Draft Final Audit Report of the 

Audit Division on the 

Democratic Party of Wisconsin 

(January 1, 2011 - December 31, 2012) 

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 haye'met ... 

the threshold 

requirements for 

substantial compliance 

with the Act" The audit-, 

determines whether the 

committee complied.with 

the limitations, " 

prohibitions..jnd 

disclosure' requirements 

of the Act. ' . • ' .x. 

Future Actidh \ 

The Commission may \ 

initiate an enforcement 

action, at a later time, 

with respect to any of the 

matters discussed in this 

report. 

About the Committee (p. 2) 

The Democratic Party ofWisconsin is a state party committee 

headquartered in Madison, Wisconsin. For more information, see 

the chart on the Committeq^Qrganization, p. 2. 

Financiai^ctivity (p. 2) 

. ReceiptsSX ^ 

o Contribut|MS f^m Individuals 

j'Oj . Contribution^from'l^olitical 

. V. Committees \ 

''oS^TTa^Ters from Affiliated and 

\' Other Polilicjl Comrnittees 

o XTransfer^froitfNqn-^'d^l 

Accounts 

' o Other'Receipts 

; Total Receipts 

\ 

}• J 

Operating-Expenditures 

\o Contributions to Other Political 

' .. Committees 

b. Transfers to Affiliated and Other 

Political Committees 

o Federal Election Activity 

o Other Disbursements 

Total Disbursements 

$ 6,744,785 

2,692,509 

8,676,624 

1,400,151 

484,290 

S 19,998,359 

$ 11,536,529 

25,500 

51,261 

7,991,072 

159,088 

$ 19,763,450 

Findings and Recommendations (p. 3) 

• Misstatement of Financial Activity (Finding 1) 

• Recordkeeping for Employees (Finding 2) 

On September 1,2014, the Federal Election Campaign Act of 1971, as amended ("the Act"), was 

transferred from Title 2 of the United States Code to the new Title S2 of the United States Code. 

^ 52 U.S.C. §30! 11(b) (formerly 2 U.S.C. §438(b)). 
Draft Final Audit Report of the 

Audit Division on the 

Democratic Party of Wisconsin 

(January 1, 2011 - December 31, 2012) 

\\ 

\ \ 

V-
Table of Contents 

Page 

Part I. Background 

Authority for Audit 

Scope of Audit 

Commission Guidance 

Part II. Overview of Committee 

Committee Organization 

Overview of Financial Activity 

- \ / • / 

Part III. Summaries 

Findings and Recommendations 

^ 

Part IV. Findings and Reco^inendations 

Finding 1. Misstatement of Financial Activity^. / 

Finding 2. Recordkeeping for Employees 

f X \ • -

A -i 

•• V:. ,/ 

2 

2 

4 

7 
Part I 

Background 

Authority for Audit 

This report is based on an audit of the Democratic Party of Wisconsin (DPW), 

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 S2 U.S.C. §30111(b) (formerly 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 S2 U.S.C. 

§30104 (formerly 2 U.S.C. §434). Prior to conducting'any^dit under this subsection, 

the Commission must perform an internal review of reports filed by selected committees 

to determine whether the reports filed by a pardculaLc^mi^it^e meet the threshold 

requirements for substantial compliance with'the^ct. 52 U.S.C.Y30111(b) (formerly 2 

U.S.C. §438(b)). / / 

^ \ Scope of Audit \ \X 

Following Commission-approve^ procedures, the Audit staff evaluated vari^ risk 

factors and as a result, this audit examined: 

1. the disclosure of individual contributor' occupation and name of employer; 

2. the disclosure of disbursements, debts and Obligations; . 

3. the disclosure of expenses allocated between federal and non-federal accounts; 

4. the consistency between reported figures and bank records; . -

5. the completeness of records; and - , ' " ... X 

6. other committee operations necessary to the review. 

Commission Gui^nce 

R^uest for Early CommissioI^Consideratlon of a Legal Question 

Pursuant to the Commission's "Policy Statement Establishing a Program for Requesting 

Consideration of Legal Qqestions by^he. Commission," several state party committees 

unaffiliatedovith DPW requested early-consideration of a legal question raised during 

audits covering the 2010 election cycle. Specifically, the Commission addressed whether 

monthly time logs under 11 'CFR § 106.7(d)(1) were required for employees paid with 100 

percent federal furid^^ .../ / 

The Commission concluded, by a vote of 5-1, that 11 CFR § 106.7(d)(1) does require 

committees to keep a monthly log for employees paid exclusively with federal funds. 

