· r-J_tFEDERAL ELECTION CO~1J\1ISSI0N AK007004

September 27, 1995

MEM.ORANDUM

TO:

FROM:

SUBJECT:

RON M. HARRIS

PRESS OFFICER

PRESS OFFICE

ROBERT J. COSTA

ASSISTANT STAFF DIRECTOR

AUDIT DIVISION

PUBLIC ISSUANCE OF THE FINAL AUDIT REPORT OR

FRIENDS OF MARC LITTLE

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Attached please find a copy of the final audit report

and related documents on Friends of Mare Little which-was

approved by the Commission on September 21, 1995.

Informational copies of the report have been received by

all parties involved and the report may be released to the

public.

Attachment as stated

cc: Office of General Counsel

Office of Public Disclosure

Reports Analysis Division

FEe Library

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REPORT OF THE AUDIT DIVISION

ON

Friends ofMarc Little

Approved September 21, 1995

FEDERAL ELECTION COMML...~ION

999 E STREET, N.W.

WASHINGTON. D.C.
TABLE or COH'l'Elft'S

FRIENDS or MARC LI'rTLE

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Executive Sn...ry

Pinal Audit Report

Background

Findings

Legal Analysis

Transmittal to Ca..ittee

Chronology

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FEDER,>\l ELECTION COtvVv'ISSION

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FINAL AUDIT REPORT

ON

FRIENDS OF MARC LITTLE

EXECUTIVE SUMMARY

Friends of Marc Little (the Committee) regi~tered with the

Clerk of the U.S. House of Representatives on December 8, 1993

as the principal campaign committee for Marc Little, Republican candidate for the u.s. House of Representatives, Florida, 3rd

District.

The audit was conducted pursuant to 2 U.S.C. S438(b), which

states, that the Commission may conduct audits of any political

committee whose reports fail to meet the threshold level of

compliance set by the Commission.

The findings of the audit were presented to the Cem.ittee

at an exit conference held after the audit fieldwork (5/17/95)

and later in an interim audit report.

The candidate responded that during the campaign he did not

approve any bank deposits or sign any campaign checks.

According to the candidate, he cannot afford the t1ae or .aney

to go back to vendors to get missing invoices, obtain canceled

checks, obtain information for in-kind contributions, provide

evidence that contributions were not from corporations, refund

money to contributors, and find contributors to expl,ain excessive contributions. He hired a campaign manager, who

appointed treasurers, who were accountable for the activities.

They were responsible for maintaining this inforaation. He

concluded that he i8 not responsible for the issues detailed in

the interim audit report. As a result, the Committee did not

comply with any of the recommendations.

The following is an overview of the findings contained in

the final audit report.

Failure to Maintain Disbursement Records - 2 u.s.c.

S432(c)(1),(2),(S), and (d); 11 CFR 100.7(a)(1) and 100.8(a)(1).

The Committee did not maintain canceled checks for $97,377 in

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disbursements. Of the disbursements that exceeded $200, the

Committee did not provide a canceled check, invoice, or

receipted bill to support $34,898. The Committee also did not

maintain any documentation to support $12,237 in in-kind

contributions.

Prohibited Contributions - 2 U.S.C. S441(b); 11 CFR

l03.3(b)(4). The Committee received $4,803 in prohibited

contributions from corporations.

Excessive Contributions - 2 u.s.c. S441a(a)(1)(A) and 441£;

11 CFR 110.4(b) and 103.3(b). One individual made a total of

$4,000 in contributions for the general election, exceeding the

contribution l~itation by $3,000. The excessive amount vas

attributed to three other individuals.

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FEDERAL ELECTION COMMISSION

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REPORT OF THE AUDIT DIVISION

ON

FRIENDS OF MARC LITTLE

I. Background

A. Overview

This report is based on an audit of Friends of Marc

Little (the ·Committee"), undertaken by the Audit Division of

the Federal Election Commission in accordance with the

provisions of the Federal Election Campaign Act of 1971, as

amended (-the Act"). The audit was conducted pursuant to

Section 438(b) of Title 2 of the United States Code which

states, in part, that the Commission may conduct audits and

field investigations of any political committee required to file

a report under section 434 of this title. Prior to conducting

any audit under this subsection, the Commission shall perform an

internal review of reports filed by selected ca.aittees to

determine if the reports filed by a particular ca-ittee meet

the threshold requirements for substantial compliance with the

Act.

