Draft Final Audit Report of the 

Audit Division on Hillary Clinton 

for President 

January 1, 2007 - December 31. 2008 

Why the Audit 

Was Done 

Federal law permits the 

Commission to conduct 

audits and field 

investigations of any 

political committee that is 

required to file reports 

under the Federal 

Election Campaign Act 

(the Act). The 

Commission generally 

conducts such audits 

when a committee 

appears not to have met 

the threshold 

requirements for 

substantial compliance 

with the Act.' 

determines 

commi 

the Ii 

prohibitions 

disclosure 

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 Campaign 

Hillary Clinton for President ( 

committee for Hillary Clintq 

Party's nomination for thi 

States. HCFP is headcu^Lnrei 

is the principal campaign 

te for the Democratic 

of the United 

1, D.C. For more 

information, see the^art on the Campai anization, p.2. 

Financial 

• Receipts 

o ^jontributions fronilVbyiduals 

o oH^j^litical Comim 

o Fr^aS^^CedCommitT 

o CanoBate 

o Offsetlto^^peii9i^V% 

Other ^Ceipts 

Total R^ipts 

isemenl^ 

Expenditures 

Transfers to Affiliates 

Ltribution Refunds 

o wmer Disbursements 

o^Total Disbursements 

$ 217,686,817 

1,610,538 

10,000,000 

13,750,000 

9,678,788 

$252,726,143 

$ 223,080,262 

6,466,215 

21,935595 

75,403 

$251,557,475 

nding and Recommendation (p. 3) 

• Receipt of Contributions that Exceed Limits 

2U.S.C. §438(b). 
Draft Final Audit Report of the 

Audit Division on 

Hillary Clinton for President 

January 1, 2007 - December 31, 2008 
Table of Contents 

Page 

Part I. Background 

Authority for Audit 1 

Scope of Audit 1 

Part II. Overview of Campaign 

Campaign Organization 

Overview of Financial Activity 

Finding and Recommendation 

nre^ntioiH^ 

jmits ^^^^^ ^ 

Part III. Summary 

Part IV. Finding and Recom: 

Receipt of Contributions that Exceed Limits 
Parti 

Background 

Authority for Audit 

This report is based on an audit of Hillary Clinton for President, undertaken by the Audit 

Division of the Federal Election Commission (the Commission) in accordance with the 

Federal Election Campaign Act of 1971, as amended (the Act). The Audit Division 

conducted the audit pursuant to 2 U.S.C. §438(b), which permits the Commission to 

conduct audits and field investigations of any political committ^B^is required to file a 

report under 2 U.S.C. §434. Prior to conducting any audit this subsection, the 

Commission must perform an intemal review of reports fi^r^^dected conunittees to 

determine if the reports filed by a particular committee r^^t thel^|^old requirements 

for substantial compliance with the Act. 2 U.S.C. §j 

Scope of Audit 

Following Commission approved proceduresT 

factors and as a result, this audit examined: 

1. The receipt of excessive contributions and loans. 

2. The receipt of contributions from 

3. The disclosure of contributions re 

4. The disclosure of debts and obligatid 

5. The consistency between reported fi, 

6. The completeness 

7. Other committe^B)eratio!lHecessary to 

yaluated varifls risk 

ited sources 
Part II 

Overview of Campaign 

Campaign Organization 

Important Dates Hillary Clinton for President 

Date of Registration January 22,2007 

Audit Coverage January 1,2007 

Headquarters Washingt 

Bank Information 

Bank Depositories 

Bank Accoimts 

Treasurer 

• Treasurer When Audit Was Conductc 

• Treasurer During Period Covered by ^ 

Management Information 

bfikwa 

• Attended FEC Campai 

• Used Commonly 

Management So: 

• Who Handled Accounf 

Recordkeepiaaffiiks 

e Seminar! 

aid Staff 

Ove ^ww Financial Activity 

(Audited Amounts) 

