Interim Report of the 

Audit Division on the 

Georgia Federal Elections 

Conunittee 

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 Campdgn 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.^ 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. 

About the Committee (p. 2) 

The Georgia Federal Elections Committee is a state party 

committee of the Georgia Democratic Party headquartered in 

Atlanta, GA. For more information, see the chart on the 

Committee Organization, p. 2. 

Financial Activity (p. 3) 

• Receipts 

o Contributions from Individuals $831,598 

o Contributions from Other Political Committees 349,991 

o Transfers from Affiliated Party Committees 776,863 

o Offsets to Operating Expenditures 13.928 

o Transfers from Non-Federal Accounts 1,193.210 

o Other Fbderal Receipts 1.800 

Total Receipts $3,167,390 

Disbursements 

o Operating Expenditures $1,815,099 

o Contributions to Federal Candidates. 12.322 

o Coordinated Party Expenditures 142.208 

o Contribution Refunds 5.800 

o Federal Election Activity 701.728 

o Transfers to Non-Federal Accounts 460.783 

o Other Disbursements 2.047 

Total Disbursements $3,139,987 

Findings and Recommendations (p. 3) 

• Misstatement of Financial Activity (Finding 1) 

• Payment of Federal Activity with Non-Federal Funds 

(Finding 2) 

• Disclosure of Occupation/Name of Employer (Finding 3) 

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

Audit Division on the 

Georgia Federal Elections 

Committee 

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

Page 

Part I. Backgroimd 

Authority for Audit 1 

Scope of Audit 1 

Changes to the Law 1 

Part II. Overview of Committee 

Committee Organization 2 

Overview of Financial Activity 3 

Part III. Summaries 

Findings and Reconmiendations 4 

Part IV. Findings and Recommendations 

Finding 1. Misstatement of Financial Activity 5 

Finding 2. Payment of Federal Activity with Non-Federal Funds 8 

Finding 3. Disclosure of Occupation/Name of Employer 11 
Part I 

Background 

Authority for Audit 

This report is based on an audit of the Georgia Federd Elections Committee (GFBC), 

undertaken by the Audit Division of the Federal Election Commission (the Commission) 

in accordance with the Federal Election Campdgn 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 disclosure of individual contributors' occupation and name of employer; 

2. The disclosure of disbursements, debts and obligations; 

3. The disclosure of expenses allocated between federal, non-federal, and Levin 

accounts; 

4. The consistency between reported figures and bank records; 

5. The completeness of records; and, 

6. Other committee operations necessary to the review. 

Changes to the Law 

On December 1, 2005, the Commission voted to amend its rules to require state, district 

and locd party committees to pay as administrative expenses the salaries, wages and 

fringe benefits of employees who spend 25 percent or less of their compensated time in a 

month on federal election activity (FEA) or activity in connection with a federal election 

("covered employees"). The previous regulation that dlowed party committees to use 

non-federal funds for salaries and wages for covered employees was struck down by the 

Supreme Court in Shays v. FEC. The revised rule became effective on January 19,2006. 

(See Finding 2, Payment of Federd Activitv witii Non-Federal Funds). 
Part II 

Overview of Committee 

Committee Organization 

Important Dates Georgia Federal Elections Committee 

• Date of Registration June 14,1976 

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

Headquarters Atlanta. GA 

• 

Bank Information 

• Bank Depositories 1 

• Bank Accounts 6 Federal, 6 non-Federal, 1 Levin 

Treasurer 

• Treasurer When Audit Was Conducted Rex Templeton 

• Treasurer During Period Covered by Audit Jeffrey J. DiSantis 

Management Information 

• Attended FEC Cainpaign Finance Seimnar Yes 

• Used Commonly Available Campaign Management 

Software Package Yes 

• Who Handled Accounting and Recordkeeping Tasks Paid Staff 
Overview of Financial Activity 

(Audited Amounts) 

