Interim Audit Report of the 

Audit Division on the 

Communications Workers of 

America – COPE Political 

Contributions Committee 

(January 1, 2019 - December 31, 2020) 

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 met 

the threshold 

requirements for 

substantial compliance 

with the Act. 1 The audit 

determines whether the 

committee complied with 

the limitations, 

prohibitions and 

disclosure requirements 

of the Act. 

Future Action 

The Commission may 

initiate an enforcement 

action, at a later time, 

with respect to any of the 

matters discussed in this 

report. 

1 

 52 U.S.C. §30111(b). 

About the Committee (p. 2) 

Communications Workers of America – COPE Political 

Contributions Committee is a separate segregated fund – labor 

organization and lobbyist/registrant political action committee, 

headquartered in Washington, DC. For more information, see the 

chart on the Committee Organization, p. 2. 

Financial Activity (p. 2) 

• Receipts 

o Contributions from Individuals $ 8,884,026 

o Contributions from Other 

Political Committees 7,500 

o Refunds of Contributions Made 

to Political Committees 98,400 

Total Receipts $ 8,989,926 

• Disbursements 

o Operating Expenditures $ 784,482 

o Transfers to Affiliated/Other 

Party Committees 22,582 

o Contributions to Federal 

Candidates/Committees 5,222,523 

o Independent Expenditures 55,708 

o Contribution Refunds 948 

o Other Disbursements 5,236,445 

Total Disbursements $ 11,322,688 

Findings and Recommendations (p. 3) 

• Misstatement of Financial Activity (Finding 1) 

• Disclosure of Occupation and Name of Employer (Finding 2) 
 

 

Interim Audit Report of the Audit 

Division on the 

Communications Workers of 

America – COPE Political 

Contributions Committee 

(January 1, 2019 - December 31, 2020) 
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. Summaries 

Findings and Recommendations 3 

Part IV. Findings and Recommendations 

Finding 1. Misstatement of Financial Activity 4 

Finding 2. Disclosure of Occupation and Name of Employer 5 
1 

Part I 

Background 

Authority for Audit 

This report is based on an audit of the Communications Workers of America – COPE Political 

Contributions Committee (CWA), 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 52 U.S.C. §30111(b), 

which permits the Commission to conduct audits and field investigations of any political 

committee that is required to file a report under 52 U.S.C. §30104. Prior to conducting any audit 

under this subsection, 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. 52 U.S.C. §30111(b). 

Scope of Audit 

Following Commission-approved procedures, the Audit staff evaluated various risk factors and 

as a result, this audit examined: 

1. the disclosure of individual contributors’ occupation and name of employer; 

2. the consistency between reported figures and bank records; 

3. the completeness of records; 

4. the disclosure of independent expenditures; and 

5. other committee operations necessary to the review. 
 

 

2 

Part II 

Overview of Committee 

Committee Organization 

Important Dates 

• Date of Registration March 20, 1975 

• Audit Coverage January 1, 2019 - December 31, 2020 

Headquarters Washington, District of Columbia 

Bank Information 

• Bank Depositories One 

• Bank Accounts One checking 

Treasurer 

• Treasurer When Audit Was Conducted Sara Steffens 

• Treasurer During Period Covered by Audit Sara Steffens 

Management Information 

• Attended FEC Campaign Finance Seminar Yes 

• Who Handled Accounting and 

Recordkeeping Tasks 

Paid Staff 

Overview of Financial Activity 

(Audited Amounts) 

Cash on hand @ January 1, 2019 $ 3,252,122 

Receipts 

o Contributions from Individuals 8,884,026 

o Contributions from Other Political Committees 7,500 

o Refunds of Contributions Made to Political 

Committees 98,400 

Total Receipts 8,989,926 

Disbursements 

o Operating Expenditures 784,482 

o Transfers to Affiliated/Other Party Committees 22,582 

o Contributions to Federal 

Candidates/Committees 5,222,523 

o Independent Expenditures 55,708 

o Contribution Refunds 948 

o Other Disbursements 5,236,445 

Total Disbursements 11,322,688 

Cash on hand @ December 31, 2020 $ 919,360 
3 

Part III 

Summaries 

Findings and Recommendations 

Finding 1. Misstatement of Financial Activity 

During audit fieldwork, a comparison of CWA’s reported financial activity with its bank 

records revealed a misstatement of the beginning and ending cash on hand balances for 

calendar years 2019 and 2020. In 2019, CWA overstated its beginning and ending cash 

on hand balances by $244,198 and $222,357, respectively. In 2020, CWA overstated its 

beginning and ending cash on hand balances by $222,357 and $265,267, respectively. 

