Preliminary Report of the 

Audit Division on 

Chris Dodd for President, Inc. 

January 24, 2007 - September 30, 2008 

Why the Audit 

Was Done 

Federal law requires the 

Commission to audit every 

political committee 

established by a candidate 

who receives public funds for 

the primary campaign.^ The 

audit determines whether the 

candidate was entitled to all 

of the matching funds 

received, whether the 

campaign used the matching 

funds in accordance with the 

law, whether the candidate is 

entitled to additional 

matching fiinds, and whether 

the campaign otherwise 

complied with the limitations, 

prohibitions, and disclosure 

requirements of the election 

law. 

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) 

Chris Dodd for President, Inc. is the principal campaign committee of Christopher 

J. Dodd, a candidate for the Democratic Party's nomination for the office of 

President of the United States. The Committee is headquartered in West Hartford, 

CT. For more information, see chart on the Campaign Organization, p. 2. 

Financial Activity (p. 3) 

• Receipts 

o Contributions from Individuals $ 9,848,996 

o Contributions from Political Committees 750,402 

o Transfers firom Affiliated Committees 4,632,357 

o Loans Received 1,302,811 

o Matching Funds Received 1,961,742 

o Offsets to Operating Expenditures 127,012 

o Other Receipts 47,506 

o Total Receipts $ 18,670,826 

• Disbursements 

o Operating Expenditures $14,978,850 

o Loan Repayments 1,302,811 

o Transfers to Other Authorized Committees^ 507,910 

o Contribution Refunds 1,365,901 

o Total Disbursements $ 18,155,472 

Findings and Recommendations (p. 4) 

• Net Outstanding Campaign Obligations (Finding 1) 

• Receipt of Prohibited Contribution and Contributions 

that Exceed Limits (Finding 2) 

• Misstatement of Financial Activity (Finding 3) 

' 26 U.S.C. §9038(a). 

^ This represents the transfer of general election contributions redesignated to the Candidate's Senate 

committee, Friends of Chris Dodd. 
Preliminary Report of the 

Audit Division on 

Chris Dodd for President, Inc. 

January 24, 2007 - September 30, 2008 
Table of Contents 

Page 

Part I. Backgroimd 

Authority for Audit 1 

Scope of Audit 1 

Inventory of Campaign Records 1 

Part II. Overview of Campaign 

Campaign Organization 2 

Overview of Financial Activity 3 

Part III. Summaries 

Findings and Recommendations 4 

Summary of Amounts Potentially Owed to the U.S. Treasury 4 

Part IV. Findings and Recommendations 

Finding 1. Net Outstanding Campaign Obligations 5 

Finding 2. Receipt of Prohibited Contribution and 

Contributions that Exceed Limits 7 

Finding 3. Misstatementof Financial Activity 11 
Parti 

Background 

Authority for Audit 

This report is based on an audit of Chris Dodd for President, Inc. (CDFP), undertaken by 

the Audit Division of the Federal Election Commission (the Commission) as mandated 

by Section 9038(a) of Title 26 of the United States Code. That section states "After each 

matching payment period, the Commission shall conduct a thorough examination and 

audit of the qualified campaign expenses of every candidate and his authorized 

committees who received [matching] payments under section 9037." Also, Section 

9039(b) of the United States Code and Section 9038.1(a)(2) of the Commission's 

Regulations state that the Commission may conduct other examinations and audits from 

time to time as it deems necessary. I 

Scope of Audit 

This audit examined: 

1. The receipt of excessive contributions and loans. , 

2. The receipt of contributions from prohibited sources. 

3. - The receipt of transfers from other authorized committees. 