Cash on hand @ jl^ ^ L1D07 $0 

o Contributions fr8B||#^iduals 217,686,817 

o Other Political CoHiittees 1,610,538 

o From Affiliated Committees 10,000,000 

o Candidate Loans 13.750.000 

o Offsets to Expenditures & Other Receipts 9.678.788 

Total Receipts $252,726,143 

o Operating Expenditures 223.080.262 

o Transfers to Affiliates 6.466.215 

0 Contribution Refunds 21.935.595 

o Other Disbursements 75.403 

Total Disbursements $251,557,475 

Cash on hand @ December 31,2008 $ 1,168,668 
Part III 

Summaiy 

Finding and Recommendation 

Receipt of Contributions that Exceed Limits 

The Audit staffs review of contributions from other political committees indicated that 

HCFP failed to timely resolve excessive contributions totalingSJ^IQ. The 

contributions were either designated to the general election bine contributing committee 

or presumptively redesignated by HCFP. HCFP has provi^R^Himentation that the 

contributions have been refunded. In response to the intc 

recommendation, HCFP*s legal counsel notes that dMl^i)nt is a ti!l[^^ of total 

receipts and went on to explain that the excessive^^tributions were dc^^^ee minor 

database errors inadvertently overlooked by I]i^ ^ Whefl^e contributi^^p^ brought 

to HCFP's attention, they took appropriate steps 

p. 4) 

ds. (For mire detail, see 
Part IV 

Finding and Recommendation 

Receipt of Contributions that Exceed Limits 

Summary 

The Audit staffs review of contributions from other political committees indicated that 

HCFP failed to timely resolve excessive contributions totaling $2J^0. The 

contributions were either designated to the general election byij^^^Stributing committee 

or presumptively redesignated by HCFP. HCFP has providoiKcumentation that the 

contributions have been refimded. In response to the intq^^al^ceport 

recommendation, HCFP's legal counsel notes that the^^Lnt islM^art of total 

receipts and went on to explain that the excessive c«Mi|jtibns wer^Bkto three minor 

database errors inadvertently overlooked by HCS^When the contribu^^^were brought 

to HCFP's attention, they took appropriate st^i^^etumlhe funds. 

Legal Standard 

A. Authorized Committee Limits. 

than a total of $2,300 per election froi 

multicandidate political committee. 2 

§§ 110.1(a) and (b), 110.2(b), and 110.9. 

authorized coiMjaee may not receive more 

le person or^B^Oner election from a 

,§(a)(l)(i'^!Wf2)(A), and (f); 11 CFR 

B. Handling Contri^^MH|mt Appear^cessive. M a committee receives a 

contribution that apij^^ to be^Bessive, the^mmittee must either: 

• Retum thd^u^Hiable Heck to the d(np|f or 

Deposit the checl^|Q#l^^|^ccQdnand: 

eyunffi^count to cover all potential refunds; 

;d explaining why the contribution may be illegal; 

n Schedule A if the contribution has to be 

e its y^ity is established; 

ition or a redesignation of the excessive portion, following 

provided in the Commission regulations; and 

tee does not receive a proper reattribution or redesignation 

after receiving the excessive contribution, refund the 

portion to the donor. 11 CFR §§ 103.3(b)(3), (4) and (5) and 

110.1(k)(3)(ii)(B). 

C. 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. 11 CFR § 102.9(e)(3). 
Facts and Analjrsis 

A review of contributions from other political committees revealed HCFP received 

excessive contributions from ten political committees totaling $21,400 which were 

unresolved. The contributions were either designated to the general election by the 

contributing committee or presumptively redesignated to the general election by HCFP. 

Since the Candidate did not run in the general election, these contributions were required 

to be refunded. At all times, HCFP maintained sufficient funds to make the necessary 

refunds. 

The Audit staff discussed this matter at the exit conference and 

representatives with a schedule of the apparent excessive con| 

the exit conference, HCFP provided the Audit staff with coi 

$21,400. The refimd checks have been negotiated and tcaKd tc 

account. 

jded HCFP 

ItioiR. In response to 

refimd checks totaling 

ippropriate bank 

Interim Audit Report Recommendat: 

The Audit staff recommended that HCFP pr 

with respect to this matter. In response, HCFP' 

tiny part of total receipts and went on to explain that 

to three minor database errors inadveltantly overlooked 

contributions were brought to HCFP's^ 

fimds. 

they took 

onmdttee^^^ponse 

s it deeme^B^sary 

otes that thr^ount is a 

cessive contributions were due 

When the 

^ate steps to retum the