The Audit staff recommends that CWA amend its most recently filed disclosure report to 

correct its cash on hand balance. (For more detail, see p. 4.) 

Finding 2. Disclosure of Occupation and Name of 

Employer 

During audit fieldwork, a review of contributions from individuals requiring itemization 

indicated that 18,702 contributions, totaling $670,717, lacked or inadequately disclosed 

the required occupation and/or name of employer information. CWA did not sufficiently 

demonstrate “best efforts” to obtain, maintain and submit the required information. 

During audit fieldwork and in response to the exit conference, CWA provided “best 

efforts” documentation for 16,768 contributions totaling $597,808. However, CWA has 

not filed amended reports to disclose missing or inadequate information. To correctly 

disclose the required information, the Audit staff recommends that CWA amend its 2019-

2020 disclosure reports; file a Form 99 (Miscellaneous Electronic Submission); or file an 

amended memo Schedule A (Itemized Receipts) on its next regularly scheduled 

disclosure report listing all the contributions for which it received additional information. 

The Audit staff further recommends CWA provide “best efforts” documentation for the 

1,542 contributions totaling $55,185 or disclose the adequate occupation and/or name of 

employer information for these contributions; and provide any comments it deems 

relevant for the 392 contributions, totaling $17,724, for which “best efforts” notifications 

were sent untimely. (For more detail, see p. 5.) 
4 

Part IV 

Findings and Recommendations 

Finding 1. Misstatement of Financial Activity 

Summary 

During audit fieldwork, a comparison of CWA’s reported financial activity with its bank 

records revealed a misstatement of the beginning and ending cash on hand balances for 

calendar years 2019 and 2020. In 2019, CWA overstated its beginning and ending cash 

on hand balances by $244,198 and $222,357, respectively. In 2020, CWA overstated its 

beginning and ending cash on hand balances by $222,357 and $265,267, respectively. 

The Audit staff recommends that CWA amend its most recently filed disclosure report to 

correct its cash on hand balance. 

Legal Standard 

Contents of (Federal) Reports. Each report must disclose: 

• The amount of cash on hand at the beginning and end of the reporting period; 

• The total amount of receipts for the reporting period and for the calendar year; 

• The total amount of disbursements for the reporting period and for the calendar 

year; 52 U.S.C. §30104(b)(1), (2), and (4). 

Facts and Analysis 

A. Facts 

During audit fieldwork, the Audit staff reconciled CWA’s reported financial activity with 

its bank records for calendar years 2019 and 2020. This review indicated that, in 2019, 

CWA overstated the beginning and ending cash on hand balances by $244,198 and 

$222,357, respectively. In 2020, CWA overstated the beginning and ending cash on hand 

balances by $222,357 and $265,267, respectively. The cash on hand balance 

discrepancies for 2019 and 2020 resulted primarily from prior period adjustments, as well 

as, minor misstatements of both receipts and disbursements during the audit period. 

B. Interim Audit Report & Audit Division Recommendation 

The Audit staff discussed the misstatements for 2019 and 2020 with CWA’s 

representatives during the exit conference and provided schedules detailing the 

information. In response to the exit conference, CWA explained some of the minor 

misstatements of receipts and disbursement during the audit period, identified by the 

Audit staff. For example, CWA explained that it did not report an erroneous wire 

transfer. Additionally, CWA explained that several disbursements identified as 

‘unreported’ were actually reported but the check numbers on the bank statements were 

missing one or more digits due to possible scanning errors or data entry errors by the 

bank. CWA reviewed its records of the actual checks and matched the erroneous check 

numbers on the bank statements to the correct check numbers and provided a spreadsheet 

identifying the recipients of the checks and the date on which CWA reported them, which 
 

 

5 

the Audit staff verified. The spreadsheet also explained other immaterial receipt and 

disbursement misstatements, many of which stemmed from prior reporting periods. 