Exercising its prosecutorial discretion, however, the Commission decided it will not 

pursue recordkeeping violations for the failure to keep time logs or to provide affidavits 

to account for employee salaries paid with 100 percent federal funds and reported as 

such. The Audit staff informed DPW representatives of the payroll log requirement and 

of the Commission's decision not to pursue recordkeeping violations for failure to keep 

payroll logs for salaries paid and correctly reported as 100 percent federal. This audit 

report does not include any findings or recommendations with respect to DPW employees 

paid with 100 percent federal funds and reported as such. 
Part II 

Overview of Committee 

Committee Organization 

Important Dates 

• Date of Registration April 21,1975 

• Audit Coverage January 1,20U - December 31,2012 

Headquarters Madison/Wiscbnsin 

Bank Information /. ;• 

• Bank Depositories Tw> . 'X \ 

• Bank Accounts Twelve Federal, Two Non-federal 

Treasurer 

• Treasurer When Audit Was Conducted Michael F. Childers-, :• 

• Treasurer During Period Covered by Audit . Michael F. Childers •.. • \ 

Management Information \ .v. 

• Attended Commission Campaign Finance 

Seminar 

Yes . •• • 

• Who Handled Accounting and ^ " 

Recordkeeping Tasks \ x'-\ Overview of Fini 

\\ NAudited A \ -v ) I. \ 

^id Staff^x^ 

ancial Activity 

inounts) 

Cash-on-haii'd ^January4,2dll.— $ 53,631 

Receipts " - ^ \ \ \> 

o Contributions from' Individuals, \ ' / 6,744,785 

o Contributions from Political Comipiltees 2,692,509 

o Transfers from Affiliated and OtherPolitical 

Committees 8,676,624 

o Transfers from.T^on-federal Accounts 1,400,151 

o Other Receipts 484,290 

Total Receipts S 19,998,359 

Disbursements 

o Operating Expenditures 11,536,529 

o Contributions to Other Political Committees 25,500 

o Transfers to Affiliated and Other Political 

Committees 51,261 

o Federal Election Activity 7,991,072 

o Other Disbursements 159,088 

Total Disbursements S 19,763,450 

Cash-on-hand @ December 31,2012 $ 288,540 
Part III 

Summaries 

Findings and Recommendations 

Finding 1. Misstatement of Financial Activity 

During audit fieidwork, a comparison of DPW's reported financial activity with bank 

records revealed a misstatement of receipts and disbursements for 2011 and 2012. For 

2011, DPW understated its receipts by $169,196 and its,disbursements by $184,702. In 

2012, DPW overstated its receipts by $402,707 and its disbursements by $381,326. In 

response to the Interim Audit Report recommendation,,DRW'amended its disclosure 

reports to materially correct the misstatements/iotra-above. ^ 

(For more detail, see p. 4.) 

Finding 2. Recordkeeping for ^nployees 

During audit fieidwork, the Audit staff determitiMvthat DPW did not miii^in any 

monthly payroll logs, as requiredfto^document thej)erdentage of time eacl^^^loyee 

spent in connection with a federal election. For 20 M^and 2012, the Audit staff identified 

payments to DPW employees tota1ing^$3.,627,262, for whteh^DPW did not maintain 

monthly payroll logs. This consisted^of $2,191,5^ for wlnch^ayroll was allocated with 

federal and non-federal-funds, and $l,434,70Cfor which payroll^^as exclusively nonfederal. In response to the Interim Audit Report i^cominendationf, DPW acknowledged 

the need to improve.its systerh of maintainiifg monthly tim^logs. As a result, DPW 

developed a web-basdd system^fo'r employees to track time associated with federal 

election activity. (For.more detail, see p. 7.) . • •. H/ ' S. ». \ . 

% . 

v.. \ • \ \\ x:\. 

V. 

; I /• 
Part IV 

Findings and Recommendations 

I Finding 1. Misstatement of Financial Activity 

Summary 

During audit fieidwork, a comparison of DPW's reported financial activity with bank 

records revealed a misstatement of receipts and disbursements for 2011 and 2012. For 

2011, DPW understated its receipts by $169,196 and its djslnirsements by $184,702. In 

2012, DPW overstated its receipts by $402,707 and its disbursements by $381,326. In 

response to the Interim Audit Report recommendation, DPW amended its disclosure 

reports to materially correct the misstatements note^ abo^ve.\^ 

Legal Standard , 

Contents of Reports. Each report must disclose: N. 