The audit covered the period from September 13, 1993,

the inception of the Commit~ee, through December 31, 1994.

The Committee reported a beginning cash balance of $0; total

receipts for the period of $214,221; total disbursements for the

period of $212,238; and an ending cash balance of $1,983.!1

B. Campaign Organization

The Committee registered with the Clerk of the U.S.

House of Representatives on December 8, 1993 as the principal

campaign committee for Marc Little, Republican candidate for the

U.S. House of Representatives, District 3, from the state of

Florida. The Committee maintained its headquarters in

Jacksonville, Florida.

1/ All figures in this report have been rounded to the nearest

dollar.

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Frlt'~d. oi~?'*rc" Litti';;\~atlliMi1: iNaAudit Report

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The audit indicated that the 90\ of the Committee'.

receipts were contributions from individuals, 6% from Political

Action Committees and the rest from offsets to operating

expenditures, a loan from the candidate and contribution. from

political party committees.

This report is based on documents and workpapers which

support each of its factual statements. They form part of the

record upon which the Commission based its decisions on the

matters in the report and were available to the Commissioners

and appropriate staff for review.

c. Key Personnel

The Treasurers of the Committee during the period covered by the audit were Mr. Clive Stephenson from inception to

OCtober 11, 1994 and Ms. Eleanor M. Christen from OCtober 11,

1994 to January 17, 1995.!1

D.

categories:

Scope

The audit included testing of the following general

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1. The receipt of contributions or loans in excess of • the statutory limitations (see Findings II.C.);

2 • the receipt of contributions from prohibited

sources, such AS those from corporations or labor

organizations (see Pinding II.B.);

3. proper disclosure of contributions f~ individuals,

political ca..ittees and other entities, to include

the itemization of contributions when required, as

well as, the caapletenes8 and accuracy of the

information disclosed:

4. proper disclosure of disbursements including the

itemization of disbursements when required, as well

as, the completeness and accuracy of the information

disclosed;

s. proper disclosure of campaign debts and obligations:

2/ Mr. Stephenson resigned from the Committee on September 20,

1994 but the Amended Statement of Or9an~zation was not

received at the Commission until OCtober ~l, 1994.

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Friends of Marc Little Committee

Audit Report

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6. the accuracy of total reported receipts,

disbursements and cash balances as compared to

campaign bank records;

7. adequate recordkeeping for campaign transactions

(see Finding II.A)i

8. other audit procedures that were deemed necessary in

the situation.

An Interim Audit Report was sent to the Committee on

June 3D, 1995. The candidate responded on August 2, 1995. He

stated that during the campaign he did not approve any bank

deposits or sign any campaign checks. According to the

candidate, he cannot afford the time or money to go back to

vendors to get missing invoices, obtain cancelled checks, obtain

information for in-kind contributions, provide evidence that

contributions were not from corporations, refund money to

contributors, and find contributors to explain excessive

contributions. He hired a campaign manager, who appointed

treasurers, who were accountable for the activities. They were

responsible for maintaining this information. He concludes that

he is not responsible for the issues detailed in the Interim

Audit Report. As a result, the Committee did not comply with

any of the recommendations.

As part of the Interim Audit Report, the Audit staff

stated they were not able to complete reviews due to the lack of

disbursement records (see Finding Il.A below). Unless

specifically discussed below, no material non-ca-pliance was

detected. Also, it was noted that the Commission may pursue any

of the matters discussed in the report in an enforcement action.