4. The disclosure of contributions and transfers received. 

5. The disclosure of disbursements, debts and obligations. 

6. The recordkeeping process and completeness of records. 

7. The consistency between reported figures and bank records. 

8. The accuracy of the Statement of Net Outstanding Campaign Obligations. 

9. The campaign's compliance with spending limitations. 

10. Other campaign operations necessary to the review. 

Inventory of Campaign Records 

The Audit staff routinely conducts an inventory of campaign records before it begins the 

audit fieldwork. CDFP's records were materially complete and the fieldwork began 

immediately. 
Part II 

Overview of Campaign 

Campaign Organization 

Important Dates Chris Dodd for President, Inc. 

• Dateof Registration January 11,2007 

• Eligibility Period November 26,2007 - January 3,2008"* 

• Audit Coverage January 24,2007 - September 30,2008"" 

Headquarters West Hartford, Coimecticut 

Bank Information 

• Bank Depositories Two 

• Bank Accounts One checking, two investment 

Treasurer 

• Treasurer When Audit Was Conducted Kathryn Damato 

• Treasurer During Period Covered by Audit Kathryn Damato 

Management Information 

• Attended FEC Campaign Finance Seminar Yes 

• Used Commonly Available Campaign 

Management Software Package 

Yes 

• Who Handled Accounting and 

Recordkeeping Tasks 

Paid staff 

^ The period during which the candidate was eligible for matching funds began on the date of certification of his 

matching fund eligibility and ended on the date the candidate announced his withdrawal from the campaign. See 

11 CFR §9033. 

^ Limited reviews of receipts and expenditures were performed after September 30,2008, to determine whether the 

candidate was eligible to receive additional matching funds. 
Overview of Financial Activity 

(Audited Amounts) 

Cash on hand @ January 24,2007 $0 

o Contributions from Individuals $ 9,848,996' 

o Contributions from Political Committees 750.402 

o Transfers from Affiliated Committees 4,632,357 

o Loans Received 1,302,811 

o Matching Funds Received 1,961,742** 

o Offsets to Operating Expenditures 127,012 

o Other Receipts 47,506 

Total Receipts $ 18,670,826 

o Operating Expenditures $ 14,978,850 

o Loan Repayments 1,302,811 

o Transfers to Other Authorized Committee 507,910' 

o Contribution Refunds 1,365,901 

Total Disbursements $ 18,155,472 

Cash on hand @ September 30,2008 $515,354 

Approximately 25,000 contributions from more than 19,200 individuals. 

As of September 30,2008, CDFP had made 4 matching fund submissions totaling $1,999,514 of which 

$1,961,742 was certified by the Commission and paid to CDFP. This represents 9% of the maximum entitlement 

($21,025,000) a 2008 Presidential candidate could receive. 

This represents the transfer of general election contributions redesignated to the Candidate's Senate committee. 

Friends of Chris Dodd. 
Part III 

Summaries 

Findings and Recommendations 

Finding 1. Net Outstanding Campaign Obligations 

The Audit staffs review of CDFP's financial activity through December 31,2008 and 

estimated winding down costs indicated that the candidate did not receive matching fund 

payments in excess of his entitlement. (For more detail, see p. 5) 

Finding 2. Receipt of Prohibited Contribution and 

Contributions that Exceed Limits 

After reviewing all contributions from other political committees, it appears that CDFP 

received a prohibited contribution of $15,423 from the Intemational Association of 

Firefighters (lAFF) which resulted from the rental of a bus/recreational vehicle (RV) 

decorated to identify Senator Dodd's Presidential campaign. The RV was provided to CDFP 

for its use just prior to the Iowa caucus. This prohibited contribution was untimely resolved 

by CDFP. CDFP also failed to resolve excessive contributions from other political 

committees totaling $51,000. In addition, a further review of General election contributions 

indicated that CDFP received contributions totaling $244,050 for which it has not obtained 

the required redesignation letters necessary to transfer these funds to the candidate's 

Senatorial Committee, Friends of Chris Dodd (FOCD), nor made appropriate refunds. 

