Report of the 

Audit Division on the 

Tennessee Democratic Party 

January 1, 2005 - December 31, 2006 

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 cojamnsaace 

with the A^WThe audit 

determin^^hether the 

commdll^^ramplied with 

the mnitaT 

prohibitions^ 

disclosure requloSBts 

of die Act. 

Future Actioi 

The Commission may 

mitiate an enforcement 

action, at a later time, 

with respect to any of the 

matters discussed in this 

report. 

About the Committee (p. 2) 

The Tennessee Democratic 

headquartered in Nashvi! 

chart on the Committee 

Financial Acti 

• Federal Receipts 

o Contributions froin 

o Contributions fronir 

o Transfers from Affiliated 

o Transfers 

o Other 

o Totalftder 

ll 

rating 

'ransfers toH^^i B Committees 

idependent^^plffilitures 

rdinated Party Expenditures 

1 Eleption Activity 

Otl^ttRDursements 

Tot«^ederal Disbursements 

^evin Receipts 

iCvin Disbursements 

Committees 

tees 

h Funds 

party committee 

information, see the 

$ 1,771,653 

234,775 

3,022,463 

797,430 

48,176 

$5,874,497 

$1,691,580 

211.950 

912,496 

712,459 

2,237,958 

160,981 

$5,927,424 

$319,869 

$319,869 

Lndings and Reconmiendations (p. 3) 

Non-allocable Federal Election Activity Disclosed on 

Schedule H6 (Finding 1) 

Disclosure of Disbursements (Finding 2) 

2U.S.C. §438(b). 
Report of the 

Audit Division on the 

Tennessee Democratic Party 

January 1, 2005 - December 31, 2006 
Table of Contents 

Part I. Background 

Authority for Audit 

Scope of Audit 

Part II. Overview of Committee 

Committee Organization 

Overview of Financial Activity 

Part III. Summaries 

Findings and Reconunendations 

Part IV. Findings and Recommendat 

Finding 1. Non-allocable Federal Election Activity xJisc 

Schedule H6 

Finding 2. Disclosure of Disbursements 

Page 
Parti 

Background 

Authority for Audit 

This report is based on an audit of the Tennessee Democratic Party (TDP), 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 au^it under this 

subsection, the Commission must perform an intemal r^ie30Lof repbrt^filed by selected 

committees to determine if the reports filed by a particUrar committee meet the threshold 

requirements for substantial compliance with the Act. ' 

Scope of Audit 

This audit examined: 

1. The receipt of excessive contributions and loans. 

2. The receipt of contributions from prohibited^^Ur^s. 

3. The disclosure of contributions received. / 

4. The disclosure of disbursements, debts and^blij^tii9ns.XJ| 

5. The disclosure of expenses allocatedrbetv^n feaeravnpn-federal, and Levin 

accounts. 

The consistency between rep(»fb4figures and\^aiiirfe6ords. 

The completeness of records./^ \ 

Other commiuee'^p^ttons necessaiy^i to the review. 
Part II 

Overview of Committee 

Coinmittee Organization 

Important Dates Tennessee Democratic Party 

• Date of Registration May 18,1983 

• Audit Coverage January 1,2005 - December 31,2006 

Headquarters Nashville, Tennessee 

Bank Information 1 V 

• Bank Depositories 

• Bank Accounts ' SiBven'^iJderal^ThieenoiiVFederal, 

/ / \ \ ^ 

Treasurer ^ \ \ 

• Treasurer When Audit Was Conducted ^ Chip FoiT^sibF-^ 

• Treasurer During Period Covered by Audijt^?-^ NRobert Tu ^ X^elainia Davis 

( ( / A \ ri y 

Management Information [ ^ / / \ 

• Attended FEC Campaign Finance/^enjinar' / ( 

• Used Commonly Available Cam^^gn I ^ 

Management Software Package v — 

• Who Handled Accduiitingaiul ^:iBa>rdkeepmg 

Tasks y Z \ ^ \ \^ ^^^^ 

y/^venofew)^^ Fhiancij 

y^Z\ (Audited Amoui 

Fed^raf^as^oii hand @ Janulai^ 1,2005 

Paid Staff 

Bd Activity 

Its) 

