lih 

REPUBLICAN PARTY 

September 19,2016 

Til/1 

Mr. Robert Morcomb, CFE 

Federal Election Commission 

Auditor 

Audit Division 

Office of Compliance ' 

Washington, DC 20463 

Re: Illinois Republican Party C0000S926 

Dear Mr. Morcomb: 

I thank you again for the time last Thursday in walking me through some of the detail 

underlying the Interim Audit Report. As we have maintained throughout, to the extent that our 

filings from 2011 and 2012 were not accurate, we desire to amend them, and will amend them, 

largely as outlined in the Interim Audit Report. We appreciate the opportunity to do so. 

As we discussed, we have a technical issue with amending our reports insofar as our | 

current, professional compliance provider uses FECfile and our staff from the 2011-2012 time 

period apparently used Aristotle. In addition, the files from that time period are no longer available 

to us. You have provided me with an FEC contact number for our compliance professionals to 

work through the technicalities of this situation, which I appreciate. At Ais point, however, this 

technical issue necessitates that the Illinois Republican Party respectfully request an extension of 

IS calendar days to amend its reports in a manner consistent wiA certain portions of the Interim 

Audit Report and to provide an official response to the Interim Audit Report. 

Respectfully, j 

/s/ John Fogarty, Jr. 

I 

John Fogarty, Jr. 

General Counsel 

Illinois Republican Party 

cc: Marty Favin 

PAID FOR BriHEIIilNOISREPUBUGMiminY. iLQ0P.0R8 

NOT AUTHORIZED BYANYCANDIIMIEORCANDIIMIECOMIIIflEE. 
^Illinois 

4 

REPUBLICAN PARTY 

October 20,2016 

I 

By email and via U.S. Mail' 

I 

Mr. Robert Morcomb, CFE; 

Federal Election Commissi9n 

Auditor 

Audit Division 

Office of Compliance i 

Washington, DC 20463 ^ 

Re: Illinois Republican Party C00005926 

Dear Mr. Morcomb: 

This letter is in response to the Interim Audit Report ("lAR") submitted to the'Illinois 

Republican Party ("IRP") by your agency on August 18, 2016. Your agency has kindly granted 

the IRP two extensions, through today's date, to respond to the lAR, given technical issues with 

amending IRP filings from the 2011 and 2012. The lAR has made six (6) Findings, to which the 

IRP responds here. 

Finding #1 address^ discrepancies between the IRP's bank account records and receipts 

and disbursements reported to your agency in 2011 and 2012. The IRP has reviewed the items 

that your agency contends were incorrectly reported. As well, you were kind enough talk with our 

counsel about these discrepancies as logged in the master excel file you sent via e-mail in tandem 

with the lAR. As the IRP has maintained throughout this process, it will amend its reports from 

this period to more accurately reflect all financial activity. The IRP has embarked upon this 

process. 

In order to do as thorough and accurate a job as possible, IRP has contracted with Red 

Curve Solutions ("Red Curve") to rebuild its files from 2011 and 2012 and to file amended reports, 

beginning in January of 2011, and continuing through the present day, if necessary. Red Curve 

has handled the IRP's day-to-day compliance since 2013, and has done so in excellent fashion. In 

particular, Danny Peppe of Red Curve will handle the amendment process, including the technical 

challenge presented by the fact that Red Curve uses FECfile, while the IRP's staff from the 2011-

2012 time period used Aristotle software. Red Curve anticipates that the database rebuild and 

amendment process will take a couple of months, and all report amendments will be made at once. 

miDroRBYIHEIillNOISRERUBUGANMinY. iLQOP.ORa 

NOT AUTHORIZED BY ANY CANDIDATE OR CANDIDATE COMMITTEE. 
once Red Curve and the IRP are confident on the accuracy of the amendments. IRP staff and 

possibly Red Curve staff will stay in contact with you as this process progresses. 

The IRP again thanks you for this opportunity to provide accurate disclosures from this 

period. We wish to reiterate that any incorrect reporting of receipts or disbursements was 

inadvertent and without any intention to circumvent reporting requirements. As well, we are 

hopeful that the IRP's investment in compliance professionals both after the 2011-2012 time 

period and in order to accomplish the recommendations made in the lAR demonstrates the IRP's 

good faith in this process. 

Finding #2 addressed the IRP's supposed failure to disclose 27 direct mail communications 

as independent expenditures. With regard to these direct mail communications, as the IRP has 

indicated during this audit, as was originally reported to the PEC by the IRP, and as is supported 

by the materials provided to your agency, the expenditures in question were not independent 

expenditures on behalf of federal candidates, but rather were for non-allocable election 

communications on behalf of federal candidates. 