The Audit staff recommends that CDFP provide evidence that the contributions are not 

prohibited, not excessive, or were resolved in a timely manner. Absent such a demonstration, 

CDFP should make appropriate refunds, or a payment of $295,050 ($51,000 + $244,050), or a 

lesser amount based on CDFP's response, to tiie U.S. Treasury. (For more detail, see p. 7) 

Finding 3. Misstatement of Financial Activity 

A comparison of reported figures to bank records revealed that for 2008, CDFP understated 

its receipts by $355,240 and overstated its disbursements by $190,935. The Audit staff 

recommends that CDFP amend its disclosure reports to correct the misstatements for 2008. 

(For more detail, see p. 11) 

Summary of Amounts Potentially Owed to the 

U.S. Treasury 

• Finding 2 Receipt of Contributions that Exceed $295,050 

Limits - Unresolved 
Part IV 

Findings and Recommendations 

Finding 1. Net Outstanding Campaign Obligations 

Summary 

The Audit staffs review of CDFP's financial activity through December 31,2008 and 

estimated winding down costs indicated that the candidate did not receive matching fund 

payments in excess of his entitlement. 

Legal Standard 

A. Net Outstanding Campaign Obligations (NOCO). Within 15 days after the candidate's 

date of ineligibility, the candidate must submit a statement of "net outstanding campaign 

obligations". This statement must contain, among other things: 

• The total of all committee assets including cash on hand, amounts owed to the 

conimittee and capital assets listed at their fair market value; 

• The total of all outstanding obligations for qualified campaign expenses; and 

• An estimate of necessary winding-dovm costs. 11 CFR §9034.5(a). 

B. Entitlement to Matching Payments after Date of Ineligibility. If, on the date of 

ineligibility, a candidate has net outstanding campaign obligations as defined imder 11 

CFR §9034.5, that candidate may continue to receive matching payments provided that he 

or she still has net outstanding campaign debts on the day when the matching payments 

are made. 11 CFR §9034.1(b). 

Facts and Analysis 

The Candidate's date of ineligibility (DOI) was January 3,2008. The Audit staff reviewed 

CDFP's financial activity through December 31,2009, analyzed estimated winding down 

costs, and prepared the Statement of Net Outstanding Campaign Obligations that appears on 

the next page. 
Chris Dodd for President, Inc. 

Statement of Net Outstanding Campaign Obligations 

As of January 3,2008 

Prepared through December 31,2009 

Assets 

Primary Election Cash in Bank $ 271,389 

General Election Cash in Bank 1,706,575 

Accounts Receivable 46,899 

Capital Assets 8.407 

Total Assets $2,033,270 

Liabilities 

Primary Election Accounts Payable $ 542,065 

General Election Accounts Payable 1,706,575 [a] 

Loans Payable 1,302,811 

Winding Down Costs: 

Paid 1/4/08 - 12/31/09 $ 1,077,271 

Estimated Winding Down Costs (1/1/10- 12/31/10) 238.000 1,315,271 [b] 

Amounts Payable to U.S. Treasury for: 

Unresolved Excessive Contributions (See Finding 2) 51.OCX) [c] 

Total Liabilities 4.917.722 

Net Outstanding Canipaign Obligations (Deficit) as of January 3,2008 ($2.884.452) 

Footnotes to NOCO Statement; 

[a] To ensure that the need to refund general election contributions had no impact on matching fund 

entitlement, the Audit staff adjusted this payable to match the general election cash in bank amount. 

Prior to DOI. CDFP received general election contributions of $1,749,670; however, at DOI. the fair 

market value of the investment account in which these contributions were maintained was $1,706,575, a 

loss of $43,095. This loss and subsequent losses are the basis for the excessive contributions of 

$244,050 discussed in Finding 2. 

[b] The Audit staff will review CDFP's disclosure reports to compare actual figures with the estimates and 

prepare adjustments accordingly. 