$128,779 

o Con&i)7utibiis from Indiviaiis^ls $1,771,653 

o Contribntidhs^om Othei^^blitical Committees 234,775 

0 Transfers irpm Affiliated Party Committees 3,022,463 

o Transfers frofh^Noriyfederal and Levin Funds 797,430 

0 Other Receipts) / 48,176 

Total Federal Receipts $5,874,497 

0 Operating Disbursements $1,691,580 

0 Transfers to Affiliated Committees 211,950 

o Independent Expenditures 912,496 

o Coordinated Party Expenditures 712,459 

o Federal Election Activity 2,237,958 

o Other Federal Disbursements 160,981 

Total Federal Disbursements $5,927,424 

Federal Cash on hand @ December 31,2006 

Levin Cash on hand @ September 26,2006 

$75,852 

$0 

Total Levin Receipts $319,869 

Total Levin Disbursements $319,869 

Levin Cash on hand @ December 31,2006 $0 
Part III 

Summaries 

Findings and Recommendations 

Finding 1. Non-allocable Federal Biection Activity 

Disclosed on Schedule H6 

A review of disbursements revealed that non-allocable fedif@l^l^k)n^tivity was paid 

with Levin funds and reported on Schedule H6 (Disbursements o: 

Funds for Allocated Federal Election Activity). Paym^s, totali; 

automated phone banks, and campaign rallies were all 

Levin. As a result, the Levin fund paid $77,674. Howe 

running for federal office was addressed in each of the 

response, TDP agreed that the automated phone banks were nl 

activity, but disagreed with the recommendation c^oncemine the 

rallies. (For more detail, see p. 4) 

Finding 2. Disclosure of Dis 

A sample review of itemized expenditj^pl reveal^ 

items tested TDP did not disclose ' 

reports that materially disclosed 

and Levin 

1, for polls, 

_ % 

learly idenlSmBAdidate 

pities/programs. In 

able federal election 

e campaign 

^proximately 18% of the 

ad(^^^yesponse, TDP filed amended 

inforH (For more detail, see p. 11) 
Part IV 

Findings and Recommendations 

Finding 1. Non-allocable Federal Election Activity 

Disclosed on Schedule H6 

Summary 

A review of disbursements revealed that non-allocable federal election activity was paid 

with Levin funds and reported on Schedule H6 (DisburseniCTteuO^ederal and Levin 

Funds for Allocated Federal Election Activity). Pavmenj!^lBBlii^tes^21. for polls, 

automated phone banks, and campaign rallies were allogated as 2i^^^ra l and 79% 

Levin. As a result, the Levin fund paid $77,674. How( 

miming for federal office was addressed in each of the 

response, TDP agreed that the automated phone banks wj 

activity, but disagreed with the recommendation concei 

rallies. 

Legal Standard 

A. Reporting Allocable Expenses betwee 

district, or local political party conm^tel 

election activity that is allocated b^peen Fed 

the category of Federal electio^Sivity for w 

made. 11 CFR §300.36(b)(2. 

B. Categories 

politicaL^arty committee 

Levio^mds for: 

^Registration Acti^ 

mtification; 

Get-^inhe-Vote Acti; 

ididate 

kivities/^S^^m^In 

^allocable CT^Rlection 

)lls and the campaign 

d Levin Funds. A State, 

sement for Federal 

and Levin funds must state 

allocable disbursement was 

Activity. A State, district, or local 

ursements between Federal funds and 

and 

Generic' lign Agility. 11 CFR §300.33(a)(l) and (2). 

C. CategoriesofNdnmocable Federal Election Activity. The following costs 

incurred by State^strict, and local party committees and organizations must be paid 

for only with federal funds: 

• A public communication that refers to a clearly identified candidate for federal 

office and that promotes, attacks, supports or opposes any candidate for federal 

office. llCFR§300.33(c). 