II. Findings and Recommendation

A. Failure to Maintain Disbursement Records

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Sections 432(c)(1), (2), (5), and (d) of Title 2 of

the United States Code state, ~n part, that the treasurer of a

political committee shall keep an account of all contributions

received by or on behalf of such political committee and

the name and address of any person who makes any contribution in

excess of $50, together with the date and amount of such

contribution by any person~ and the name and address of every

person to whom any disbursement is made, the date, amount, and

purpose of the disbursement, including a receipt, invoice, or

cancelled check for each disbursement in excess of $200. The

treasurer shall preserve all records required to be kept by this

section and copies of all reports required to be filed by this

subchapter for 3 years after the report is filed.

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Sections 100.7(4)(1)(iii)(A) and 100.8(a)(1)(iv)(A)

of Title 11 of the Code of Federal Regulations state, in part,

that the terms contributions and expenditures include anything

of value, which includes in kind contributions.

The Committee did not maintain cancelled checks for

$97,377 of their disbursements, however, it did maintain

receipts and invoices to support many of the disbursements.

These records were not maintained in any particular order. The

Committee records also contained all of the bank statements and

check registers for part of the period. Using these records and

the Committee's disclosure reports which itemized nearly all

disbursements, the Audit staff attempted to associate the

expenditures itemized on the report with the receipts and

invoices provided by the Committee. Of the disbursements that

exceeded $200, the Committee did not provide a cancelled check,

invoice, or receipted bill to support $34,898.

The Committee also did not maintain a complete record

of the expenditures made during the campaign. Using other

available records, including printouts of Committee

disbursements, hand written summaries of checks, and the above

documentation, the Audit staff was able to find some record,

beyond an entry on a bank statement, for all but $17,447 in

Committee disbursements. All of these disbursements were • itemized on the Committee's disclosure reports. Also, $13,627

of the $17,447 is included in the $34,898 noted above.

In addition, during the audit period, the COBaittee

reported receiving in-kind contributions fro. individuals

totaling $24,170. The Audit staff could not locate 8Upport for

$12,237 of the reported in-kind contributions in the COBaittee

records.

The Commit~ee was provided lists of the disbursements

discussed above at the exit conference. As of the date of the

Interim Audit Report, the C01lll\i.t.t:ee had not submitted any

additional records.

In the Interi-:...'udit Report recOllBDendation the

Committee was to either; ,1) contact the vendors and attempt to

get missing invoices, c= S~ ether statement from the vendor to

support the disburseme~l~s and submit copies of the letters sent

and responses receive~7 and/or (2) obtain and submit copies of

both sides of the ~ancel~ed checks fra. its bank supporting the

$34,898 in disburaemen~s. The Committee was to also submit

additional information concerning the $17,447 and the $12,237 in

in-kind contributions for which no records were presented.

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Friends of 'Marc Little Committee

Audit Report

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B. Prohibited Contributions

Section 441b of Title 2 of the United States Code

states, in part, that it is unlawful any national bank,

corporation, or labor organization to make a contribution or

expenditure in connection with any election at which a

Representative in Congress is to be voted for or for any

candidate, political committee, or other person knowingly to

accept or receive any contribution prohibited by this section.

Section 103.3{b)(4) of Title 11 of the Code of

Federal Regulations states that any contribution which appears

to be illegal under 11 CFR 103.3(b)(1) or (3), and which is

deposited into a campaign depository shall not be used for any

disbursements by the political committee until the contribution

has been determined to be legal. The political committee must

either establish a separate account in a campaign depository for

such contributions or maintain sufficient funds to make all such

refunds.

The Audit staff conducted a 100\ review of

contributor check copies for possible prohibited contributions.

Upon verification with various Secretaries of State, it was

determined that the Ca.mittee had received 31 contributions

totaling $4,803 from 28 entities that are apparently

incorporated. There was no record that the Committee had .ade

any attempt to dete~ine whether these contributions were from

prohibited sources. The Comaittee did not maintain a separate

account or maintain sufficient funds to refund these

contributions, as required by 11 CFR S103.3(b)(4).

At the completion of fieldwork the Committee was

supplied with the list of verified corporate contributions.