[c] This amount does not include unresolved excessive general election contributions of $244,050. 
Shown below are adjustments for fimds received after January 3,2008, through July 17,2008 

(the date of the last matching fund payment): 

Net Outstanding Campaign Obligations (Deficit) as of 1/3/08 ($2,884,452) 

Private Contributions and Other Receipts Received 1/4/08 

through 7/17/08 

503,712 

Matching Funds Received 1/4/08 through 7/17/08 1,961,741 

Remaining Net Outstanding Campaign Obligations 

(Deficit) as of 7/17/08 

($418,999) 

As presented above, CDFP has not received matching fund payments in excess of its 

entitlement. 

The Audit staff presented the NOCO to CDFP representatives. In its response, CDFP did not 

address the NOCO. 

Preliminary Audit Report Recommendation 

The Audit staff recommends that, within 60 calendar days of service of this report, CDFP 

demonstrate an adjustment(s) is required to any component of the NOCO statement or provide 

any other comments it so desires. 

Finding 2. Receipt of Prohibited Contribution and 

Contributions that Exceed Limits 

Summary 

After reviewing all contributions from other political committees, it appears that CDFP 

received a prohibited contribution of $15,423 from the Intemational Association of 

Firefighters (lAFF) which resulted from the rental of a bus/recreational vehicle (RV) 

decorated to identify Senator Dodd's Presidential campaign. The RV was provided to CDFP 

for its use just prior to the Iowa caucus. This prohibited contribution was imtimely resolved 

by CDFP. CDFP also failed to resolve excessive contributions from other political 

committees totaling $51,000. In addition, a further review of General election contributions 

indicated that CDFP received contributions totaling $244,050 for which it has not obtained 

the required redesignation letters necessary to transfer these funds to the candidate's 

Senatorial Committee, Friends of Chris Dodd (FOCD), nor made appropriate refunds. 

The Audit staff recommends that CDFP provide evidence that the contributions are not 

prohibited, not excessive, or were resolved in a timely maimer. Absent such a demonstration, 

CDFP should make appropriate refunds, or a payment of $295,050 ($51,000 + $244,050), or a 

lesser amount based on CDFP's response, to the U.S. Treasury. 

Legal Standard 

A. Authorized Committee Limits. An authorized committee may not receive more than a 

total of $2,300 per election from any one person or $5,000 per election from a multicandidate 
political committee. 2 U.S.C. §441a(a)(l)(A), (2)(A) and (f); 11 CFR §§110.1(a) and (b) and 

110.9. 

B. Handling Contributions That Appear Excessive. If a committee receives a contribution 

that appears to be excessive, the committee must either: 

• Retum the questionable check to the donor; or 

• Deposit the check into its federal account and: 

o Keep enough money in the account to cover all potential refunds; 

o Keep a v^itten record explaining why the contribution may be illegal; 

o Include this explanation on Schedule A if the contribution has to be itemized 

before its legality is established; 

o Seek a redesignation of the excessive portion, following the instructions 

provided in the Commission regulations (see below for explanation of 

redesignation); and 

o If the conimittee does not receive a proper redesignation within 60 days after 

receiving the excessive contribution, refund the excessive portion to the donor. 

11 CFR §§103.3(b)(3), (4) and (5). 

C. Redesignation of Excessive Contributions. When an authorized candidate committee 

receives an excessive contribution (or a contribution that exceeds the committee's net debts 

outstanding), the committee may ask the contributor to redesignate the excess portion of the 

contribution for use in another election. The committee must inform the contributor that: 

1. The redesignation must be signed by the contributor; 

2. The redesignation must be received by the committee within 60 days after the 

committee received the original contribution; and 

3. The contributor may instead request a refund of the excessive amoimt. 11 CFR 

§110.1(b)(5). 

Within 60 days after receiving the excessive contribution, the committee must either receive 

the proper redesignation or refund the excessive portion to the donor. 11 CFR §§ 103.3(b)(3) 

and 110.1(b)(5)(ii)(A). Further, a political conimittee must retain written records conceming 

the redesignation in order for it to be effective. 11 CFR § 110.1(1)(5). 

