Why the Audit 

Was Done 

Federal law permits the 

Commission to conduct 

audits and field 

investigations of any 

political conmiittee 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 

committee complied with 

the limitations, 

prohibitions and 

disclosure requirements 

ofthe Act. 

Final Audit Report of the 

Commission on SEIU COPE 

(Service Employees International 

Union Committee on Political 

Education) 

January 1, 2007 - December 31, 2008 

About the Committee (p. 2) 

The SEIU COPE (Service Employees Intemational Union 

Conmiittee on Political Education) is a separate segregated fund of 

the Service Employees Intemational Union (SEIU) headquartered 

in Washington, DC. For more information, see chart on the 

Committee Organization, p 2. 

Financial Activity (p. 2) 

• Receipts 

o Contributions from Individuals 

o Transfers from Affihated Committees 

o Refunds from Federal Candidates 

o Other Receipts 

Total Receipts 

• Disbursements 

o Operating Expenditures 

o Contributions to Federal Candidates 

o Independent Expenditures 

o Other Disbursements 

Total Disbursements 

Additional Issue (p. 3) 

$15,973,115 

12,873,571 

13,500 

2,359,327 

$31,219,513 

$ 1,819,586 

2,868,450 

35,191,683 

7,525,177 

$47,404,896 

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

Commission on SEIU COPE 

(Service Employees International 

Union Committee on Political 

Education) 

January 1, 2007 - December 31, 2008 
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. Summary 3 

Part IV. Additional Issue 4 
Part I 

Background 

Authority for Audit 

This report is based on an audit of the Service Employees Intemational Union Committee on 

Political Education (SEIU COPE), 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 factors and as a 

result, this audit examined: 

1. the receipt of excessive contributions and loans; 

2. the receipt of contributions from prohibited sources; 

3. the disclosure of contributions received; 

4. the disclosure of disbursements, debts and obligations; ^ 

5. the consistency between reported figures and bank records; 

6. the completeness of records; and 

7. other committee operations necessary to the review. 

^ SEIU COPE complied with the recordkeeping requirements of 11 CFR § 102.903). The Audit staffs testing for the 

adequacy of reporting was limited for those independent expenditures made by SEIU on behalf of SEIU COPE 

(See Additional Issue). 
Part II 

Overview of Committee 

Committee Organization 

Important Dates 

• Date of Registration April 17,1972 

• Audit Coverage January 1,2007 - December 31,2008 

Headquarters Washington, DC 

Bank Information 

• Bank Depositories 2 

• Bank Accounts 4 

Treasurer 

• Treasurer When Audit Was Conducted Anna Burger/Gerald Hudson 

• Treasurer During Period Covered by Audit Anna Burger 

Management Information 

• Attended FEC Campaign Finance Seminar Yes 

• Who Handled Accounting and Recordkeeping Tasks Paid Stafif 

Overview of Financial Activity 

Cash on hand @ January 1,2007 $18,191,099 

o Contributions from Individuals 15,973,115 

o Transfers from Affiliated Committees 12,873,571 

o Refunds from Federal Candidates 13,500 

o Other Receipts 2,359,327 

Total Receipts $31,219,513 

o Operating Expenditures 1,819,586 

o Contributions to Federal Candidates 2,868,450 

o Independent Expenditures 35,191,683 

o Other Disbursements 7,525,177 

Total Disbursements $47,404,896 

Cash on hand @ December 31,2008 $ 2,005,716 
Part III 

Summary 

On May 5, 2011, the Commission considered a Proposed Final Audit Report which included a 

finding that, based upon a limited examination of the statements and reports filed and the records 

presented by SEIU COPE, the Audit stafif did not discover any material non-compliance. 

There were not the required four affirmative votes among the Commissioners to approve the 

finding. Pursuant to Directive 70, the discussion of this matter was included in the "Additional 

Issue" section of this audit report. 

Some Commissioners concluded that that additional reporting of certain funds was necessary. 