In the Inter~ Audit Report recODDDendation the

Committee was to provide evidence that demonstrated these

contributions were not fro. corporations. Absent such a

demonstration, the Committee was to refund the contributions and

provide evidence of the refunds (photocopies of the front and

back of the canceled check). If money was not available, the

Committee was to repo~ debts owed to the contributors, and

refund these contributions from the next available funds that it

received.

C. Excessive Contributions

Section 441a(a)(1)(A) of Title 2 of the United States

Code states that no person shall make contributions to any

candidate and his authorized political committees with respect

to any election for Federal office which, in the aggregate,

exceed $1,000.

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Friends of Marc Little Committee

Audit Report

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Section 441f of Title 2 of the United States Code

states, that no person shall make a contribution in the name 01

another person or knowingly permit his name to be used to effecL

such a contribution, and no person shall knowingly accept a

contribution made by one person in the name of another

person.

Section 110.4(b)(iv)(2)(ii) of Title 11 of the Code

of Federal Requlations states, in part, that an example of a

contribution in the name of another includes, makinq a

contribution and attributing the source as another person when

in fact the contributor is the source.

Section 103.3(b)(4) of Title 11 of the Code of

Federal Regulations states that any contribution which appears

to be illegal under 11 CFR l03.3(b)(1) or (3), and which is

deposited into a campaign depository shall not be used for any

disbursements by the political committee until the contribution

has been determined to be legal. The political committee must

either establish a separate account in a campaign depository for

such contributions or maintain sufficient funds to make all such

refunds.

During the Audit staff review of the Committee's

contributor records and contributor check copies, we noted a .- contributor, L. John Arbizzani, who contributed $1,000 for the

primary election and $1,000 for the general election. In

addition, Mr. Arbizzani made an additional $3,000 in

contributions on OCtober 14, 1994. On the memo lines of each

check were the names of three individuals. The Committee

included the names of these other individuals in the records and

on its disclosure reports as the source of these contributions.

The Committee was provided this information at the exit

conference.

There was no record that the Committee had made any

attempt to determine whether these contributions were from the

three individuals on the memo lines of the checks. The

Committee did not maintain a separate account or maintain

sufficient funds to refund these contributions, as required by

11 CFR Sl03.3(b)(4).

In the Interim Audit Report recommendation the

Committee was to provide evidence that demonstrated these were

not excessive contributions and represented the personal funds

of the contributors recorded by the Committee, to include a

statement from the contributors. Absent such a demonstration,

the Committee was to refund the contributions and prOVide

evidence of the refund (photocopies of the front and back of the

canceled check). If money was not available, the Committee

was to report debts owed to the contributors, and refund these

contributions from the next available funds that it received.

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FEDERAL ELECTION COMMISSION

September 7 t 1995

Lavrence ". Nobl.

General Counsel

Kia Bright-Col••an

A••ociate General C un••l

Lorenzo Bolloway -1kA·

Assistant General Couns.l

Rhonda J. vosdingb f/n./

Attorney ,.".,

Proposed rinal Audit ••port Oft Priends of Rarc Little

(LIlA 1477)

TO: Robert J. Costa

Aaaistant Staff Direetor

Audit DiViSion,

John C. Surina '",j :,~ Staff Director J c:Jt" TIIROUGS:

PROM:

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Th. Office of General Coun••l ha. reviewed tbe propo••d Final

Audit Report on rriends of Marc Littl. (-tb. Co.aitt••-) subaitted

to this Office on August 7, 1995.1/ ~. following ...orandua

provides our coaaent. on the proposed report. If you have any que.tions concerning our co...nt., pl•••• contact Rhonda Voadingh, the attorney assigned to this audit.

Initially, ve note that we concur with the Audit Division's

reco..endationa contained in the propo••d rinal Audit Report.

1/ Since the proposed rinal Audit .eport does not include any iatters exeapt fro. public disclosure und.r 11 C.F.R. S 2.4, we

r.co..end that the Coaais.ion'. discus.ion of this docuaent be

conducted in open ••••ion. Throu9hout our co..ent., -FECAw refers

to the rederal Election C.apai9rl Act of 1971, as ••ended, 2 U.S.C.