Federal Cash on hand @ January 1,2005 $17,342 

o Conuibutions from Individuals $856,051 

o Contributions from Other Political Committees 333.157 

o Transfers from Affiliated Party Committees 776.863 

o Offsets to Operating Expenditures 13.928 

o Transfers from Non-Federal Accounts 1.193.209 

o Other Federal Receipts 1.800 

Total Federal Receipts $3,167,390 

o Operating Expenditures $1,815,098 

o Contributions to Federal Candidates 12.323 

o Coordinated Party Expenditures 142.208 

o Contribution Refunds 5,800 

o Federal Election Activity 701,728 

o Transfers to Non-Federal accounts 460,783 

o Other Federal Disbursements 2,047 

Total Federal Disbursements $3,139,987 

Federal Cash on hand @ December 31,2006 $44,745 

Levin Cash on hand @ January 1,2005 $6,886 

Total Levin Receipts 750 

Total Levin Disbursements 7,210 

Levin Cash on hand @ December 31,2006 $426 
Part III 

Summaries 

Findings and Recommendations 

Finding 1. Misstatement of Financial Activity 

A comparison of GI^EC's reported financial activity to bank records revealed a 

misstatement of receipts and disbursements in both'2005 and 2006; and an understatement 

of cash at December 31,2006. In 2005, GFEC under reported receipts and disbursements 

by $523,109 and $523,965 respectively, and in 2006 GFEC under reported receipts by 

$126,313 and disbursements by $100,422. GFEC's reported cash bdance at December 31, 

2006 was understated by $26,262. The Audit staff recommends that GFEC file amended 

disclosure reports to correct tiie misstatements. (For more detdl, see p. 5) 

Finding 2. Pasrment of Federal Activity with Non-Federal Funds 

Disclosure of Salaries and Related Expenses 

GFEC fdled to provide supporting documentation detailing the time spent on federal 

activities for employees whose earnings and related payroll'expenses were dlocated on 

Schedules H4. GFEC reported sdaries and related expenses on Schedules H4 totaling 

$233,772. Absent the supporting documentation, GFEC should have disclosed these 

payments on Schedules B. The Audit staff recommends that GFEC either provide the 

supporting documentation mentioned above or amend its reports to correctly itemize its 

salaries and related expenses as 100% federal activity on Schedules B. 

Funding by the Non-Federal Account for Possible Federal Activity 

The Georgia Democratic Party made 68 transfers totaling $628,254 from its non-federal 

accounts into a federal account it used to make payroll disbursements. Without supporting 

documentation to show otherwise, the Audit staff considers all of the disbursements made 

from GFEC's **payrol]" account to be 100% federal activity reportable on Schedules B. The 

Audit staff recommends that GFEC demonstrate that its disbursements for sdaries and 

related expenses are allocable to its non-federal account. Absent such a demonstration, the 

Georgia Democratic Party will be required to transfer $478,715^ from its federal account to 

its non-federal account as payment for its share of federal expenses. (For more detdl, see 

p. 8) 

Finding 3. Disclosure of Occupation/Name of Bmpioyer 

A review of contributions from individuals reveded that 71 contributions totaling $170,474 

lacked, or did not adequately disclose, the contributor's occupation and/or name of 

employer. Furthermore, no evidence was provided that "best efforts'* was made to obtain, 

maintain, and submit the information. The Audit staff recommends that GFEC provide 

evidence that it exercised "best efforts" or contact each contributor lacking this 

information, submit evidence of such contact, and disclose any information received on 

Schedules A. (For more detail, see p. 11) 

^ See Facts and Analysis section for calculation. 
Part IV 

Findings and Recommendations 

Finding 1. Misstatement of Financial Activity 

Summary 

A comparison of GFEC's reported financial activity to bank records reveded a 

misstatement of receipits and disbursements in both 2005 and 2006; and an understatement 

of cash at December 31,2006. In 2005, GFEC under reported receipts and disbursements 

by $523,109 and $523,965 respectively, and in 2006 GFEC under reported receipts by 

$126,313 and disbursements by $100,422. GFEC's reported cash balance at December 31, 

2006 was understated by $26,262. The Audit staff recommends that GFEC file amended 

disclosure reports to correct the misstatements. 