D. General Election Contributions. If a candidate is not a candidate in the general election, 

any contributions made for the general election shall be refunded to the contributors or 

redesignated in accordance with 11 CFR §§ 110.1(b)(5) or 110.2(b)(5), as appropriate. 

E. Unreimbursed Value of Transportation. The unreimbursed value of transportation 

provided to any campaign traveler is an in-kind contribution from the service provider to the 

candidate committee on whose behalf the campaign traveler traveled. 11 CFR § 100.93(b)(2). 

F. Payment of Transportation. If a campaign traveler uses any other means of 

transportation, with the exception of an airplane, the campaign committee on whose behalf the 

travel is conducted, must pay the service provider within thirty calendar days after the date of 

receipt of the invoice for such travel, but not later than sixty calendar days after the date the 

travel began. 11 CFR § 100.93(d). 
G. Receipt of Prohibited Contribution from Labor Organizations. Political campaigns 

may not accept contributions made from the general treasury funds of labor organizations. 2 

U.S.C. §441b. 

Facts and Analjrsis 

The Audit staff's review of all contributions from individuals and other political committees 

indicated that CDFP received a prohibited contribution and a significant number of excessive 

contributions. The contributions included: 

• Receipt of prohibited contribution - CDFP was billed $12,088 on Febmary 12,2008, 

by the Intemational Association of Fire Fighters (lAFF) for a share of the cost of the 

rental of a bus/recreational vehicle (RV). The RV was rented for a period of 48 days 

from November 18,2007 to January 4,2008. It was decorated to identify Senator 

Dodd's Presidential campaign. The invoice from the LAFF indicated that CDFP used 

the RV for 18 of the 48 days in December 2007, through the date of ineligibility, and 

prorated the cost using a daily rate. The total cost of the rental for the 48 days was 

$32,233, with $15,423 representing the cost of the vehicle and $16,810 was the cost of 

"wrapping" it to identify the campaign. The invoice requested that payment of 

$12,088 be made within 60 days to the Intemational Association of Firefighters 

Interested in Registration and Education PAC (FIREPAC), a separate segregated fund 

of the lAFF. In response to a discussion of this issue at the exit conference, CDFP 

representatives provided a copy of a reimbursement check, dated October 21,2009, to 

L\FF FIREPAC for $32,233. 

In its December 2007 monthly report, FIREPAC disclosed making an independent 

expenditure^ on November 28,2007, in support of Dodd for "RV Art & Wrapping" in 

the amount of $16,810. When questioned about this matter, CDFP representatives 

stated that the lAFF initially paid for the RV to use as transportation to events 

involving commimications with the lAFF's restricted class. They stated that 

FIREPAC paid to wrap the RV because it was a communication expressly advocating 

Senator Dodd's presidential candidacy, which had not been coordinated with CDFP. 

CDFP later sou^t to determine whether it could obtain the use of the wrapped RV 

from the lAFF for its own purposes. The lAPT" made the RV available and CDFP 

used it just prior to the Iowa caucus. As mentioned above, the invoice was for a 

portion of the cost ($12,088); however, CDFP paid the entire RV rental and wrapping 

cost of $32,233. It should also be noted that CDFP's payment occurred more than 1 Vi 

years from the invoice date. After reporting the independent expenditure, FIREPAC 

disclosed a debt owed by CDFP in its March 2008 monthly report for the fiill cost of 

the RV ($32,233) and continued to report this debt until the reimbursement was 

reported in its December 2009 monthly report^. In response to this issue, CDFP 

representatives simply stated that it paid both for the use of the bus and of the wrap to 

avoid receiving an in-kind contribution. In response to other inquiries from the Audit 

staff, CDFP representatives stated that it was their understanding that the lAFF paid 

the rental cost of the bus; that the same bus wrapping was utilized by both the LAFF 

' FIREPAC reported independent expenditures of approximately $374,000 in support of CDFP. 

