Interim Audit Report of the 

Audit Division on the New 

Jersey Republican State 

Committee

(January 1, 2015 - December 31, 2016)

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.1 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 New Jersey Republican State Committee is a state party 

committee headquartered in Trenton, New Jersey. For more 

information, see the chart on the Committee Organization, p.2.

Financial Activity (p. 2)

• Receipts

o Contributions from Individuals

o Contributions from Political 

Committees

o Transfers from Affiliated 

Committees

o Other Receipts

Total Receipts

$ 1,103,366

315,325

1,593,755

2,265

$ 3,014,711

• Disbursements

o Operating Expenditures

o Transfers to Affiliated Committees

o Coordinated Party Expenditures

o Contribution Refunds

o Federal Election Activity

o Other Disbursements

Total Disbursements

$ 1,055,532

1,605,635

93,721

23,110

335,379

61,500

$ 3,174,877

Findings and Recommendations (p. 3)

• Misstatement of Financial Activity (Finding 1)

• Reporting of Debts and Obligations (Finding 2)

 1

 52 U.S.C. §30111(b).
Interim Audit Report of the Audit 

Division on the

New Jersey Republican State 

Committee

(January 1, 2015 - December 31, 2016)
Table of Contents

Page

Part I. Background

Authority for Audit 1

Scope of Audit 1

Part II. Overview of Committee

Committee Organization 2

Overview of Financial Activity 2

Part III. Summaries

Findings and Recommendations 3

Part IV. Findings and Recommendations

Finding 1. Misstatement of Financial Activity 4

Finding 2. Reporting of Debts and Obligations 5
1

Part I

Background

Authority for Audit

This report is based on an audit of the New Jersey Republican State Committee (NJRSC), 

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 52 U.S.C. §30111(b), which permits 

the Commission to conduct audits and field investigations of any political committee that 

is required to file a report under 52 U.S.C. §30104. Prior to conducting any audit under 

this subsection, the Commission must perform an internal 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. 52 U.S.C. §30111(b).

Scope of Audit

Following Commission-approved procedures, the Audit staff evaluated various risk 

factors and as a result, this audit examined: 

1. the receipt of excessive contributions;

2. the receipt of contributions from prohibited sources;

3. the disclosure of contributions received;

4. the disclosure of individual contributors’ occupation and name of employer;

5. the disclosure of disbursements, debts and obligations;

6. the disclosure of expenses allocated between federal and non-federal accounts;

7. the consistency between reported figures and bank records;

8. the completeness of records; and

9. other committee operations necessary to the review.
2

Part II

Overview of Committee

Committee Organization

Overview of Financial Activity

(Audited Amounts)

Cash-on-hand @ January 1, 2015 $ 237,334

Receipts

o Contributions from Individuals $ 1,103,366

o Contributions from Political Committees 315,325

o Transfers from Affiliated Committees 1,593,755

o Other Receipts 2,265

Total Receipts $ 3,014,711

Disbursements

o Operating Expenditures $ 1,055,532

o Transfers to Affiliated Committees 1,605,635

o Coordinated Party Expenditures 93,721

o Contribution Refunds 23,110

o Federal Election Activity 335,379

o Other Disbursements 61,500

Total Disbursements $ 3,174,877

Cash-on-hand @ December 31, 2016 $ 77,168

Important Dates

• Date of Registration July 23, 1982

• Audit Coverage January 1, 2015 - December 31, 2016

Headquarters Trenton, New Jersey

Bank Information

• Bank Depositories Three

• Bank Accounts Three Federal, Three Non-Federal

Treasurer

• Treasurer When Audit Was Conducted April Bengivenga

• Treasurer During Period Covered by Audit John O. Bennett, January 1, 2015 - March 

17, 2015 

James Foerst, March 18, 2015 -

December 31, 2016

Management Information

• Attended FEC Campaign Finance Seminar Yes

• Who Handled Accounting and 

Recordkeeping Tasks

Paid Staff
3

Part III

Summaries

Findings and Recommendations

Finding 1. Misstatement of Financial Activity

During audit fieldwork, a comparison of NJRSC’s reported financial activity with its 

bank records revealed a misstatement of receipts and disbursements in calendar year 

2016. Specifically, NJRSC understated its receipts and disbursements by $100,000 and 

$99,980, respectfully. Subsequent to the exit conference, NJRSC filed an amended 

disclosure report that corrected the receipts and disbursements. The Audit staff 

recommends that NJRSC provide any additional comments it may have with respect to 

this matter.

(For more detail, see p. 4.)

Finding 2. Reporting of Debts and Obligations

During audit fieldwork, the Audit staff noted that NJRSC failed to disclose debts and 

obligations owed to eight vendors totaling $58,324. The Audit staff recommends that, 

absent documentation demonstrating that these expenditures did not require reporting on 

Schedule D (Debts and Obligations), NJRSC amend its reports to disclose these debts or 

file a Form 99 (Miscellaneous Text Submission) to disclose these debts.

(For more detail, see p. 5.)
4

Part IV

Findings and Recommendations

Finding 1. Misstatement of Financial Activity

Summary

During audit fieldwork, a comparison of NJRSC’s reported financial activity with its 

bank records revealed a misstatement of receipts and disbursements in calendar year 

2016. Specifically, NJRSC understated its receipts and disbursements by $100,000 and 

$99,980, respectfully. Subsequent to the exit conference, NJRSC filed an amended 

disclosure report that corrected the receipts and disbursements. The Audit staff 

recommends that NJRSC provide any additional comments it may have with respect to 

this matter. 