D. Coordinated Party Expenditures. National party committees and state party 

conunittees are permitted to piurchase goods and services on behalf of candidates in 

the general election—over and above the contributions that are subject to contribution 

limits. 
Such purchases are referred to as "coordinated party expenditures." They are subject 

to the following rules: 

• The amount spent on "coordinated party expenditures" is limited by statutory 

formulas that are based on the Cost of Living Adjustment (COLA) and the voting 

age population. 

• Party committees are permitted to coordinate the spending with the candidate 

committees. 

• The parties may make these expenditures only in connection with the general 

election. 

• The party committees—^not the candidates—are responsible for reporting these 

expenditures. ^ 

• If the party committee exceeds the limits on coord^^^ pmy/^penditures, the 

excess amount is considered an in-kind contribu(i!on, subj^ to the contribution 

limits. (V ^ \ 

• A national or state party committee may assign ^llor/^rt of its CQorainat.ea party 

spending authority to another party committee. X^.S.Q. §441 a(d) ai^dlJ/CFR 

§§ 109.32(b) and 109.33(a). ^ 

£. Assignment of Coordinated Party £xpenditul%^Limit. A pb^iti^^arty may 

assign its authority to make coordinated pafty~dxp endi [tures autl^zed by 11 CFR 

§109.32 to another political party committ|^. Such>W^iStsi^^ must be made in 

writing, must state die amount of th^auti^ty assigaedi am must be received by the 

assigned committee before any codra^ated p^y exppp^itures is made pursuant to 

assignment. 11 CFR §109.33(8r)^/ 

Facts and Anslysiar 

The Audit staffMipnt-ifiedmyi^nts, tdt£^^N$g^321, for polls, automated phone banks, 

and campaijgd!^allies. TDFisonsi^ered these ^penditures to be allocable federal election 

activity an^Uocated each payi^en\ as 21 federal and 79% Levin. As a result, the 

LevinidndXaid $77,674. 

The poll qu)E 

candidate for 

ed phone bank scripts both refer to a clearly identified 

ices for expenses associated with campaign rallies were 

tioiis^d the auto: 

ederal^pffice. ^ 

billed to the feder^cah(^a^e^ campaign but paid by TDP. It is the opinion of the Audit 

staff that these typesiNof expenditures, some of which appear to represent coordinated 

party expenditures, do^ot qualify as allocable federal election activity and should have 

been paid entirely b^nUie federal account. 

Polls - TDP paid $24,500 for two statewide tracking polls conducted during the period 

October 14,2006 through October 28,2006. Poll questions related to candidates running 

for election to the United States Senate and candidates for the Govemor of Tennessee. 

The majority of the questions related to the senate election. The cost of the polls can not 

be allocated between the federal account and Levin fund since both polls refer to a clearly 

identified candidate running for federal ofHce. As such, the cost should have been paid 

entirely by the federal account. The federal account should reimburse the Levin fimd 

$19,355 ($24,500x79%). 
Automated Phone Banks - TDP paid $36,400 for two automated phone bank programs. 

The phone scripts for both programs refer to a clearly identified candidate runnmg for 

federal office. As such, this cost can not be considered allocable federal election activity 

and paid for, in part, with Levin funds. The federal account should reimburse the Levin 

fund $28,756 ($36,400 x 79%). 

Further, the cost of this program appeared to represent coordinated party expenditures on 

behalf of Harold Ford, Jr., candidate for the United States Senate. The first phone script 

was narrated by the Govemor of Tennessee (Govemor Script), who was running for reelection. He asked for "your support and yoiu: vote." He also asked that "you support 

Harold Ford, Jr.", and continued to speak on his behalf He^^eabys^ing, "vote for 

me, Harold Ford, Jr., and all of our great democratic canjmSSSs nHM^for election." 

