the 

BESPOKE 

GROUP 

July 2,2010 

Joseph F. Stoltz 

Assistant Staff Director 

999 E Street, NW 

Washington, DC 20463 

Dear Sir: 

The Republican Party of Kansas (RPK) is in receipt ofthe Interim Audit Report (lAR) issued by^ 

the Federal Election Commission (FEC) on May 14,2010 and received by the RPK on May 23,2010. 

The original due date for a response from the RPK was May 21,2010. On June 17,2010 the RPK 

requested and received a 15 day extension. Accordingly, the RPK's response to the FEC's lAR is due on 

July 6,2010. 

The RPK has submitted ail reports to be amended for the 2007 and 2008 calendar years to the 

FEC for an initial informal review. Subsequent to this review, the RPK has amended reports for the entire 

audit period. Additionally, the RPK has amended reports for 2009 and 2010 to date lo correct minor 

filing errors and reallocate shared federai and state expenses. The RPK considers these amendments as a 

full and complete response to the FEC's Finding 1. "Misstatement of Financial Activity." 

In addition to these amendments, more information must be communicated to fully respond to the 

FEC's Findings 2. "Receipt of Apparent Prohibited Contributions." 

The FEC noted severable contributidns from sources that it presumed to be prohibited. The RPK 

agrees with this finding. These contributions, were received from corporations or from Limited Liability 

Companies that file their taxes as corporation. These contributions were placed in the RPK's Federal 

Account. These contributions should have been placed in the RPK's State Account and reported to the 

Kansas Govemment Ethics Commission. A portion of one contribution was refunded to the contributor 

(see enclosed check copy). The RPK has secured the consent of these contributors to transfer these 

contributions to the RPK State Account. These contributions will continue to be reported on the RPK's 

Federal FEC Reports as debts owed to the RPK State Committee until such tune as the RPK has sufficient 

fiinds to transfer those contributions to the RPK State Account. 

. The FEC's third and final fmding is Findmg 3. "Payment of Federal Activity Out of Non-federal 

Accounts." The FEC notes that the RPK made payments from the RPK's State Account for various 

federal expenses. THE FEC advised that thc RPK should either demonstrate that these payments were for 

non-federal expenses or report these transactions as memo entries on the appropriate reports. A review of 

the RPK's amended reports reveal that, due to scant records, the RPK is unable to demonstrate lhat these 

expenses were incurred for non-federal purposes and has reported them on the RPK's amended federal 

reports. 

www.bespokekc.coin 

140 Walnut, Suite 202, Kansas City, Missouri 64106 1 p: 816.569.5435 I F: 816.549.5436 campaign fino!ice I public affairs consulring 
It is important to note that afier reviewing transfers and reimbursements between the Federal and 

State Accounts, the FEC found that the RPK State Account could have reimbursed the RPK Federal 

Account an amount in excess of the amounts at issue. The FEC notes: 'Therefore, after considering all 

adjustments, it is concluded that there was no net funding of the federal activity by thc non-federal 

committee at the end of the two year audit period and only the disclosure issues need to be addressed by 

the RPK." As such, the reporting of these expenses represent reporting and filing errors and not improper 

funding of federal activity with non-federal funds. 

The RPK believes that several mitigating factors indicate that leniency is warranted in the current 

case. To demonstrate, the RPK attaches a copy of a letter from the current Treasurer of the RPK 

indicating remedial actions taken by the committees to address the financial misstatements on the FEC 

reports and intemal accounting irregularities at the RPK. The RPK also notes the continuous and ongoing 

efforts of its staff and agents to resolve this matter to the satisfaction of the FEC, the public and 

supporters of the RPK. 

We are pleased to conclude this audit process and look forward to resolving any additional issues 

identified by the FEC and its staff. If you have any additional questions or wish to discuss this 

correspondence or the amended reports filed by the RPK, please do not hesitate to contact me at (816) 

569-5435. 

/ V 

Amy R. Blunt 
KANSAS REPUBLICAN PARTY 

i(i?iav\Bji;vs?w;.-?.«;-..-.--.::>-- •; •;.••„ • 

AMANDA L. ADKINS. CHAIR 

June 30,2010 

Federal Election Commission 

Attn: Joseph F. Stoltz 

Assistant Staff Director 

999 E Street, NW 

Washington, DC 20463 

Dear Sir: 

T appreciate the veiy professional and courteous manner in which your audit team uncovered and 

detailed several deficiencies in the RepubUcan Party of Kansas's (RPK) 2007 and 2008 Reports of 

Receipts and Disbursements. 