IS 431-455.

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Memorandum to Robert J. Costa

proposed Final Audit Report on

Friends of Marc Little (LRA 1477)

'age 2

In the cover memorandum to the proposed Final Audit Report,

you asked whether, in the absence of a treasurer, "the candidate

should be held responsible for the matters noted in the report."

You explained that there has been a vacancy in the treasurer'.

office since January 17, 1995 and stated that you have been

working with the candidate throughout the audit. In discus.ions

with this Office, you explained that your question went to whether

the Interim Audit Report had been properly served on the Committee

in light of the fact that it was provided to the candidate. The

candidate had responded to the Interim Audit Report by disavowing responsib: ~ity for the issues raised in the Interim Audit Report.

On January 17, 1995, prior to the audit fieldwork, th@

Committee treasurer, Ellie Christen, and deputy treasurer, Jeanne

MacDonald, resigned. No one was appointed to fill these

position., and the Committee did not comply with any of thft

recommendations in the Interia Audit Report. The Interim Audit

Report wa. provided to the candidate on June 30, 1995, and he

responded to it on August 2, 1995. The candidate argued that the

campaign manager, Glorious Johnson, and Committee treasurers are

responsible for complying with the recommendations in the Interim

Audit Report "because they signed documents indicating they would

assume such responsibilities.-1/

The Office of General Counsel believes that the candidate i"

an agent of the Committee who .ay accept service of the Interia

Audit Report. W. alao believe the candidate .ay be re.pon.ible for responding to the reeo..endationa in the Interia Audit ••port. Under the FECA, the treasurer i. an &gent of the coaaittee.

2 U.S.C. S 432(a) (-No expenditure shall be aade without

authorization of the treasurer or designated agent."). Sisi1ar1y, if a candidate accepts or obligates funds of his or her authorized

committee, the candidate ha. acted as an agent of the coaaittee.

11 C.F.R. S l02.7(d). Thus, if a candidate serves as an agent of

his or her committee when the candidate accepts contributions or

obligates funds, by analogy, the candidate serves in this capacity also when he or she undertakes other activities normally aSBused

by the treasurer or on behalf of the committee. Cf. Karl Rove'

Co. v. Thornburrh, 39 F.3d 1273 (5th Cir. 1994) (Cindldate heta

personally I1a6 e for contractual obligation incurred by his

campaign committee).

2/ The responsibilities to which he referred include obtaining iissing invoices from vendors, copies of both sides of canceled

checks, information on in-kind contributions; providing evidence

to the Commission that contributions were not from corporations; refunding contributions; and finding contributors to explain

excessive contributions, as recomaended in the Interim Audit

Report. The candidate further contended that the campaign manager and Committee treasurers were -also responsible for keeping all

campaign data up-to-date and accessible."

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M••orandum to Robert J. Coata

proposed rinal Audit .eport on

rriends of Marc Little (LRA 1477)

Page 3

Furthermore, the Commission haa named individuals, including candidates, acting as treasurer as respondents in enforc••ent

matters where there was no committee treasurer and the candidate

has assumed the duties of treasurer. In determining whether to

name an individual as treasurer in a~ enforcement matter, the

Commission considers the following factors: 1) whether the

treasurer of record has ceased to perform his or her duti•• as

treasurer; 2) whether the individual acting as treasurer

maintained the committee's books and records; 3) whether the

individual acting as treasurer accepted contribut:O~la on behalf of

the committee; 4) whether the individual acting as ~~ea.ur.r made

expenditures on behalf of the committee; 5) whether the individual

acting as treasurer made deposits into and disburse.ents fro. the

committee's accounts; and 6) whether the individual acting as

treasurer filed the committee's financial reports. Se. rEe v.

Committee to Elect Bennie Batts, No. 87-5789 (S.D.N.V:-reS. 14,

1989). Although the 1nstant question does not arise in an

enforcement context, we believe the sa.e principles apply.