These discrepancies, however, did not resolve the misstated beginning and ending cash 

on hand balances. In fact, the explanations resulted in an increase in the overstatements 

of the 2019 beginning and ending cash on hand balances by $3,000 and $25,675, 

respectively, as compared to the misstated cash balances presented during the exit 

conference,2

 and did not affect the ending cash for 2020 which remained overstated by 

$265,267. In its response to the exit conference, CWA did not address or further explain 

the misstated beginning and ending cash on hand balances. 

The Audit staff recommends that, within 30 calendar days of service of this report, CWA 

amend its most recently filed disclosure report to correct the cash on hand balance with 

an explanation that the change resulted from the prior period adjustment. Further, CWA 

should reconcile the ending cash on hand balance of its most recent report to identify any 

subsequent discrepancies that may affect the adjustment recommended by the Audit staff. 

Finding 2. Disclosure of Occupation and Name of 

Employer 

Summary 

During audit fieldwork, a review of contributions from individuals requiring itemization 

indicated that 18,702 contributions, totaling $670,717, lacked or inadequately disclosed 

the required occupation and/or name of employer information. CWA did not sufficiently 

demonstrate “best efforts” to obtain, maintain and submit the required information. 

During audit fieldwork and in response to the exit conference, CWA provided “best 

efforts” documentation for 16,768 contributions, totaling $597,808. However, CWA has 

not filed amended reports to disclose missing or inadequate information. To correctly 

disclose the required information, the Audit staff recommends that CWA amend its 2019-

2020 disclosure reports; file a Form 99 (Miscellaneous Electronic Submission); or file an 

amended memo Schedule A (Itemized Receipts) on its next regularly scheduled 

disclosure report listing all the contributions for which it received additional information. 

The Audit staff further recommends CWA provide “best efforts” documentation for the 

1,542 contributions totaling $55,185 or disclose the adequate occupation and/or name of 

employer information for these contributions; and provide any comments it deems 

relevant for the 392 contributions, totaling $17,724, for which “best efforts” notifications 

were sent untimely. 

Legal Standard 

A. Itemization Required for Contributions from Individuals. A political committee 

other than an authorized committee must itemize any contribution from an individual 

if it exceeds $200 per calendar year, either by itself or when combined with other 

contributions from the same contributor. 52 U.S.C. §30104(b)(3)(A). 

2 

 The 2019 beginning cash on hand balance increase of $3,000 = $244,198 - $241,198; the 2019 ending 

cash on hand balance increase of $25,675 = $222,357 - $196,682. 
6 

B. Required Information for Contributions from Individuals. For each itemized 

contribution from an individual, the committee must provide the following 

information: 

• the contributor’s full name and address (including zip code); 

• 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 

• the calendar year-to-date total of all contributions from the same individual. 52 

 U.S.C. §30104(b)(3)(A) and 11 CFR §§100.12 and 104.3(a)(4)(i). 

C. Best Efforts Ensure Compliance. When the treasurer of a political committee 

shows that the committee used best efforts (see below) to obtain, maintain, and 

submit the information required by the Act, the committee’s reports and records will 

be considered in compliance with the Act. 52 U.S.C. §30102(i) and 11 CFR 

§104.7(a). 

D. Definition of Best Efforts. The treasurer and the committee will be considered to 

have used “best efforts” if the committee satisfied all of the following criteria: 

• All written solicitations for contributions included: 

 A clear request for the contributor's full name, mailing address, 

occupation, and name of employer; and 

 The statement that such reporting is required by Federal law. 

• Within 30 days after the receipt of the contribution, the treasurer made at least 

one effort to obtain the missing information, in either a written request or a 

documented oral request. 

• The treasurer reported any contributor information that, although not initially 

provided by the contributor, was obtained in a follow-up communication or 

was contained in the committee’s records or in prior reports that the 

committee filed during the same two-year election cycle. 11 CFR §104.7(b). 