The script concluded with a second speaker stating, "pw for by t^^^messee 

Democratic Party" and "approved and authorized by HQ U Jr. fo^unessie.' 

fill Clinton'fSITnton 

you who hasn't 

Id Ford, Jr. to 

Heni^d by telling 

ith second speaker 

oved and authorized by 

The second phone bank script was narrated by former pi 

Script). He asked that "everyone go to the polls and take somS^ftiyith 

voted." He also stated that 'Tennessee has an histOEif chance 

the United States Senate," and continued talkii 

"everyone to go to the polls and vote." The 

stating, "paid for by the Teimessee Democn 

Harold Ford, Jr. for Teimessee." 

It appears diat die automated pho^Msgram wasl^^^ted with Harold Ford, Jr. for 

Teimessee (Ford Commiuee) siijl^^^^ler stated that the candidate approved and 

authorized each ijMiiW|MgirthcSBbpntracts for each phone bank program were 

signed by Jim^jDEterTr^re^^w TDP addresses at bodi TDP and at the 

candidateJi^rampaign headqu^^^were liSRon one of the contracts. Finally, prior to 

the date^^^ach contract, Mr. iMft: was onployed by the Ford Committee. 

The^Audif^^ghas allocated thcRbst of the Govemor Script one-third (Govemor), onethird (Harold^^^^.), and on^hird to all other (unnamed) candidates running for 

election. ThereH^n6.300i^8,900 x 33%) represented a coordinated expenditure on 

behalf of Harold j^^HMRuther, since Harold Ford, Jr. is the only candidate named in 

the Clmton Script, die^^re cost ($17,500) represents a coordinated expenditure on 

behalf of Harold Fordfjr. 

Campaign Rallies - The Audit staff identified payments, associated with 12 mvoices, 

totaling $37,421, which were dated in October 2006 and addressed to Harold Ford's 

campaign. The invoices denoted, "Bill to Harold Ford Jr." or "Prepared for Harold Ford 

for Senate Campaign" or "Sold to Harold Ford Jr. Campaign." Each disbursement was 

reported as get-out-die-vote activity and disclosed on Schedule H6 as allocable federal 

election activity. 
These payments do not appear to represent the cost of get-out-the-vote activities since the 

rallies appear to benefit Harold Ford, Jr. Therefore, the cost of this activity should have 

been paid entirely by the federal account. As such, the federal accoimt should reimburse 

the Levin fimd $29,563 ($37,421 x 79%). 

Further, the Audit staff believes these disbursements represent coordinated party 

expenditures on behalf of Harold Ford, Jr. As previously stated, the invoices contained 

notations as either billed to, prepared for, or sold to the Ford Committee. The invoices 

represented expenditures for Ford Committee rallies, such as, tents, staging, 

refreshments, audio, parking and clean-up. One invoice was for custom labeled bottled 

water - label name "Ford for Tennessee Bottled Water." Another invoice described the 

event name as a "Political Rally for Harold Ford, Jr." 

Coordinated Party Expenditure Limit - TDP's coordini 

State Senate candidate from die state of Tennessee was^ 

committee has the same limit; which was assigned to 

coordinated expenditures of behalf of Harold Ford, Jr. i: 

for a United 

TDP reported on Schedule F (Itemized Coordinat 

Party Committees or Designated Agent(s) on 

coordinated party expenditures on behalf of 

addition of the cost for the automated phon 

campaign rallies ($37,421), it appearedAit 

($773,680 - $724,400). Thenormalr|Bdy wou 

reimburse TDP $49,280. Howev Ale e the For 

excess campaign fimd^a^DP 

matter to be timek^^B^lniifiiuirms 

^y ExpeiiS^^^dade by Political 

andidates^^rederal Office) 

lin|$712,459. With die 

00 + $17,500]) and 

imitation by $49,280 

en for the Ford Committee to 

ittee transferred $154,000 in 

her 6,2006, the Audit staff considered this 

rther action. 