No one was appointed to the treasurer or deputy treasurer

position of the Committee. The candidate, however, perfor.ed the

duties required of a committee treasurer. When the treasurer and

deputy treasurer resigned their posts, the Committee'. check book

and other financial infor.ation were left in the candidate'.

control. rurtheraore, the candidate participated in the audit.

He attended the audit entrance and exit conferencea.31 Be alao

si9ned the State.ent of Availability of Records and the State.ent

of Bank Accounts and Cash on Band.4/ Moreover, notwithstanding his

disavowal of responsibility, the candidate accepted the Interia

Audit Report and provided a response to it.

In addition, the candidate did not argue that his receipt of

the Interia Audit aeport rendered the report invalid. Tbus, it

appears that neither the candidate nor the Co..itt•• ia

challenging the sufficiency of service of the Interi. Audit

Report. The candidate'S assertion that the ca.paigD .anager, Glorious Johnson, and Coaaittee treasurers are re.ponsible for

complying with the recomaendations in the Interi. Audit Report "because they signed docuaents indicating they would a.suae such

responsibilities" does not absolve the candidate from

3/ The foraer treasurer and deputy treasurer also attended the

entrance conference.

4/ The fora State.ent of Availability of Records contains the

itate.ent "I aa the treasurer of Coaaittee(s)." The

candidate crossed out "treasurer" and wrote "custodian." The form

Statement of Bank Accounts and Cash on Hand also contains the

statement "I aa the treasurer of Coaaittee(s)" and

asks for the signature of the treasurer. The candidate did not

replace the word ·treasurer" in the state.ent; he did, hovever,

replace it with ·custodian- on the signature line.

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'~~'~~~Z~;:::~~;~=:i'~E~=~;"" .ropo••~LYlft.l -Audl~.'port Oft

Friends of Marc Llt~l. (LBA 1.77)

.ag. C'

r••ponalbility.S/ ~h. rICA require. political coaaitt••• to

appoint a tr.a.urer. 2 u.s.c. S 432(a); 11 c.p.a. I 102.7.

railure to appoint a trea.urer cannot ab.olve • coaaitte. from

perlor.1ft9 ta.ka nor.ally undertaken by the treasurer.!/

Consequently, it wa. proper to provide the Interia Audit

aeport to the candidate, and the candidate vas r.sponsible for

r••ponding to the Interia Audit ••port.

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S/ The candidate did not provide the docuaents he ~lai.ed

lndicate the c••paign 88nager and trea.urer. a••uaed any re.ponsibility.

6/ Moreover, ve note that .erving the Interia Audit Report on

{he candidate i. consistent with Coaais.ion policy. In the

ab.ence of • d••i9ft_ted trea.urer, Coaai••ion notice. generally

are i ••ued to the candidate a ••n agent of or •• the de facto

tr.a.urer of the coaaitte.. ror ex••ple, the ••port. Analysis Diviaion .ddr••••d a ••qu••t for Additional Infor.ation fro. the

Coaaitte. to -Rarc Little, Tre••urer.-

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FEDERAL ELECTION COMMISSION

WASHINCTON. 0 C. 2046]

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September 22, 1995

Mr. Marc Little

Friends of Marc Little

UMC Group

5991 Chester Ave., .213

Jacksonville, FL 32217

Dear Mr. Little:

Attached please find the l.nal Audit Report on Friends of

Marc Little. The Commission approved the report on September

21, 1995.

The Commission approved Final Audit Report will be on the

public record on September 27, 1995. Should you have any

questions regarding the public release of the report, please

contact the Commission's Press Office at -{202) 219-4155. Any questions you have related to matters covered during the audit

or in the report should be directed to Russ Bruner or Joe Stoltz

of the Audit Division at (202) 219-3720 or toll free at (800)

424-9530.

Director

Attachment as stated

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CPage 14, Awroved 9/21/95
CHROHOLOGY

FRIENDS OF MARC LITTLE

Audit Fieldwork S/1/95 - 5/17/95

c

Interim Audit Report to

the Committee

Response Received to the

Interim Audit Report

Pinal Audit Report Approved

6/30/95

8/2/95

9/21/95

Page 15, Approved 9/21/95