• the amount of cash-on-hand at the beginhiiig and end gf the repoitii^-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; 

and \ 

• certain transactions that requirejtemization on SchedulcsA (Itemized Receipts) or 

Schedule B (Itemized Disbursements). "5210.8.0. §30104(b)(1), (2), (3), (4) and (5) 

(formerly 2 U.S,G. §434(b)(l), (2),^), (4) a>d (5))., ^ 

\ \ 

Facts and Analysis ^ \ 

A. Facts \ \ y' 

As part of audit fieldw6rk,"the Audit, sthff reconciled DPW's reported financial activity 

with its bank records^for 2011 a^id 20l2-...fhe.recohciliation determined that DPW 

miisstated receipts and ^isburse^nts for 2b I Land 2012. The following charts outline the 

discrepancies betweeh^pP)V's disclosure reports and its bank records, and the succeeding 

paragraphs explain why the discrepancies occurred. 

2011 Committee Activity 

Reported Bank Records Discrepancy 

Beginning Cash Balance @ 

January 1, 2011 

$56,862 $53,631 $3,231 

Overstated 

Receipts $3,758,853 $3,928,049 $169,196 

Understated 

Disbursements $3,497,621 $3,682,323 $184,702 

Understated 

Ending Cash Balance @ 

December 31,2011 

$316,089' $299,357 $16,732 

Overstated 

^ DPW miscalculated its ending cash balance. It should have been $318,094 (a diflerence of $2,DOS). 

Using the correct ending cash balance ($318,094), the discrepancy is $18,737. 
The beginning cash balance was overstated by $3,231 and is unexplained, but likely 

resulted from prior-period discrepancies. 

The understatement of receipts resulted from the following: 

• Transfers from non-federal accounts, not reported 

• In-kind contributions, not reported as receipts 

• Vendor refund, not reported 

• Vendor refunds reported as negatives 

• Interest, not reported 

• Political committee and individual contributions, 

not reported. 

• Reported refunds and contributions not supported by a credit 

or deposit 

• Unexplained differences • N ' 

Net Understatement of Receipts / } 

\ 

-1- $35,130 

+ 2,565 

+ 9,198 

+ 57,545 

+ 145 

+ 73,851 

. 9,260 

+ 22 

+ S16?,196 

The understatement of disbursements resiilted-from the following: 

• In-kind contributions, not reported as'disbursem^ 

• Vendor refunds reported negatives^ 

• Transfers to non-federal'accounts, not repo 

• Disbursements and fees, riot rtporfed.^ 

• Reported disbursements no^suppofte4^by-^checl^or debit 

• Vendor feeSj,not reported \A "V \\ 

• Unexplained differences \ 

NetUnderstatemeiito^DisbursemehtS/'^ ^ v./ ^ S18IJ02 

The $16,732 overstatement of the ending cash balance resulted from the misstatements 

described above, as well as from a $2,005 mathorriatical discrepancy in calculating the 

ending cash balance. . -' 

2012 Committee Activity . . * 

«, Reported Bank Records Discrepancy 

Beginning Cash Balance . 

@January 1,2012 / 

$316,089 $299,357 $16,732 

Overstated 

Receipts . / 

/ 

$16,473,017 $16,070,310 $402,707 

Overstated 

Disbursements $16,462,453 $16,081,127 $381,326 

Overstated 

Ending Cash Balance @ 

December 31,2012 

$290,921=* $288,540 $2,381 

Overstated 

* DPW repotted vendor refunds as negative entries on Schedule B (Itemized Disbursements). Unless the 

refund is for allocable federal and non-federal expenditures or allocable federal and Levin expenditures, 

the refund should be reported as an ofhet to operating expenditures on Schedule A (Itemized Receipts). 

' DPW miscalculated its ending cash balance. It should have been $326,654 (a difference of $35,733). 