This matte 

the doci 

^s discussed at 

itation in order to 

it conf^nce. TDP representatives received copies of 

IT revi^ these issues. 

In responsB^^e exit conferenvthe former director of Tennessee Victory 2006 

submitted a s^Rtetatement dj^addressed four campaign rally invoices, totaling 

$17,401. Withn^^Lto eaajj^e stated Tennessee Victory 2006 expenditures were 

incorrectly invoicei^^^iRarold Ford Jr. campaign; the expenditures were related to 

get-out-the-vote activHR; activities were not planned or conducted in coordination with 

any federal candidatf^and, no federal candidates attended diese events. The response 

did not address the polls or automated phone banks. 

Two of the invoices addressed in the response, Jackson Centre ($1,522) and Royal Reed 

Catering (Jackson Centre Menu - $8,120) contained references to Harold Ford, Jr. The 

Jackson Centre invoice referred to the event name as "Political Rally for Harold Ford, 

Jr." The Royal Reed Catering invoice "order info" section appeared to have had Harold 

Ford, Jr.'s name on the first line but that information had been redacted. 
Interim Audit Report Recommendation 

The Audit staff recommended that TDP demonstrate that expenditures: 

• For polls, automated phone banks, and campaign rallies represented allocable 

federal election activity; or 

Absent such evidence, the federal account should have reimbursed the Levin Fund 

$77,674 (polls $19,355, automated phone banks $28,756, campaign rallies 

$29,563) and filed amended reports disclosing the expenditures on Schedule B or 

Schedule F as appropriate (see below). 

• For automated phone banks and campaign rallies di^^t rc^ipjspm. coordinated 

party expenditures on behalf of Harold Ford, Jr.'"Jor ' 

Absent such evidence, TDP should have filed amend^d^ports a^clbsing/j 

expenditures for the automated phone banks $23^00 i^6,300 + $17> .500} ahd 

campaign rallies ($37,421) as coordinated party<^c^iandihires on Schedtile F. 

Committee Response to Recommendation and AudU Stiff's 

Assessment //"N , JX 

In response. Counsel for TDP (Counsel) stat^^ //^^N^^ ^ 

Polls - Counsel acknowledged that the'S^t of 1he/nolls slrould not have been reported on 

Schedule H6 but indicated this co^xshduld have fa|eenj:ep^rted on Schedule H4 

(Disburseinents for Allocated Federali^onfederal AQtLvity); as shared operating 

expenditures. Counsel-furth^ stated, thbvtracking polls were conducted to get a sense of 

issues and voting-^ids^base^n genb^ ^llin&principals; the polls did not promote, 

support, attap^!^^^oppose an^fed^ral candid^Pthe polls did not constitute generic 

campaigi^^tivity; the polls did notconsti^te voter registration activity; the polls did not 

constitjLtte get-out-the-vote activity; and, most importantly the polls did not constitute 

vot^:^e^tifibarion activity. Toip amended its reports to reflect die cost for the polls on 

Schedule H^all^^ting $5,145yi[2i %) to the federal account and $19,355 (79%) to die 

non-federal accountv / / 

It remains the opmlbn of me Audit staff that the cost of the polls represented federal 

election activity that shpuld have been paid solely by the federal account and not 

allocable as a sharediactivity. The telephone interviews of 1,000 likely voters occurred 

(in October 2006) within the FEA time frame; represented a public communication that 

referred to a clearly indentified candidate for federal office that promotes, attacks, 

supports or opposes such candidates. 

Bodi polls referred to clearly identified candidates running for federal office. Among the 

questions asked of callers were: if they favored either of the federal candidates; whether 

they would vote for a certain federal candidate if the election were held today; their 

opinion of attack ads against one of the federal candidates; and their opinions of various 

positions of each federal candidate. 
Automated Phone Banks - Counsel acknowledged that the automated phone calls 

included advocacy for a Federal candidate and should not have been disclosed on 

Schedule H6. TDP filed amended reports to disclose 50% of the cost of the Govemor 

Script on Schedule B ($9,450) and 50% on Schedule F. The entire cost of die Clinton 

Script was disclosed on Schedule F. According to Counsel, it is TDP's belief that, 

despite their disclosure on Schedule H6, no allocation transfer was made in connection 

with these expenditures. 