The officers and staff of the RPK take very seriously our obligations to the Party and all of its 

members as well as our obligation to observe the law. When first contacted by the Federal Election 

Commission (FEC), shortly afier I became the Treasurer the new Chairman and Executive Director were 

hired, we engaged an accounting firm to conduct a complete audit. The accounting firm confirmed that 

the previous leadership team left inadequate records and that an audit was impossible. 

I want to emphasize that the Party headquarters is veiy small. In 2007 and 2008 it had only two 

people on staff. Unfortunately the former Executive Director, was essentially unsupervised. 

In 2009, the newly elected officers and the newly hired staff - there were no carry over personnel 

from, the previous years - took several actions upon leaming ofthe federal reporting problems. 

• The RPK and its agents and consultants reviewed ali available information; 

• RPK staff participated in FEC provided training; 

• The RPK hired an accounting firm to assist us in establishing and revamping our 

procedures to bring them into compliance with FEC safe-harbors; 

• The RPK leadership team increased oversight and approval process for check writing, 

balance reconciliation and intemal auditing; 

• We eliminated unnecessary and duplicative bank accounts; 

• The RPK hired a consulting firm experienced in election laws and procedures to review 

our 2007 and 2008 books and to recreate both electronic and paper files; 

• Additionally, we made changes to our corporate govemance documents to codify new 

policies and procedures. 

Throughout the FEC audit process, the staff of the RPK have cooperated fully with the FEC and 

its auditors. We are vety grateful for their patience as we attempt to comply with their requests for 

infonnation. We are also grateful for their guidance in improving our procedures. 

POBox 4157 

Topeka. KS 66604 

republlcanpartyC^ksgop.org 

Paid fbr and authorized by the Kansas Republican Party with regulated funds. 

PO Box 4157, Topeka. KS 66604 

Not authorized by any candidate or candidate oommitte& 

Phone 785-234-3456 

Fax 785-228-0353 

wvvw.ksg6p.org 
KANSAS REPUBLICAN PARTY 

AMANDA L ADKINS. CHAIR. 

We agree with many of the findings detailed in the Interim Audit Report issued by the FEC and 

we have taken decisive and immediate corrective action to implement the FEC's audit findings. The RPK 

has also made substantial improvements to the overall management and conduct ofthe Party's financial 

affairs. The Executive Committee of the Party and the State Delegates have been kept informed as these 

actions have been taken. 

While the RPK acknowledges that there were significant reporting inconsistencies and deviations 

from the best practices recommended by the FEC during the audited time period, we believe that they 

were largely the result of the negligence and poor administration ofthe staff employed during that time 

period. We neither believe, nor have we found evidence to support a finding that there was malicious 

intent or a motive of active concealment by the former RPK staff and administration. 

We also believe that the significant and timely remedial action taken by the RPK and its staff 

since the RPK became aware of these issues as well as the leadership of an entirely new administrative 

team support the application of leniency in this case. A significant fine would present an undue hardship 

for the RPK. The committee has already incurred significant expenses as a result of the audit process. 

Additionally, in the coming months, it will be necessary to raise a significant amount of money into the 

party's federal account so that transfers can be made from the federal to the non-federal account to fully 

implement the FEC's audit findings and recommendations. 

I am proud of the efforts our team has made to address the concems of the FEC during the past 

eighteen months. On behalf of all of us who have worked with the FEC staff, thank-you for the assistance 

and many courtesies that have been shown to us. We appreciate your difficult work in guiding 

organizations such as ours to comply with applicable laws and mlings. As always, please do not hesitate 

to contact me with any additional questions or needs. 

Best regards. 

Kansas Republican Party 

cc: KRP Chair 

KRP Vice-Chair 

KRP Secretary 

KRP Executive Director 

Amy Blunt, Bespoke 

PO Box 4157 

Topeka. KS 66604 

republicanparty@ksgop.org 

Raid fbr and authorized by the Kansas Ftepublican Party with regulated fiinds. 

PO Box 4157. Topeka, KS 66604 

Not authorized by any candidate or candidate committee. 

Phone 785-234-3456 

Fax 785-228-0353 

vwvw.ksgop.org