Using the correct ending cash balance ($326,654), the discrepancy is $38,114. 
+ $15,312 

+ 9,186 

+ 1,000 

+ 22,310 

+ 31,270 

- 43,160 

- 457,814 

+ • 19.189 

-

The overstatement of receipts resulted from the following: 

• Vendor refunds reported as negatives 

• In-kind contributions, not reported as receipts 

• Contribution from a political committee, not reported 

• Transfers from non-federal accounts, not reported 

• Transfers from the National Party, not reported 

• Incorrectly disclosed transfers from non-federal accounts 

• Contributions from joint fundraisers reported twice 

• Unexplained differences 

Net Overstatement of Receipts 

Regarding the $457,814 in contributions from joint ^ti^isers reported twice, the Audit 

staff noted the following. In its October 2012 montlilv rep^^ DPW correctly reported 

transfers from two joint fundraiser representatives on'ScheduIe^^CItemized Receipts). 

DPW also reported the contributions from the'individuals received^at these joint 

fundraising events. However, DPW shou!d1)nly1have reported tl^e.^n^ributions from the 

individuals as memo entries. As a result of.reporting both the transfer^ofLtotal 

contributions received from the joint fundraisei^and each of the contri^butions from the 

individuals, DPW overstated the receipts it received from these joint fundraising events. 

The overstatement of disbursement-resulted from the following: 

• Vendor refunds reported as negatives ' . + $15,312 

• Transfers to non-federal accounts, not repphed^ ' "*• 27,179 

• In-kind contributions; not reported as disbursements ' . + 9,186 

• Duplicate reported paytnents to vendor , - 514,424 

• Unexplained differences • + 81.421 

NetOverstateiiiento/'DisbursementN - S381.326 " -• • • - •' • \ Regardingthe $5.I 4;424 in duplicate reported-payments, the Audit staff noted the 

reportin'g errors reIate^"to a singlb>yendor tHat.]mduced mailers for DPW. Also, all three 

duplical&..^orted disbu^emenfs.wec^ported in the 2012 Pre-General report. 

The $2,38Toveretatement of the endmg^cash balance resulted from the misstatements 

described abbve,''as well as from a $35,733 mathematical discrepancy in calculating the 

ending cash baianM^^ j j 

B. Interim Audit Report & Audit Division Recommendation 

The Audit staff discuss^'the misstatement of disbursements with DPW representatives at 

the exit conference. DPW representatives asked questions for clarification and said they 

would respond after having time to thoughtfully review each issue. The Audit staff 

provided work papers detailing the misstatement of receipts to DPW representatives after 

the exit conference. DPW did not provide a response to either the disbursements or 

receipts misstatements. 

The Interim Audit Report recommended that DPW amend its disclosure reports to correct 

the misstatements noted above and reconcile the cash balance on its most recent report to 

identify any subsequent discrepancies that could affect the recommended adjustments. 
The Interim Audit Report further recommended that DPW adjust the cash balance as 

necessary on its most recent disclosure report, noting that the adjustment was the result of 

prior-period audit adjustments. 

C. Committee Response to Interim Audit Report 

In response to the Interim Audit Report recommendation, DPW amended the disclosure 

reports to materially correct the misstatements. 

Counsel explained that while DPW does not contest the discrepanies identified by the 

auditors as part of the misstatement finding, the nature of these discrepancies in many 

cases involved the form of the disclosure provided, not ite^stance. Counsel 

specifically commented on the recommended reporting^'adjusfments of the Audit staff 

concerning vendor refunds and joint fundraising contfibutioijs. For example, DPW 

reported vendor refunds as negative entries on Sch^ule B'(Itemized Disbursements) 

instead of as offsets to operating expenditures oh Schedules A. (Itemized Receipts) as 

recommended by the Audit staff. With respect to reporting adjustments for joint 

fundraising contributions. Counsel stated that the error in reporting occurred because the 

wrong box was selected in the campaign finance reporting.software used^o prepare its 

reports. Counsel further added that these contributions were, reported to^'the'Commission 

on a timely, individualized basis, even if its cash position was incorrect duetto the 

reporting error. , \ 

In response, the Audit staff would Hke\o note^at.^ounMlJ^juments for the activity 

noted above are based oh the assumptiomthat mere discjosure,^^these financial 

transactions is sufficient, reg^less of tl^^ove^sffl accufabyv^f its'reports. However, the 