The Audit staff and Counsel agree that the expenditures were coordinated and reportable 

on Schedule F, although TDP has concluded diat 50% of the cost of the Govemor's 

Script represents coordinated spending, whereas, the Au^tttsi^ cph^^d a lesser 

percentage (33%). As previously stated, the Audit stafC^l'Iocated the cost of the 

Govemor's Script on a 1/3 basis since the script concluo^ "vote|0^i^^;ne^^^old Ford, Jr., 

and all of our great democratic candidates running for Mebtio)^TherefOTe>we aflo""'" 

1/3 of the cost to each die Govemor, Harold Ford, Jr. aim^l d^ier democr^ticteEl^ai 

running for election. The TDP's allocation is also acceptable. 

ocated 

idates 

Campaign Rallies - Counsel stated that TDP beli^v-ed die invoice^pre^^ted generic 

campaign activity; that it was not uncommon fe^«^dbrs to confuse ^party organization 

with the campaign of a candidate; and, that the invoicjgs were incoi^ctly sent to the 

Harold Ford campaign. The response also incmded4 deelarati^ from the Director of 

Tennessee Victory 2006, a project of theTFeimesseefe^ Party.^ He attested that 

of the twelve invoices, eleven were^Qorrectly involoeiTO'the Harold Ford campaign. 

TDP agreed that the remaining iiwoio^for custoni-Tlab^ea bottled water was a 

coordinated expenditurejind ainpiid^ jtsjreports to disclose this expense on Schedule F. 

The followin ect to^e rt^voices in question: 

The Jacksoii Centre and Royal Reed Catering invoices. The Jackson Centre invoice 

mdic^ie(Hn^ee places that thejevjent was a "Political Rally for Harold Ford Jr." The 

client name^at;ontact person noted on the invoice was also named in reports filed by 

the Ford Committfee^s receiviiM^avel reimbursements in October and November 2006;^ 

the same time fraime^sJheA second Jackson Centre invoice indicated 

technical/productibi\|s6rVi^ for: Harold Ford Jr. The Royal Reed Catering 

invoice, which representdd the menu for the event, had "For Harold Ford Campaign" 

redacted. 

Jason's Deli - There were three invoices. The name Harold Ford was redacted on one 

invoice. The other two invoices were billed to Harold Ford, Jr. at a Memphis, Tennessee 

address. Further, the Ford Committee reported a payment to Jason's Deli on September 

13,2006. The reported purpose was "Food for Campaign Event." 

This individual also submitted a similar declaration in response to the exit conference. That declaration 

only addressed invoices firom four of the vendors. 

This individual was also disclosed in reports filed by TDP as receiving travel reimbursements. 
10 

Grand Events & Party Rentals - This invoice was addressed to Harold Ford, Jr. 

Campaign at a Memphis, Tennessee address (same as Jason's Deli). TDP' is located in 

Nashville, Teimessee. 

STC - Memphis, Inc. - Four invoices were billed to Harold Ford Jr. for US Senate at the 

same Memphis address discussed above. On three of the invoices, Harold Ford, Jr. for 

US Senate had been crossed out. 

The Memphis, Teimessee address is for the Park Place Center that rents office 

space. The Ford Committee, located at different address in Memphis, disclosed 

this mailing address on Schedule B (Itemize Disbursements) for at least two 

individuals who received airfare reimbursements. This addfess) wpsiip^ecorded 

in TDP's electronic files. 

Little Porky's - The invoice contained the following: 

Harold Ford Jr." 

Victor Chatman Productions - This invoice indicated sold to *^I^arbld Ford Jr. 

Campaign." Description - "Harold Ford Jr. Campai^ Rally at S^^in^^^fne Golf Range 

on October 14,2006." 