^ This report notes that a reimbursement from CDFP was inadvertently deposited into its non-federal account, 

and the transfer will be reflected on the year-end report. 
10 

and CDFP; and, that they are not aware of any other expenses that were paid by 

FIREPAC relating to the use or wrap of the bus after CDFP acquired its use. 

The Audit staff acknowledges that the payment of $32,233 by CDFP was an attempt to 

rectify this matter. However, the rental portion of the RV cost ($15,423), apparentiy 

paid by die lAFF, appears to be a prohibited contribution. I^bor organizations are 

prohibited from making contributions to political campaigns. This was untimely 

resolved by CDFP as a result of the reimbursement made to FIREPAC noted above. 

• Refunds of the excessive portion of contributions - The Audit staff identified three 

excessive contributions (totaling $8,000) which had been timely refunded by CDFP; 

however, the refund checks never cleared CDFP's bank account. As such, these 

remain unresolved excessive contributions. 

• Redesignation letter provided, but funds not transferred - There was one excessive 

contribution (for $4,000) which CDFP presented a timely, completed redesignation 

letter. However, the contribution was never transferred to the candidate's Senatorial 

committee, Friends of Chris Dodd (FOCD), nor refunded. It should be noted that 

transferring the funds to FOCD would have resolved this issue. However, because the 

candidate is no longer seeking re-election to the Senate, the transfer may not be 

plausible. At this time, the Audit staff considers this an unresolved excessive 

contribution. 

• No evidence of refund or redesignation provided - There are thirteen excessive 

contributions (totaling $39,000) which CDFP failed to provide any evidence of a 

refimd or redesignation. As such, these remain unresolved excessive contributions. 

• General election contributions not resolved - CDFP had contributions designated for 

the General election totaling $244,050^° for which it has not obtained the required 

redesignation letters necessary to transfer these fimds to FOCD. In accordance with 

Advisory Opinion 2008-04 (AO), CDFP had six days from the receipt of the AO 

(dated September 2,2008) to obtain redesignations and make refimds. Even if CDFP 

were to obtain the required redesignation letters, it lacks the fimds to complete the 

transfer or refimd. Until such letters are provided, the Audit staff considers these 

unresolved excessive contributions. 

At the exit conference, the Audit staff provided CDFP representatives with a schedule 

outlining the excessive contributions. In its response, CDFP representatives provided the 

responses noted above. 

Preliminary Audit Report Recommendation 

The Audit staff recommends that, within 60 calendar days of service of this report, CDFP 

provide documentation demonstrating that it did not receive a prohibited contribution of 

'° The Audit staff also noted that CDFP transfenred general contributions ($67,800) to FOCD for which 

redesignation letters were not provided and has redesignation letters for $98,410 in contributions to be 

transferred, but insufficient funds to do so. 
11 

$15,423 from the L\FF and that contributions of $295,050 ($8,000 + $4,000 + $39,000 + 

$244,050) are not excessive. To demonstrate that it did not receive a prohibited contribution, 

CDFP should provide documentation verifying that lAFF did not pay for the rental portion of 

the RV. For the unresolved excessive contributions, such documentation should include 

copies of timely negotiated refimd checks or timely signed and dated redesignation letters. 

Absent such documentation, CDFP should make appropriate refunds to contributors and 

provide evidence of such action (copies of the front and back of negotiated refund checks) or 

make a payment of $295,050 to the U.S. Treasury. Should documentation be presented that 

demonstrates any review exceptions are not prohibited or excessive contributions, the Audit 

staff will calculate a revised amount payable to the U.S. Treasury. This revised amount or the 

unrefunded portion thereof, is payable within 30 calendar days of service of the final audit 

report. 

