JONES DAY 

SI LOUISIANA AVENUE. N.W, • WASHINGTON. D.C. 20OOI.21I3 

TELEPHONE:+ 1.202.078.3939 • FACSIMILE:+I.202.B2S.1700 

OIRECTNUMICR: (202)879-3732 

WMCaiNLEVOjONESDAV.CeM ' 

May 23,2016 

VIA E-MAIL TOBRlEN@FEC.GOV 

Mr. Terry O'Brien 

Auditor 

Audit Division 

Federal Election Commission 

999 E Street, NW 

Washington, DC 20463 

Re: 

Dear Mr. O'Brien: 

On behalf of our client, the Oklahoma Leadership Council ("OLC" or the "Committee"), this 

responds to the Draft Final Audit Report O'DFAR") that was delivered to our client May S, 2016. 

As discussed below, the Committee has fully complied with the Audit Division's 

recommendations as set forth in the DFAR. We also wish to inform the Commission that OLC is 

not requesting an audit hearing in this matter. 

The record in this matter clearly demonstrates that the Committee fully cooperated with the 

Audit Division during the course of this audit. It is our expectation that the Audit Division, 

Office of the General Counsel, and the Conunission itself will review the DFAR and the 

Committee's response in a fair and objective manner. 

OLC^s Responses to ;the .BEAR-Eindings arfd J8,ectimmiindatioiis. 

Findings 1 (Misstatement of Financial Activity) & 3 (RecordKeeping for Employees): As 

stated in the DFAR, OLC has materially complied with the Auditors' Interim Audit Report 

recommendations for Findings 1 and 3 and no further action is required. 

Finding 2: Misstatement of Financial Activity-Levin Fund 

In response to the Interim Audit Report (lAR) and after consulting with the Audit Division, OLC 

was instructed that it may correct the public record in the financial misstatement findings in the 

lAR by filing a Form 99 with the Corxunittee's March monthly report rather than filing amended 

2011 and 2012 reports. In addition, the Audit Division requested OLC make a one-time audit 

ALKHOBAR • AMSTERDAM • ATLANTA • BEIJING • BOSTON • BRISBANE • BRUSSELS • CHICAGO • CLEVELAND • COLUMBUS • DALLAS 

DETROIT t DUBAI • OD5SELOORP • FRANKFURT • HONGKONG • HOUSTON • IRVINE • JEDDAH • LONDON • LOS ANGELES 

MADRID • MEXICO CITY • MIAMI • MILAN • MOSCOW • MUNICH • NEW YORK • PARIS • PERTH • PITTSBURGH • RIYADH 

SAN DIEGO • SAN FRANCISCO • SAO PAULO • SHANGHAI • SILICON VALLEY t SINGAPORE • SYDNEY • TAIPEI • TOKYO • WASHINGTON 
JONES DAY 

Teny O'Brien 

May 23.2016 

Page 2 

adjustment and iile an amended 2012 Year-End rq)ort. OLC complied with the audit division's 

revised recommendations as detailed in the February 19,2016 email from auditor Terry O'Brien. 

On April 29, 2016, Mr. O'Brien sent an enuul asking a question about OLC's Form 99. 

Specifically, he asked about why the Form 99 did not contain the January 2S, 2012 SIO.OOO 

Levin Fund deposit. On May 4,2016, we submitted a draft Form 99 listing the January 2S, 2012 

$10,000 Levin Fund deposit for his review. On May S, 2016, Mr. O'Brien replied via email that 

the draft Form 99 "looks factually accurate and, if filed as such, will resolve the Levin 

misstatement." OLC filed the Levin Fimd Form 99 on May S, 2016 and submitted written 

evidence of the filing to the auditors on the same date.. Accordingly, OLC has materially 

complied with the audit division's recommendations. 

Finding 4: Contributions from Unregistered Political Organizations 

As stated in response to the lAR, on March 1, 2016, OLC transferred $1,000 fixrm its federal 

account to the state account in accordance with the Audit Division's recommendation for lAR 

Finding 4, as modified by Mr. O'Brien's February 19,2016 email. Attached as are the relevant 

page's from OLC's April 20 monthly report disclosing the transfer. (See Attachment 1.) 

In addition, attached are the Oklahoma state campaign finance reports of the unregistered 

corrunittees that make up contributions in the amount of $7,150. These reports demonstrate that 

each uruegistered committee had sufficient permissible fimds to make each donation. (See 

Attachment 2.) Accordingly, OLC has materially complied with the audit division's 

recommendations. 
JONES DAY 

Teny O'Brien 

May 23,2016 

Pages 

Conclmton 

We respectfully request that the Audit Division, Office of the General Counsel, and die 

Commission fiiirly and objectively review the DFAR and the responses submitted on behalf of 

our client, OLC. The record in this matter clearly demonstrates that OLC has fiilly cooperated 

with the Audit Division in an effort to resolve this audit as expeditiously as possible. 

Attachments