W.C. Hunter - This invoice indicated that thfe vendOT^ul^ sandwiches for the 

"Harold Ford, Jr., Campaign on Saturd^y^Octooe/14, 20p6.^t should also be noted that 

the invoice for the Ford for Tennessee hdttled waier-^s-delivered to a location on 

October 14,2006. / \ 

Southem Rents &'^lflJ--T£e^ had been redacted. 

B & B Clea^^^endces^^ sold to "Ford's." 

Based-on the^ove it does not apppr as if the vendors mistakenly invoiced the Ford 

Committees(mstead of die TDP)[ The vendors use of die phrases - Political Rally for 

Harold ForcUt - Rar Harold F)9ja Campaign - Family BBQ for Harold Ford Jr. - Harold 

Ford Jr. Campaign Rklly aiding Time Golf Range on October 14,2006 - Harold Ford, 

Jr., Campaign on Siuirdh^October 14,2006, as well as, three vendors used a billing 

address that the Ford Cpimnittee also disclosed on its reports supports the conclusion that 

the above events benefited the Ford Committee. Therefore, it is die opinion of the Audit 

staff diat the payments, for diese events, by TDP represented coordinated party 

expenditures that should have been disclosed on Schedule F. 

TDP's assertion that the Levin Fund may not have made a transfer of funds for the 

automated phone bank cost could be coirect and also applicable to the cost of the polls 

and campaign rallies. TDP reported on Schedule H6 shared activity totaling $715,056; 

die Levin Fund portion being $564,894 ($715,056 x 79 %). However, die Levin Fund 

reported only $319,399"^ in transfers to the federal account for its portion of shared 

TDP reported Levin Fund receipts and disbursements totaling $319,869. 
11 

activity. It is not possible to determine specifically which expenses were reimbursed. 

Therefore, unreimbursed Levin activity totaled $245,495 ($564,894 - $319,399); diat 

amount was paid by the federal account. The overpayment by the federal account is 

greater than the Levin activity in question ($77,673) and eliminates the need for any 

reimbursements to the Levin Fund for the cost of the automated phone banks, poll, or 

campaign rallies. 

Conclusion 

TDP filed amended reports that disclosed the cost of automated phone banks on Schedule 

F. However, it remauis the opinion of the Audit staff that the cost of the polls should 

have been disclosed on Schedule B and the cost of campaign rallies should have been 

disclosed on Schedule F; they were not. 

I Finding 2. Disclosure of Disbursements 

Summary // \ \ — 

A sample review of itemized expenditures revealed that^or approximately 18% of the 

items tested TDP did not disclose the payees' address. In respor^e^T^DP^led amended 

reports that materially disclosed the missing infornSation. 

Legal Standard 

Reporting Operating Expenditures. Whei^^eratihg expenditures to the same person 

exceed $200 in a calendar year, die c^impittee mii4(repoi;:{/dief 

• Amount; 

• Date when the expenditi^s^dre made; 

• Name andaddress pf:;die payee; ahd 

• Purpose'^a-tSi^dej^cri^^^ of wSy^he-^fsbursement was made). 2 U.S.C. 

§4WbX5)(A) and lVgra\§lO4.3(^))j0)(i). 

Factf^mdNAnalsrsis 

A s^ple^review of itemized expenditures revealed that for 18% of the items tested, TDP 

did not disclo^ me^ayees' addijsss. The majority of the disbursements lacking 

addresses relatbdjtpl^anvasser^^ mailing address was noted in TDP's records. This 

issue was discussec(^diiring^the exit conference. TDP representatives had no significant 

comments. 

Interim Audit Report Recommendation and Committee's Response 

The Audit staff recommended diat TDP file amended reports to disclose the missing 

information. In response. Counsel wrote that they have, "engaged extensive efforts to 

locate the missing information and will file amendments to include the address[es] which 

it has located." TDP filed amended reports that materially disclosed the missing 

information.