Legal Standard 

Contents of Reports. Each report must disclose: 

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

• The totd amount of receipts for the reporting period and for the cdendar year; and 

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

• Certdn transactions that require itemization on Schedules A (Itemized Receipts), 

Schedules B (Itemized Disbursements), Schedules H3 (Transfers from Nonfederal 

Accounts for Allocated Federd/Nonfederal Activity), or Schedules H4 (Disbursements 

for Allocated Federd/Nonfederd Activity). 2 U.S.C. §434(b)(l), (2), (3), (4), and (5) 

and §434(e)(2), (3), and (4). 

Facts and Analysis 

The Audit staff reconciled GFEC's reported financid activity to its bank records for 2005 

and 2006. Below are charts that outline the discrepancies in both years followed by 

explanations of the misstatements, if known. 

2005 Activity 

Reported Bank Records Discrepancy 

Opening Cash Balance 

@ January 1,2005 

$16,116 $17,342 $1,226 

Understated 

Receipts $414,202 $937,311 $523,109 

Understated 

Disbursements $418,781 $942,746 $523,965 

Understated 

Ending Cash Bdance 

©December 31,2005 

$11,537 $11,907 $370 

Understated 
Beginning Cash on Hand as of January 1,2005: 

The $1,226 understatement of beginning cash on hand was due to prior period errors. 

The understatement of receipts resulted from the following: 

• Unreported transfers: non-federd accounts to payroll account^ 

• Unreported contributions from political committees 

• Unexpldned difference 

Understatement of Receipts 

The net understatement of disbursements resulted from the following: 

• Unreported disbursements made from payroll account 

• Unreported transfers: federal accounts to non-federal accounts' 

• Inter-account transfers from federal accounts to payroll 

account erroneously reported 

• Unexpldned difference _ 

Net Understatement of Disbursements 

+ 

+ 

+ 

$505,984 

17.000 

125 

$523,109 

$500,014 

34,018 

2,895 

7,172 

$523,965 

2006 Activity 

Reported Bank Records Discrepancy 

Opening Cash Bdance 

©January 1,2006 

$11,537 $11,907 $370 

Understated 

Receipts $2,103,766 $2,230,079 $126,313 

Understated 

Disbursements $2,096,820 $2,197,242 $100,422 

Understated 

Ending Cash Balance 

©December 31,2006 

$18,483 $44,744 $26,261 

Understated 

$122,391 

5.000 

1,078 

The net understatement of receipts resulted from the following: 

• Unreported transfers: non-federd accounts to payroll account + 

• Transfer from political committee not reported + 

• Unexplained difference . 

Net Understatement of Receipts $ 126,313 

The net understatement of disbursements resulted from the following: 

• Unreported disbursements made from payroll account + $122,391 

• Reported transfers from federd account to non-federal - 27,550 

account not traced to bank 

• Unreported transfers: federal account to non-federd account + 258 

• Unexpldned difference + 5,323 

Net Understatement of Disbursements $100,422 

^ GFEC paid both federal and non-federal stafT from this account but did not report the majority of the 

account activity to the Commission. Since payments for federal payroll were made from this account, the 

Audit staff considered it a federal account. 
On December 31, 2006, the cash balance was understated by $26,261 as a result of the 

errors described above. 

In both 2005 and 2006 the primary reason for the understatement of receipts and 

disbursements was GFEC's fdlure to properly report activity to and from its payroll 

account. The Georgia Democratic Party, which did not consider this account to be a 

federd account, made severd transfers into this account from both its non-federd and 

federal accounts and pdd both its federal and non-federal employees from the account. It 

should be noted that only 33% of the payroll account's activity was reported on GFEC's 

disclosure reports to the Commission.^ 

The Audit staff presented this matter at the exit conference. GFEC representatives 

disagreed that the payroll account was a federal account and explained that the payroll 

account was used like an "escrow account." They stated that this account was created to 

accommodate GFEC's payroll processing vendor, Paychex, which would not draw funds 

to process payroll from multiple accounts. GFEC representatives opined that this account 

was not a federd account and its non-federal activity was not reportable to the 

Cominission. 