E. Reporting Missing Information. If any of the contributor information is received 

after the contribution has been disclosed on a regularly scheduled report, the political 

committee shall either: 

• File with its next regularly scheduled report, an amended memo Schedule A 

listing all contributions for which contributor identifications have been 

received and an indication of the previous report(s) to which the memo 

Schedule A relates; or 

• File amendments which include the contributor identifications together with 

 the dates and amounts of the contributions. 11 CFR §104.7(b)(4)(i). 

Facts and Analysis 

A. Facts 

CWA did not disclose or inadequately disclosed the required occupation and/or name of 

employer information for contributions requiring itemization on its FEC reports, as of the 

date of the audit notification letter. 
 

 

 

 

7 

Contributions Requiring Itemization -

Missing or Inadequate Occupation and/or Name of Employer Disclosure 

Number of Contributions 18,702 

Dollar Value of Contributions $670,717 

Percent of Contributions 58% 

For contributions requiring itemization on Schedule A (Itemized Receipts), CWA 

disclosed the following 18,702 unacceptable entries totaling $670,717: 

• “Information Requested” or “N/A” for 18,373 contributions totaling $660,430 and 

• Inadequate occupation and/or name of employer for 329 contributions totaling 

$10,287. 

1. Contributor Information Obtained but Not Disclosed: 

During audit fieldwork, the Audit staff reviewed the contribution documentation 

provided by CWA to determine if it utilized the “best efforts” to obtain, maintain and 

submit the required disclosure information. The Audit staff identified 16,768 

contributions, totaling $597,808, for which CWA obtained the required contributor 

occupation and/or name of employer information but did not disclose the information: 

Contributor Information Obtained but Not Disclosed 

Contributor Information in CWA’s records at the Start of the Audit3 

Dollar Value of Contributions 

7,147 

$267,628 

Contributor Information Obtained from Untimely “Best Efforts” Letters4 

Dollar Value of Contributions 

505 

$18,733 

Contributor Information Obtained from Timely “Best Efforts” Letters5 

Dollar Value of Contributions 

159 

$6,256 

Contributor Information in CWA’s Records (no record of when the 

information was obtained)6 

Dollar Value of Contributions 

8,957 

$305,191 

Total Number of Contributions 

Total Dollar Value of Contributions 

16,768 

$597,808 

3 CWA’s receipt database for the audit period contained the occupation and name of employer information 

for 7,147 contributions totaling $267,628. 4 Based on mail merge files submitted by CWA in response to the exit conference. 

5 See supra footnote 4. 6 Based on an Occupation/Name of Employer Spreadsheet submitted by CWA in response to the exit 

conference. 
 

 

8 

2. Best Efforts Not Demonstrated: 

CWA did not provide the Audit staff records to document “best efforts” for the 

following: 

Best Efforts Documentation Not Provided by CWA 

Number of Contributions 1,542 

Dollar Value of Contributions $55,185 

Best Efforts Notification Sent Untimely by CWA with No Responses Obtained 

Number of Contributions 392 

Dollar Value of Contributions $17,724 

B. Interim Audit Report & Audit Division Recommendation 

The Audit staff discussed this matter with the CWA representatives during audit 

fieldwork and at the exit conference and provided the schedule detailing these disclosure 

errors. 

In its written response to the exit conference, CWA stated that it searched its 

contribution and membership records for the 2,1707

 individuals who lacked the required 

disclosure information, as identified by the Audit staff. Of the 2,170 individuals, CWA 

stated that it had “complete [occupation and name of employer] information for 1,7748 – 

7 

 CWA’s reference to 2,170 individuals is a reference to the number of contributors who made the 18,702 

contributions totaling $670,717 described in the first table on page 7 of this report; many of CWA’s 

contributors made multiple contributions. The Audit staff presented a schedule at the exit conference 

that detailed disclosure errors for 2,161 contributors that were not on the receipt database with complete 

occupation and name of employer information and nine contributors that were on the receipt database 

with complete occupation and name of employer information. These nine contributors did not have their 

occupation and/or name of employer information disclosed on the disclosure reports. 8 

 The 1,774 individuals CWA references appear to refer to a subset of contributors that make up the 16,768 

contributions, totaling $597,808, as described in the second table on page 7 of this report. Specifically, 

the 1,774 contributors CWA identifies appear to refer to contribution information obtained from timely 

and untimely “best efforts” letters, and contributor information in CWA’s records for which there was no 

record of when that information was obtained. This subset represents the records CWA provided to the 

