December 1, 2016 

Re: Response to DFAR, Kind for Congress 

To Whom It May Concern, 

The Committee has no new comments on the DFAR and stands by the. position that it took in 

replying to the Interim Audit Report. For the.Corhmission's convenience, that position is copied 

below: 

The Committee would like to thank the Federal Elections Commission staff throughout this 

exercise for their courteousness and professionalism. We strive to Conduct ourselves with the 

utmost transparency, and we are pleased that the results of this audit underscore the 

importance that the Committee has long emphasized of ensuring complete transparency of 

cjonors. To that end, we already go far beyond existing regulations by maintaining a policy of 

fully disclosing every contributor to our Committee, whether or not that contributor meets the 

$200 itemization threshold. 

This audit was a healthy and extensive exercise. We are pleased that this exercise has hcit 

resulted in any findings of missing funds, lack of disclosure, misappropriations, or any 

other indication of financial or reporting discrepancies, and the Committee recognizes that 

the only finding is that a portion of donations were not deposited to our local financial institution 

in La Crosse, Wl in a timely manner. 

With respect to this lone finding, the Committee acknowledges the issue and has prpactively 

taken a number of steps to address the finding, which have already fixed the issue. The 

Committee also respectfully submits that the statute and FEC rules are unclear with respect to 

the timeliness of deposits - they couid easily be read to allow 20 days - but regardless, the 

Committee has now taken a number of actions to ensure deposits occur within 10 days.^ 

The Committee would also like to note that many of the contributions that took longer than 10 

days to be deposited into our La Crosse, Wi financial institution were not received in La Crosse, 

and therefore had to be mailed to the campaign in La Crosse, and then physically deposited. 

Unfortunately, as many Wisconsinites are aware, mail delivery to rural areas has gotten 

slower over the years due to a variety of factors, in fact, rural mail delivery can sometimes 

take weeks. The FEC's one-size-fits-all policy on timeliness of deposits does not take into 

account that mail delivery in rural areas is generally much slower than in big cities or on the 

coasts. 

Despite the lack of clarity in the law and the additional challenge for rural communities, the 

Committee has already enacted a number of changes to ensure that all donations are 

now deposited in a more timely manner. The changes that we have proactiveiy made 

include: 

1. We have engaged a professional compliance-firm to further ensure compliance 

with all applicable rules. 

• The law provides that "[e]very person who receives a contribution for an authorized political committee shall, 

no later than 10 days after receiving such contribution, forward to the treasurer such contribution.' 52 U.S.C. § 

30102(b)(1). Thereafter, FEC rules provide that '[a]il deposits shall be made wlthln 10 days of the treasurer's 

receipt.' 11 C.F.R. § 103.3. Thus, statute and mie could be construed to indicate that a committee-has 20 

days to deposit, for any contribution that is not sent directly to the treasurer. 
2. Wisconsin staff now make deposits of contributions on a weekiy basiSi to ensure 

timely deposits of ail contributions received in the district. 

3. We have a new campaign Treasurer, and campaign staff has received additional 

training regarding compliance rules. 

4. When donations are received by campaign staff in Washington, DC, they are now 

deposited directly Into a DC branch of our financial institution. This was a 

suggestion by.FEC staff, and helps address the challenge of ensuring timely 

deposits despte the feet that rural mail delivery can often take many days or even: 

weeks. 

5. In addition to continuing our practice of kbepihg ail records required by FEC rules, 

see 11 C.F.R. § lb2.9(a), we are keeping ail additional records relevant to when 

contributions are received, including eiivelopes and additional paperwork. 

I 

The Committee is confident that with these changes that have already been irnpiemented, ^ 

we will ensure the timely deposit of ail contributions in the future. | 

Again, we are pleased that there were no findings of missing funds, lack of disclosure, 

misappropriations, or any other financial or reporting discrepancies, and we have 

proactively addressed the single finding to ensure timely deposits. Thank you to the FEC 

staff for their hard work and professional demeanor throughout this extensive process. We look 

fonward to continuing to work with the FEC as we go above and beyond the regulations to 

ensure an open, transparent and weil-prganized campaign committee. 

Brent. Smith, Treasurer 
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Re: Response to DFAR 

Ryan Cornett <cornett.ryan48@gmall.com> 

O Sun 12/4,8:19 AM 

Christina Cmssiah 

H 

You replied on 12/9/2016 11:07 AM. 

I have confirmed we do not want to request a hearing. 

Sent from my U.S. Cellular® Smartphone 

1 of] 12/1S/2016 12:00 PM