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 total amount of receipts for the reporting period and for the calendar year; 

• the total amount of disbursements for the reporting period and for the calendar 

year; and

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

Schedule B (Itemized Disbursements). 52 U.S.C. §30104(b)(1), (2), (3), (4), and 

(5).

Facts and Analysis

A. Facts

During audit fieldwork, the Audit staff reconciled NJRSC’s reported financial activity 

with its bank records for calendar years 2015 and 2016. The reconciliation determined 

that NJRSC misstated receipts and disbursements for 2016. The following chart details

the discrepancies between NJRSC’s disclosure reports and bank activity. The succeeding 

paragraphs explain why the discrepancies occurred.

2016 Committee Activity

Reported Bank Records Discrepancy

Beginning Cash Balance @ 

January 1, 2016

$62,830 $59,129 $3,701

Overstated 

Receipts $2,606,298 $2,706,298 ($100,000)

Understated

Disbursements $2,588,279 $2,688,259 ($99,980)

Understated

Ending Cash Balance @ 

December 31, 2016

$80,849 $77,168 $3,681

Overstated
5

The beginning cash balance was overstated by $3,701 and is unexplained, but likely

resulted from prior period reporting discrepancies.

The misstatement of receipts resulted from the following difference:

• Transfer from affiliated committee not reported $100,000

Understatement of Receipts $100,000

The misstatement of disbursements resulted from the following differences:

• Transfer to affiliated committee not reported $99,980

• Wire fee for transfer to affiliated committee not reported 20

• Transfer to affiliated committee reported incorrectly (20)

Net Understatement of Disbursements $99,980

B. Interim Audit Report & Audit Division Recommendation

At the exit conference, the Audit staff discussed the misstatements for calendar year 2016 

with NJRSC representatives and provided schedules detailing the misstatements. NJRSC 

representatives did not provide any comments. 

Subsequent to the exit conference, NJRSC filed an amended disclosure report that 

corrected the receipts and disbursements.

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

NJRSC provide any additional comments it may have with respect to this matter.

Finding 2. Reporting of Debts and Obligations

Summary

During audit fieldwork, the Audit staff noted that NJRSC failed to disclose debts and 

obligations owed to eight vendors totaling $58,324. The Audit staff recommends that, 

absent documentation demonstrating that these expenditures did not require reporting on 

Schedule D (Debts and Obligations), NJRSC amend its reports to disclose these debts or 

file a Form 99 (Miscellaneous Text Submission) to disclose these debts.

Legal Standard

A. Continuous Reporting Required. A political committee must disclose the amount 

and nature of outstanding debts and obligations until those debts are extinguished. 52 

U.S.C. §30104(b)(8) and 11 CFR §§104.3(d) and 104.11(a).

B. Separate Schedules. A political committee must file separate schedules for debts 

owed by the committee and debts owed to the committee, together with a statement 

explaining the circumstances and conditions under which each debt and obligation 

was incurred or extinguished. 11 CFR §104.11(a).
6

C. Itemizing Debts and Obligations.

• A debt of $500 or less must be reported once it has been outstanding 60 days from 

the date incurred (the date of the transaction); the committee reports it on the next 

regularly scheduled report.

• A debt exceeding $500 must be disclosed in the report that covers the date on 

which the debt was incurred. 11 CFR §104.11(b).

Facts and Analysis

A. Facts

During audit fieldwork, the Audit staff reviewed NJRSC’s disbursement records and 

disclosure reports for proper reporting of debts and obligations. This review identified 

debts owed to eight vendors totaling $58,3242 that NJRSC failed to report on Schedule D 

during the audit period. Based on a review of the records, these vendors mainly provided 

parking space, utilities3, marketing, advertising, solicitation/fundraising, consulting, and 

legal services. NJRSC reported debt totaling $91,849 on Schedule D during the audit 

cycle. The Audit staff calculated the debts owed to the vendors based on the invoice date 

and the subsequent payment date.

4

 Debts were outstanding for periods ranging from 18 

to 3005 days.

B. Interim Audit Report & Audit Division Recommendation

The Audit staff discussed the reporting of debts and obligations with NJRSC 

representatives at the exit conference and provided a schedule detailing the transactions 

requiring disclosure on Schedule D. NJRSC representatives asked questions pertaining to 

the calculation of debt, and stated that they would verify the amounts paid. 

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

NJRSC provide additional documentation demonstrating that these transactions were not 

obligations which required reporting on Schedule D. Absent such documentation, the

Audit staff recommends that NJRSC amend its reports or file a Form 99 (Miscellaneous

Text Submission)

6 to correctly disclose these debts and obligations on Schedule D.

 2

 Each debt in this amount was counted only once even if it was required to be disclosed over multiple periods. 3

 Utilities were gas and electric payments for a NJRSC satellite office. The debt was incurred in 2014 but 

was not paid until March 2015. Therefore, the debt should have been reported on the 2015 February 

Monthly, March Monthly, and April Monthly reports. 4

 For one vendor, where the invoice date was unavailable, the ending date of the period of service for 

which the service was performed was utilized. For example, if services were performed during the 

period ranging from April-June 2015, then the Audit staff used June 30, 2015 as the invoice date. 5

 Two debts were outstanding for 18 and 29 days, respectively. Both of these items were outstanding at the 

end of reporting periods and therefore reportable. 6

 If the committee chooses to file a Form 99 instead of amending its disclosure reports, the form must 

contain all pertinent information that is required on each schedule.