I Finding 3. Misstatement of Financial Activity 

Summary 

A comparison of reported figures to bank records revealed that for 2008, CDFP understated 

its receipts by $355,240 and overstated its disbursements by $190,935. The Audit staff 

recommends that CDFP amend its disclosure reports to correct the misstatements for 2008. 

Legal Standard 

Contents of Reports. Each report must disclose: 

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

• The total amount of receipts for the reporting period and for the election cycle; and 

• The total amount of disbursements for the reporting period and for the election cycle; and 

• Certain transactions that require itemization on Schedule A (Itemized Receipts) or 

Schedule B (Itemized Disbursements). 2 U.S.C. §434(b)(l), (2), (3), (4) and (5). 

Facts and Analysis 

The Audit staff reconciled reported activity to bank records for 2008. The following chart 

outlines the discrepancies for the begiiming cash balances, receipts, disbursements, and the 

ending cash balances. The succeeding paragraphs explain why the differences occurred, if 

known. 
12 

2008 Committee Activity 

Reported Bank Records Discrepancy 

Opening Cash Balance 

@ January 1,2008 

$ 2,489,560 $ 2,456,875 $ 32,685 

overstated 

Receipts $ 1,910,177 $ 2,265,417 $ 355,240 

understated 

Disbursements $ 4,397,873 $4,206,938 $ 190,935 

overstated 

Ending Cash Balance @ 

September 30,2008 

$515,970" $ 515,354 $616 

overstated 

The overstatement of opening cash on hand ($32,685) was the result of discrepancies that 

occurred in the previous year, 2007. 

The understatement of receipts resulted from the following: 

• Matching fund payment received 7/17/08, not reported $ 514,173 

• Realized losses (investment accounts), not reported (202,336) 

• Vendor refimd, not reported 5,876 

• Offsets to operating expenditures, not reported 23,954 

• Political Coinmittee contributions, not reported 16,100 

• Unexplained difference (2.527) 

Net understatement of receipts $ 355.240 

The overstatement of disbursements resulted from the following: 

• Loan repayment, over-reported $ (144,757) 

• Disbursements and investment fees, not reported 239,950 

• Net errors in reporting payroll and fees 41,733 

• Transfer to the Candidate's Senate coinmittee, over-reported (351,210) 

• Reported disbursements that actually cleared bank in Dec. '07 (3,300) 

• Unexplained difference 26.649 

Net overstatement of disbursements $ (190.935'^ 

Regarding the over reporting of transfers to the Candidate's Senate committee (totaling 

$351,210), CDFP representatives stated that it had instructed its broker to transfer the fimds to 

the FOCD account, and it was the broker's delay in making the transfer that caused the 

reporting discrepancy. The reporting error could have been avoided if CDFP had not reported 

the transfer until the fiinds were actually transferred. Regarding the reporting of operating 

expenditures, CDFP representatives stated that many operating expenditures were not 

The reported ending cash balance is incorrect because CDFP decreased its beginning cash on hand by $12,949 

in its August 2008 Monthly Report and increased beginning cash on hand by $527,055 in its October 2008 

Monthly Report. The unexplained changes in cash may have been an attempt to correct the cash 

discrepancies that resulted from the misstatements of receipts and disbursements. Absent these incorrect 

adjustments by CDFP. the reported ending cash balance at September 30.2008 would have been $1,864. 
13 

reported because they were unaware of the data processing requirements for entering debts 

and obligations. As such, many debt payments were not disclosed in CDFP's reports. No 

other discrepancy (noted above) was addressed by CDFP representatives. 

At the exit conference, the Audit staff discussed die misstatement and provided CDFP 

representatives with copies of the Audit staff's bank reconciliation. In its response, CDFP 

representatives presented the positions mentioned above. No adjustments were made by the 

Audit staff. 

Preliminary Audit Report Recommendation 

The Audit staff recommends that, within 60 calendar days of service of this report, CDFP 

amend its report to correct the misstatements for 2008.