Other Commissioners concluded that SEIU COPE was in material compliance. 
Part IV 

Additional Issue 

Summary 

On May 5, 2011, the Commission considered a Proposed Final Audit Report which included a 

finding that, based upon a limited examination of the statements and reports filed and the records 

presented by SEIU COPE, the Audit staff did not discover any material non-compliance. 

There were not the required four affirmative votes among the Commissioners to approve the 

finding. Pursuant to Directive 70, the discussion of this matter was included in the "Additional 

Issue" section of this audit report. 

Some Commissioners concluded that that additional reporting of certain funds was necessary. 

Other Commissioners concluded that SEIU COPE was in material compliance. 

Legal Standard 

A. Reporting Independent Expenditures. Every political committee that makes independent 

expenditures must report all such independent expenditures on Schedule E in accordance with 11 

CFR § 104.3(b)(3)(vii). Political committees and other persons that make independent 

expenditures at any time during a calendar year—up to and including the 20^*^ day before an 

election—^must disclose this activity within 48 hours each time that the expenditures aggregate 

$10,000 or more. Political committees and other persons who make independent expenditures 

during the last 20 days—^up to 24 hours—^before an election, must disclose this activity within 24 

hours each time that the expenditures aggregate $1,000 or more. 11 CFR § 104.4(a), (b) and (c). 

B. Itemization of Independent Expenditures. When independent expenditures to the same 

person exceed $200 in a calendar year, the committee must report the: 

• Amount of the expenditures; 

• Date when the expenditures were made; 

• Name and address of the payee; and 

• Purpose ofthe expenditures. 2 U.S.C. § 434(b)(5)(A) and 104.3(b)(3)(vii). 

Facts and Analysis 

On May 5,2011, the Commission considered a Proposed Final Audit Report which included a 

finding that, based upon a limited examination of the statements and reports filed and the records 

presented by SEIU COPE, the Audit stafif did not discover any material non-compliance. 

Commission Conclusion 

On May 5,2011, at an Open Meeting, the Commission considered the Audit Division's Proposed 

Final Audit Report. There were not the required four affirmative votes among the 

Commissioners to approve the finding ofthe Audit Division. 

In the cover memorandum to the Audit Division's Proposed Final Audit Report, the Audit 

Division explained that during the 2008 election cycle, SEIU COPE transferred $14,427,267 to 

SEIU, its connected organization, which subsequently disbursed the funds to various payees on 
behalf of SEIU COPE. SEIU COPE reported the transfers as independent expenditures with the 

purpose of door-to-door voter ID and get-out-the-vote efiforts on behalf of Barack Obama or 

opposing John McCain. Records sufficient to support the disposition of the transferred funds 

were not reviewed by the Audit stafif. In its analysis of this information, the Ofifice of General 

Counsel considered the reporting to be adequate. 

Some Commissioners concluded that additional itemization and reporting of the ultimate payees 

of the independent expenditures was necessary, since the lack of itemization of these 

independent expenditures limited the Audit Division's ability to verify the dates ofthe public 

dissemination for the independent expenditures, the timeliness of any 24-hour or 48-hour notices 

filed, or the use of any proper disclaimers for any public communications contained in those 

expenditures. These Commissioners voted to reject the finding of the Audit Division. 

Other Commissioners concluded that SEIU COPE was in material compliance. Consistent with 

the recommendation of the Audit Division and advice of the Ofifice of General Counsel, they 

concluded that SEIU COPE complied with the applicable recordkeeping requirements, and that 

the Audit Division's examination of the statements and reports filed and the records presented by 

SEIU COPE was sufficient to support its recommendation. These Commissioners voted to 

approve the finding of the Audit Division, except with respect to the assertion that the Audit 

Division's examination of SEIU COPE's statements and reports was subject to a limitation. 

Pursuant to Directive 70, the discussion of this matter was included in the "Additional Issue" 

section of this audit report.