Commission's regulations uhdervl 1 CFR)§104.1^4(d) als^re^ire disclosure reports to be 

accurate. DPW's me^od of disclpsure resulted in inaccuracies in total receipts, total 

disbursements, and c^sh^balan^esl-Under si^y.^.C. §30104(b)(1), (2), (4)® and 11 CFR 

§104.3Ca)(l), (2); (b)(1); committees.mustrepdrt the amount of beginning cash-on-hand, 

the.t6taj atnouht of alKreceipts apd all disbureenibnts, as well as the total amount of 

receipts and disbur^mehts i^^various enumerated catergories. Therefore, the overall 

totals^and. individual totalis for specific types of receipts and disbursements are significant 

for disclosure purposes and accuracy. N 

The Audit staff agrees that vendor refunds and the joint fundraiser receipts were included 

in DPW's original disclosure reports. However, because the transactions were either 

reported twice or reported'as negative entries, DPW's receipt, disbursement and cash 

balances were misstated. To materially correct these misstatements, DPW filed amended 

disclosure reports for 2011 and 2012. 

I Finding 2. Recordkeeping for Employees 

Summary 

During audit fieldwork, the Audit staff determined that DPW did not maintain any 

monthly payroll logs, as required, to document the percentage of time each employee 

Formerly 2 U.S.C. §434(b)(l), (2) and (4). 
spent in connection with a federal election. For 2011 and 2012, the Audit staff identified 

payments to DPW employees totaling $3,627,262, for which DPW did not maintain 

monthly payroll logs. This consisted of $2,192,554, for which payroll was allocated with 

federal and non-federal funds, and $1,434,708, for which payroll was exclusively nonfederal. In response to the Interim Audit Report recommendation, DPW acknowledged 

the need to improve its system of maintaining monthly time logs. As a result, DPW 

developed a web-based system for employees to track time associated with federal 

election activity. 

Legal Standard 

Maintenance of Monthly Logs. Party committees must k^eji.a monthly log of the 

percentage of time each employee spends in connection'with-la federal election. 

Allocations of salaries, wages, and fringe benefits are t^^ undertaken as follows: 

• employees who spend 25 percent or less of Iheir^compensated time in a given 

month on federal election activities musfbe paid eitherTfbm the federal account 

or be allocated as administrative cost^; ^ 

• employees who spend more than 25 percent of their compensated time in a given 

month on federal election activities must^be paid only from a federal account; and, 

• employees who spend none of their comp^s|ated'tim^ in a given\ionth on federal 

election activities may b^^id^n^rely wfth Jund^ that comply with^tate law. 11 

CFR§106.7(d)(l). 

Facts and Analysis • \ ^ v. \ ^ 

\ > > . 

A. Facts 

During fieldwork, the^Audit staff reviewed disbufsementsffor payroll. DPW did not 

maintain any monthly payroll logs or equivalent records to document the percentage of 

time each employee spent in.cbnnectiori with a federal election. These logs are required 

to document the proper allocation of federal and^nqn-federal funds used to pay employee 

salaries and wages.. For 2011 and 2012, DP.W'did'not maintain monthly logs for 

$3i627i262 in payroll.? This amount includes payroll paid as follows to DPW 

employees. ' \ v, 

i. Employees reported on Schedule H4 and paid with a mixture of federal and 

nqn^federal funds during the same month (totaling $2,192,554). 

ii. Eihployees reported on Schedule H4 and/or Schedule B and also paid with 

both a rnixture.df federal and non-federal funds and exclusively non-federal 

funds during the same month (totaling $28,972); and 

ill. Employees paid exclusively with non-federal funds in a given month and not 

reported by DPW (totaling $1,405,736)*. 

^ This total does not include payroll for employees paid with 100 percent federal fonds and reported as 

such (see Part I, Background, Commission Guidance, Request for Early Commission Consideration of a 

Legal Question, Page I). Payroll amounts are stated net of taxes and fringe benefits. 

' Some of these employees were paid from federal funds and reported as such in other months within the 

audit period. 
B. Interim Audit Report & Audit Division Recommendation 

The Audit staff discussed the recordkeeping requirement with DPW representatives 

during the audit fieldwork and at the exit conference. DPW representatives asked 

questions for clarification and said they would respond after having time to thoughtfully 

review each issue. Subsequently, DPW representatives stated that payroll logs had not 

been identified nor other evidence indicating that they were maintained. However, DPW 

provided a statement contending that other information confirmed the basis on which 

employees were paid. DPW representatives supported this statement by providing 

exhibits with a basic job description for the employees and a narrative that stated, in part, 

"Beginning in February, 2011 and continuing through th&su^mer of 2012, Wisconsin 

held multiple elections in connection with various recalls o^state-level elected officials. 