Audit staff during fieldwork and represents 9,621 (505 +159 +8,957) contributions totaling $330,180 

($18,733+$6,256+$305,191). In addition to this, however, the Audit staff’s review also identified 

contributor information already in CWA’s records at the start of the audit, representing 7,147 

contributions totaling $267,628, as reflected in the first row of the table. Taken together, therefore, 

CWA did not disclose contributor information for 16,768 contributions totaling $597,808. Finally, 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

9 

more that 80% of the individuals whose contributions were identified as requiring “best 

efforts” documentation.” In response to the exit conference, CWA also provided the 

following documentation: 

1. Sample Best Efforts Letter – A sample "best efforts" letter which was also 

provided during audit fieldwork. 

2. Mail Merge Files – Mail merge files which contained the complete and adequate 

occupation and/or name employer information for 148 contributors who made 664 

contributions totaling $24,989.9  CWA did not submit the contributor information 

on its disclosure reports. 

3. Occupation/Name of Employer Spreadsheet – CWA provided a committee 

spreadsheet that included the occupation and name of employer information for 

1,598 contributors whose 8,957 contributions totaled $305,191.10 CWA did not 

submit the contributor information on its disclosure reports. 

CWA acknowledged that the additional information provided in response to the exit 

conference did not “constitute direct evidence that the Committee made “best efforts” to 

obtain missing information from all contributors during the audit period...” However, 

CWA believed that its record of outreach to the contributors named in the “mail merge” 

files and the fact that it obtained the complete information for the “overwhelming 

majority of contributors” identified during the audit, demonstrates its compliance with the 

Commission’s “best efforts” requirements. 

Additionally, CWA stated that it modified its procedures for documenting its “best 

efforts” to obtain missing occupation and name of employer information in early 2021. 

CWA has centralized the printing and mailing of all letters requesting the occupation 

and/or name of employer information through its in-house print shop. CWA explained 

that, during the audit period, each member of its compliance personnel team sent letters 

to the contributors whose contributions they had been assigned to process, whereas now, 

its compliance personnel create, on a monthly basis, one centralized list of missing 

occupation and/or name of employer information which is used to generate one file for 

letters to contributors. Bypassing its administrative divisions, CWA now sends these 

letters immediately after filing the monthly report. 

Based on contributor documentation provided by CWA during fieldwork and in response 

to the exit conference, CWA obtained the occupation and name of employer information 

although CWA refers in its response to “1,774” contributors, the Audit’s staff’s analysis shows that this 

number is actually1,746 contributors. 

9 Most of the 148 contributors made multiple contributions. 664 contributions totaling $24,989, consisted 

of 505 untimely “best efforts” letters ($18,733) and 159 timely “best efforts” letters ($6,256). See the 

Contributor Information Obtained but Not Disclosed chart on page 7. 10 Most of the 1,598 contributors made multiple contributions. 
 

 

 

 

10 

for a total of 16,768 contributions totaling $597,80811, however CWA did not submit the 

obtained information on its disclosure reports. 

To correctly disclose this information, the Audit staff recommends that, within 30 

calendar days of service of this report, CWA: 

• Amend its 2019-2020 disclosure reports; 

• File a Form 99 (Miscellaneous Electronic Submission)12; or 

• File an amended memo Schedule A (Itemized Receipts) on its next regularly 

scheduled disclosure report listing all the contributions for which it received 

additional information. 

The Audit staff further recommends that CWA provide documentation that would 

demonstrate “best efforts” for the 1,542 contributions totaling $55,185, and/or disclose 

the adequate occupation and/or name of employer information for these contributions 

using one of the methods outlined above. Lastly, the Audit staff recommends CWA 

provide any comments it deems relevant for the 392 contributions, totaling $17,724, for 

which “best efforts” notifications were sent untimely. 

11 See the Contributor Information Obtained but Not Disclosed chart on page 7. 12 If CWA chooses to file a Form 99, instead of amending its disclosure reports, the form must contain all 

pertinent information that is required on each schedule.