(ii 

mized on Schedule 

repayments 

i(iii) and 

principal^ust be 

"Tie committee must report the 

C. Schedule C-1.' i 

brokerar- nt,« 

nkloa erage account, credit 

for endorsers and 

"Loan Source" after the 

^obtains a]pE from an advance on the candidate's 

W" line of credit or other line of credit for 

'smnpaign, the candidate's principal campaign 

Dit, covering die period when the loan was 

fon Schedule C-1 or C-P-1: 

and ii^krest rate of the loan, advance, or line of credit; 

of the lending institution; and 

of collateral or other sources of repayment that secure the 

line of credit, if any. 11 CFR § 104.3(d)(4). 

Facts and Analysis 

A. Facts 

The Audit staff identified loans from the Candidate totaling $40,000 that were not 

itemized correctly by JSFP. On June 22,2012, JSFP received loans fiom the Candidate 

for the primary election in the amounts of $14,000 and $6,000 that were disclosed 

correctly on Schedule C-P but not itemized on Schedule A-P. In addition, on September 

11,2012, the Candidate made a loan for the general election in the amount of $20,000 

which was not itemized on either Schedules A-P or C-P. 
19 

It should be noted that the Audit stafTs bank reconciliation for 2012 determined that the 

Candidate loans totaling $40,000 discussed here were also not included in reported 

activity totals on the Detailed Summary Page of their respective reports (see Finding 2), 

B. Preliminaiy Audit Report Recommendation 

At the exit conference, the Audit staff provided JSFP representatives with schedules 

detailing these discrqrancies. In response, the representatives agreed to amend JSFP's 

reports. The representatives offered no additional coimnents during the exit conference. 

Subsequent to the exit conference, the Audit staff reviewed 

the audit notification letter and concluded that the loans from 

properly itemized on these amendments. 

The Preliminary Audit Report recommeiided that JSFP 

infomation or written comments that it considered 

C. Committee Response to Preliminary Aui 

In response to the Preliminary Audit Report 

issues with the itemization of these Candidate 1 

JSFP indica 

reports filed after 

idate were 

^ditional 

it all