It is the opinion of the Audit staff that since GFEC made several disbursements from the 

payroll account for both federal and non-federd payroll, the account functioned as an 

allocation account and all activity to and from this account was reportable to the 

Commission on Schedules A, B, H3, and/or H4. In Finding 2, Pavmcnt of Federd 

Activitv with Non-Federd Funds, the Audit staff states that since GFEC did not maintdn 

monthly logs, time sheets or affidavits for its employees, it is not possible to detennine. 

whether payroll should have been paid wholly from tiie federal account, the non-federal 

account, or allocated between the two accounts as administrative expenses. Therefore, 

GFEC should report these disbursements on Schedules B until it can demonstrate what 

percentage of its employees' time was spent working on non-federal election activity. 

Interim Audit Report Recommendation 

The Audit staff recommends that, within 30 days of service of this report, GFEC: 

• Amend its 2005 and 2006 reports to correct the misstatements noted above, including 

appropriate Schedules A, B, H3, and H4. 

• Report non-federal payroll disbursements on Schedules B as "Other Disbursements," 

line 29 of the detdled summary page and report the corresponding transfers from the 

non-federal account on Schedules A as "Other Federd Receipts," line 17. 

• Include a memo text with each amended item stating that "the transactions are being 

disclosed as a result of tiie 2005-2006 cycle FEC audit." 

• Amend the cash bdance on its most recently filed report with an explanation that it 

resulted from audit adjustments from a prior period. It is further recommended that 

* In 2005, only 2% of GFEC's activity from the payroll account was reported. In 2006,70% of this activity 

was reported. 
GFEC reconcile the cash bdance on its most recent report to identify any subsequent 

discrepancies that may impact adjustments recommended by the Audit staff. 

Finding 2. Pa3rment of Federal Activity with Non-Federal Funds | 

Summary 

Disclosure of Salaries and Related Expenses 

QFEC fdled to provide supporting documentation detailing the time spent on federal 

activities for employees whose earnings and related payroll expenses were allocated on 

Schedules H4. GFEC reported sdaries and related expenses on Schedules H4 totaling 

$233,772. Absent the supporting documentation, GFEC should have disclosed these 

payments on Schedules B. The Audit staff recommends that GFEC either provide the 

supporting documentation mentioned above or amend its reports to correctly itemize its 

salaries and related expenses as 100% federal activity on Schedules B. 

Furidin£F by the Non-Federal Account/or Possible Federal Activity 

The Georgia Democratic Party made 68 transfers totaling $628,254 from its non-federal 

accounts into a federd account it used to make payroll disbursements. Without 

supporting documentation to show otherwise, the Audit staff considers dl of the 

disbursements made from GI^C's "payroll" account to be 100% federd activity 

reportable on Schedules B. The Audit staff recommends that GFEC demonstrate that its 

disbursements for salaries and related expenses are allocable to its non-federal account. 

Absent such a demonstration, the Georgia Democratic Party will be required to transfer 

$478,715^ from its federd account to its non-federal account as payment for its share of 

federal expenses. 

Legal Standard 

A. Accounts for Federal and Non-federal Activity. A party committee that finances 

political activity in connection with both federal and non-federal elections shall establish 

two accounts (federal and non-federal) and allocate shared expenses, those that 

simultaneously support federd and non-federal election activity between the two 

accounts. Altematively, the committee may conduct both federal and non-federal activity 

irom one bank account, considered a federal account. 11 CFR §102.5(a)(l)(i). 

B. Paying for Allocable Expenses. Commission regulations offer party committees two 

ways to pay for diocable shared federal/non-federd expenses. 

• They may pay the entire amount of the shared expense from the federal account 

and transfer funds from tiie non-federal account to the federal account to cover the 

non-federal share of that expense; or 

• They may estabhsh a separate, federal allocation account into which the committee 

deposits funds from both its federal and non-federal accounts solely for the 

purpose of paying the allocable expenses of shared federal/non-federd activities. 

11 CFR §106.5(g)(l)(i) and (ii)(A). 

See Facts and Analysis section for calculation. 
C. Reporting Allocable Expenses. A political committee that allocates federal/nonfederd expenses must report each disbursement it makes from its federal account (or 

separate allocation account) to pay for a shared federal/non-federal expense. Committees 

report these kinds of disbursements on Schedules H4. 11 CFR §104.10(b)(4). 