Again, the IRP reiterates that these 27 direct mail communications were non-allocable, 

candidate-specific volunteer mass mailings. In further support of the volunteer component of these 

non-allocable (and not independent) expenditures, the IRP has submitted the affidavits of two 

individuals heavily involved and responsible for the volunteer component of the volunteer mail. 

Both affidavits describe the process by which the IRP volunteers regularly processed all of the 

IRP's non-allocable mail. Indeed, as noted in the affidavit of Jon Calloway, the IRP's Deputy 

Director during the relevant time period, none of the mail pieces the IRP sent on behalf of federal 

Republican candidates were, nor were intended to be, independent expenditures. Rather, all mail 

pieces were intended to be processed and sent as non-allocable mail. 

The IRP has searched its records on many occasions throughout this process, and does not 

have any additional invoices or information regarding the 27 direct mail communications 

referenced by your agency. As well, the IRP does not have any additional volunteer timesheets or 

photographs to document additional volunteer processing of non-allocable direct mail. However, 

the IRP attaches the affidavit of Joe Weiss, Deputy Executive Director for the IRP, in further 

support of the IRP's contention that all of the direct mail at issue was intended to be processed as 

non-allocable mail, and not as independent expenditures. 

Finding #3 addressed expenditures disclosed by the IRP as "FEA Volunteer Mail, 

Advocacy calls for Federal candidates. Direct Mail Services, equipment and phone minutes for 

Federal candidates and Auto-Dialer for Federal candidates." This finding contends that the IRP 

has not produced records to sufficiently record these disbursements as "FEA Volunteer Mail, 

Advocacy calls for Federal candidates. Direct Mail Services, equipment and phone minutes for 

Federal candidates and Auto-Dialer for Federal candidates" and has requested the IRP provide 

copies of communications, invoices and scripts that would substantiate these disclosures. The IRP 

has searched its records, and unfortunately has no additional documents that would further 

substantiate these disclosures. 

PAID FOR BYlHEIlUNOISREPUBUCMimunY. iljQOP.ORQ 

NOT AUIHGRIZED BYAIIYCANDiilAIEORCANDiilAIEOGMMillEL 
Finding #4 addressed possible prohibited contributions in the amount of $72,880 that are 

reflected on invoices from the mailhouse Revolvis as having been paid directly to Revolvis for 

postage for mail for Joe Walsh for Congress and Plummer for Congress. The IRP contends that 

such amounts were permissibly spent by the IRP on behalf of the Walsh and Plummer campaigns 

for non-allocable mail, through the Revolvis mailhouse. The IRP contends that all funds it paid to 

Revolvis for direct mail to support federal candidates were raised in accord with federal limits and 

source prohibitions, regardless of whether Revolvis may have paid for postage costs directly for 

certain direct mail. The IRP continues to search for records to further support this contention, to 

the extent that it is not supported by the records that have been produced thus far in this audit. 

Finding #5 addressed items that arguably should have been reported as debt on Schedule 

D during the relevant reporting period. The IRP has reviewed the items identified in the lAR and 

will amend its reports from-this period to more accurately reflect amounts that should have been 

considered debt. These amendments will occur in conjunction with the matters to be amended as 

described in response to Finding #1. Again, the IRP appreciates the opportunity to more accurately 

disclose its financial activity from this period, and again reiterate that any incorrect reporting of 

debt was inadvertent and without any intention to circumvent reporting requirements. 

Finding #6 addressed record keeping for field employees. Regrettably, the IRP does not 

possess any monthly payroll logs for employees for the 2011 -2012 time period, to the extent that 

such records were kept. As has been related during the fieldwork portion of this audit, a change 

in senior staff following the 2012 election cycle has fhistrated the ability of current IRP leadership 

to produce records from 2011 and 2012. 

Regardless, as was the case during the 2014 election cycle, and as is the case currently, the 

IRP requires all of its employees who are paid by both federal and state funds to maintain monthly 

logs of the time each spends on federal and state activities. Going forward, the IRP will continue 

to require such employees to maintain monthly payroll logs. 

Respectfully, 

/s/ NickKlitzmg /s/ 

Nick Klitzing 

Executive Director 

Illinois Republican Party 

cc: John Fogarty, Jr. 

nyDroRBYIHEIlUNOISREPUBUCMIRMaY. IUIOP.ORfl 

NOT AUIHORIZED BY ANY CANDIDAIE OR CANDIDATE ODMMITTEE.