Recall elections for nine Wisconsin state senators were held^uring the summer of 2011. 

Recall elections for the Governor, Lieutenant Govemof^rid rour additional state senators 

were held during the spring and summer of 20.1^NtKroughout 2011 and through the 

summer of 2012, the Committee and its staff were'engrossed in'th^e^nonfederal 

elections. Employees directly involved in supporting nonfederal randldates performed 

no work in connection with federal elections, while other employees were paid entirely 

with federal funds." • \\ '' • . •. \ In addition, DPW submitted documentfitiqn identifying non-federal and federal election 

dates and events for both years 201.1 and 2012, stating, "..^as a result of these events, the 

Committee hired staff to work exclusively in connection with^yarious nonfederal [sic] 

recall elections." " ^ . . \ . '• . v 

The statement aiid exhibits ^vided by DPW are'not sufficient evidence and do not 

resolve the recordkeeping finding, because they^^o not document the time an employee 

spent in connection with^a federal'elecdon and the documents were provided after 

notification of the auditX "^ 

The Interim Audit Report^conimended that-DPW provide evidence that it maintained 

monthly, time logs to document the^percentage of time an employee spent in connection 

with a federal election; or^|mplement.^lan to maintain monthly payroll logs in the 

future. \ ' \ \ 

\ ] j C. Committee Response to Interim Audit Report 

In response to the interim' Audit Report recommendation. Counsel stated that the 

employee recordkeeping finding appears to be one of the most common findings in recent 

audits of state and local parties. Additionally, Counsel added that the scope of the 

Commission's Jurisdiction in relation to payments to employees with non-federal funds 

for exclusively non-federal activity has been a subject of recent Commission debate. 

Counsel believes the maintenance of monthly time logs is particularly burdensome for 

committees, such as DPW, that are heavily involved in non-federal election activity. 

Counsel stated that DPW participated in an unprecedented 13 non-federal elections 

during the 2012 election cycle. Counsel added that the non-federal elections arose 

unexpectedly as a result of the filing of petitions that led to the recall of 13 state senators, 

the lieutenant governor, and the govemor. Counsel stated that the recall elections 

garnered nationwide attention. 
10 

Despite these contentions, Counsel acknowledged the need to improve its system of 

maintaining monthly time logs. Counsel stated that a web-based system for employees to 

enter and track time spent on federal election activity was developed. A screen shot of 

the new time log was also submitted. Counsel stated that having the new system 

electronically helps to ensure the records will not be lost or misplaced. Furthermore, 

Counsel stated that the web-based system complies with the requirements of Commission 

regulations. 

Counsel raised the question as to whether the Commission should apply the employee log 

requirement to a party committee heavily involved in non-federal elections. However, 

the log requirement of 11 CFR §I06.7(d)(l) also applies to payroll paid exclusively out 

of non-federal funds. The language is broad in that^it api)lies the term "each employee" 

and "each employee" necessarily includes all of a domnfii^'s employees, including 

those who spend no time in connection with federal elections'because zero percent is also 

a percentage of time spent in connection with' fetleVal elections. Qoiinsel's statement that 

employees directly involved in supporting non-federal candidates performed no work in 

connection with federal elections needs to be^bcumented in order to ensure that, in light 

of potential concems about funding federal elecddn related ^tivity with federally noncompliant funds, it can be verified" for accuracy. \y 

The screen shot of the new time l^g sHowa employees ar^required to enter a name, 

description of work performed, pay perm^o^s^spent imth^pay period on non-federal 

activity, hours spen^in'the-pay periotronvfederabactiVity, and^a certification that the 

information ente^d is accurate. If the w^b^base^ systein tra^kVthe time each employee 

spends in connectioif 'with a^Te^deral electibn,''as^he screen-shot suggests, then it is 

consistent with theC^mmissioh payroll log^requirements for party committees at 11 CFR 

§106.7(d)(l). As suc>i; DPW lias complied WitH:the Interim Audit Report 

recommendation by implementing a plan to maintain monthly payroll logs in the future. • • •• . • 

' \ 

Vi • 

\ • •. 

•\ -v /