D. Costs allocable by State party committees between Federal and Non-federal 

accounts (Effective prior to January 19,2006). State party committees must pay salaries 

and wages from funds that comply with State law for employees who spend 25% or less of 

their time in any given month on federal election activity. 11 CFR § 106.7(c)(1). 

E. Costs allocable by State party committees between Federal and Non-federal 

accounts (Effective on January 19,2006). State party committees must either pay 

salaries, wages, and fringe benefits for employees who spend 25% or less of their time in 

a given month on federal election activity with funds from their federal account, or with a 

combination of funds from their federal and non-federal accounts. 11 CFR § 106.7(c)(1), 

as amended January 19, 2006. 

F. Recordkeeping: Salaries and Wages. Committees must keep a monthly log of the 

percentage of time each employee spends in connection with a Federal election. Salaries 

and wages for employees who spend more than 25% of their compensated time in a given 

month on Federal election activity or activities in connection with a Federal election must 

be paid only from a Federal account. 11 CFR §106.7(d)(l)(ii). 

Facts and Analysis 

Disclosure of Salaries and Related Expenses 

The Audit staff's review of payroll expenses indicated that GFEC did not mdntain 

monthly logs, time sheets or affidavits for its employees. Therefore, based on the 

regulatory change effective January 19,2006 (See page 1, Changes to the Law), the 

Audit staff applied the following to assess salary expenditures: 

1. For salary and payroll tax payments made before January 19,2006: 

If there is monthly log, time sheet or affidavit which states that: 

• the time spent on federal activity is less than or equd to 25%; the payment can 

be made from the non-federal account and it requires nothing further of the 

federal committee; or 

• the time spent on federd activity exceeds 25%, or for which there is no . 

documentation indicating a lesser percentage, the federal committee must 

disclose these payments on Schedules B, Line 30b4 as non-allocable federal 

election activity (FEA). 

2. For salary and payroll tax payments made on or after January 19, 2006^: 

If there is monthly log, time sheet or affidavit which states that: 

^ GFEC did not allocate any salary or wage payments on Schedules H4 before the regulations changed on 

January 19,2006. 
10 

• the time spent on federal activity each montii is none, or 0%; this may be pdd 

by the non-federal account and requires nothing further of the federal 

committee; or 

• the time spent on federal activity is less than or equal to 25%; this payment 

must be made from the federd account and disclosed by the federd committee 

on Schedules H4 as allocable administrative activity, for which reimbursement 

may be sought from the non-federal account at the administrative ratio; or 

• the time spent on federal activity exceeds 25%, or for which there is no 

documentation indicating a lesser percentage, the federal committee must 

disclose these payments on Schedules B, Line 30b, as non-allocable FEA. 

The Audit staff's review revealed that GFEC fdled to mdntdn supporting 

documentation detailing the time spent on federal activities for employees whose salaries 

and related expenses, reported on Schedules H4, totaled $233,772. Absent the supporting 

documentation, GFEC should have disclosed these salary and related expenses as nonallocable FEA on Schedules B, Line 30b of the detdled summary page. 

The Audit staff discussed this matter with GFEC's representatives during the audit and 

requested monthly logs, timesheets and affidavits. GFEC representatives were unable to 

locate any of the items requested. 

Funding by the Non-Federal Account for Possible Federal Activity 

The Georgia Democratic Party made 68 transfers totaling $628,254 from its non-federd 

accounts into a federal account it used to make payroll disbursements. Without 

supporting documentation, the Audit staff considers all of the disbursements made from 

GFEC's payroll account to be non-allocable FEA, reportable on Schedules B, Line 30b of 

the detdled summary page. 

The Audit staff's analysis indicated that during the period covered by the audit, excluding 

payroll, the Georgia Democratic Party transferred $149,539 less than it could have from 

non-federal to federal accounts for allocable expenses. A similar andysis of GFEC's 

payroll account for the same period showed that the Georgia Democratic Party transferred 

$628,254 more than it should have from non-federal accounts into its payroll account. 

This resulted in the Georgia Democratic Party's non-federal accounts overfunding its 

federal/payroll accounts by $478,715 ($628,254 - $149,539). 

During audit fieldwork the Audit staff made severd requests for GFEC to provide 

monthly logs, time sheets or notarized affidavits for its employees that would 

demonstrate its non-federal account was not financing federal activity. GFEC did not 

provide any of the requested items. At the exit conference, GFEC representatives stated 

that they did not believe any of the unreported activity from the payroll account was for 

federal election activity. They further stated that the account used to pay these 

employees was not a federal account. The account was set up to accommodate GFEC's 

payroll processing company who would only process GFEC's payroll from a single bank 

account. Therefore, GFEC believes the nonfederd activity related to this account is not 

reportable to the Commission. 
11 

Interim Audit Report Recommendation 

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

GFEC: 

• Provide monthly logs or time sheets attesting to the time spent by employees for 

the period employed by GFEC, or affidavits stating that these employees did not 

spend more that 25% of their time on Federd election activities or activities in 

connection with a Federal election, and amend its disclosure reports accordingly. 

• Report any disbursements that GFEC can show are solely non-federd on 

Schedules B, line 29 of the detailed summary page as "Other Disbursements." 

• Report any disbursements that GFEC cannot show are allocable or solely nonfederal on Schedules B, line 30b of the detailed summary page, as FEA. 

• If no additional documentation is provided, GFEC should reimburse the nonfederal account $478,715. 

• GFEC should dso include a memo text with each amended item stating that "the 

transactions are being disclosed as a result of the 2005-2006 cycle FEC audit." 

Findings. Disclosure of Occupation/Name of Employer | 

Simunary 

A review of contributions from individuals revealed that 71 contributions totaling 

$170,474 lacked, or did not adequately disclose, the contributor's occupation and/or 

name of employer. Furthermore, no evidence was provided that "best efforts" was made 

to obtdn, maintain, and submit the information. The Audit staff recommends that GFEC 

provide evidence that it exercised "best efforts" or contact each contributor lacking this 

information, submit evidence of such contact, and disclose any information received on 

Schedules A. .. . 

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. 2 U.S.C. §434(b)(3)(A). 

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

coiitribution from an individual, the committee must provide the following infonnation: 

• 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 tiie same individual. 11 

CFR §§100.12 and 104.3(a)(4) and 2 U.S.C. §434(b)(3)(A). 

C. Best Efforts Ensures Compliance. When the treasurer of a politicd committee 

shows that the committee used best efforts (see below) to obtain, mdntdn, and submit 
12 

the information required by the Act, the committee's reports and records will be 

considered in compliance with the Act. 2 U.S.C. §432(h)(2)(i). 

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: 

o A clear request for the contributor's full name, mdling address, occupation, 

and name of employer; and 

o 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 initidly 

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

contdned 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). 

Facts and Analysis 

A review of contributions from individuals revealed that 71 contributions totding 

$170,474 lacked, or did not adequately disclose, the contributor's occupation and/or 

name of employer. This represents 23% of the dollar vdue of individual contributions 

itemized by GFEC. Most of these contributions were disclosed with a notation of 

"infonnation requested." 

The Audit staff asked a GFEC representative to provide documentation in support of their 

"best efforts" procedures. In response, the GFEC representative explained that the 

origind solicitations and follow-up letters to the contributors contained a request for the 

occupation and name of employer information and that any information received would 

be provided to the auditors for review. To date, no such infonnation has been provided. 

The Audit staff discussed this matter with GFEC representatives at the exit conference 

and provided a list of the itemized contributions that lacked, or did not adequately 

disclose, the required occupation and/or a name of employer information. 

Interim Audit Report Recommendation 

The Audit staff recommends that, within 30 days of receipt of this report, GFEC take the 

following action: 

• Provide documentation that it exercised best efforts to obtdn, mdntdn and 

submit the required contributor information; or 

• Make an effort to contact those individuds for whom the required information 

was hot in GFEC files and provide documentation of such efforts (such as copies 

of letters/emdl to the contributors and/or phone logs); and, 

• File amended reports to disclose any information in GFEC's possession as well 

as information obtained in response to this recommendation.