Final Audit Report of the 

Commission on the Mississippi 

Democratic Party PAC 

(January 1, 2009 - December 31, 2010) 

Why the Audit 

Was Done 

Federal law permits the 

Commission to conduct 

audits and field 

investigations of any 

political conunittee that is 

required to file reports 

under the Federal 

Election Campaign Act 

(tiie Act). The 

Commission generally 

conducts such audits 

when a conunittee 

appears not to have met 

the tiireshold 

requirements for 

substantial compliance 

witii tiie Act.* 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 Mississippi Democratic Party PAC is a state party committee 

headquartered in Jackson, Mississippi. For more information, see 

the chart on the committee organization, p. 2. 

Financial Activity (p. 2) 

• Receipts 

o Contributions from Individuals 

o Contributions from Other 

Political Committees 

o Transfers from Affiliated/Other 

Party Committees 

o Transfers from Non-federal 

Account 

o Other Receipts 

Tota] Receipts 

• Disbursements 

o Operating Disbursements 

o Other Disbursements 

Total Disbursements 

$ 153,038 

30,550 

568,534 

88,144 

951 

$ 841,217 

$ 437,223 

389,693 

$ 826,916 

Commission Findings (p. 3) 

• Misstatement of Financial Activity (Finding 1) 

• Disclosure of Disbursements (Finding 2) 

• Disclosure of Occupation/Name of Employer (Finding 3) 

• Recordkeeping for Employees (Finding 4) 

2 U.S.C. §438(b). 
Final Audit Report of the 

Commission on the Mississippi 

Democratic Party PAC 

(January 1, 2009 - December 31, 2010) 
Table of Contents 

Page 

Part I. Background 

Authority for Audit 1 

Scope of Audit 1 

Commission Guidance 1 

Audit Hearing 1 

Part II. Overview of Committee 

Committee Organization 2 

Overview of Financial Activity 2 

Part III. Summaries 

Commission Findings 3 

Part IV. Commission Findings 

Finding 1. Misstatement of Financial Activity 5 

Finding 2. Disclosure of Disbursements 8 

Finding 3. Disclosure of Occupation/Name of Employer 9 

Finding 4. Recordkeeping for Employees 11 
Parti 

Backgromid 

Authority for Audit 

This report is based on an audit of the Mississippi Democratic Party PAC (MDP), 

undertaken by the Audit Division of the Federal Election Conunission (the Commission) 

in accordance with the Federal Election Campaign Act of 1971, as amended (the Act). 

The Audit Division conducted the audit pursuant to 2 U.S.C. §438(b), which permits the 

Conunission to conduct audits and field investigations of any political committee that is 

required to file a report under 2 U.S.C. §434. Prior to conducting any audit under this 

subsection, the Commission must perform an intemal review of reports filed by selected 

committees to determine whether the reports filed by a particular committee meet the 

threshold requirements for substantial compliance with the Act. 2 U.S.C. §438(b). 

Scope of Audit 

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

factors and as a result, this audit examined: 

1. the receipt of contributions from prohibited sources; 

2. the disclosure of individual contributors' occupation and name of employer; 

3. the consistency between reported figures and bank records; 

4. the disclosure of disbursements, debts and obligations; 

5. the completeness of records; and 

6. other committee operations necessary to the review. 

Commission Guidance 

Request for E^ly Commission Consideration of a Legal Question 

Pursuant to the "Policy Statement Establishing a Program for Requesting Consideration 

of Legal Questions by the Commission," MDP requested early consideration of a legal 

question raised during the audit. MDP questioned whether the monthly time logs 

required under 11 CFR § 106.7(d)(1) applied to employees paid with 100 percent federal 

funds. (See Finding 4.) 

The Commission concluded, by a vote of 5-1, that 11 CFR §106.7(d)(l) does require 

committees to keep a monthly log for employees paid exclusively with federal fiinds. 

Exercising its prosecutorial discretion, however, the Commission decided it will not 

pursue recordkeeping violations for the failure to keep time logs or to provide affidavits 

to account for employee salaries paid with 100 percent federal funds and reported as 

such. The Audit staff informed MDP Counsel of the Conunission's decision on MDP's 

request. This audit report does not include any finding or recommendation with respect 

to MDP's employees paid with 100 percent federal funds and reported as such. 

Audit Hearing 

MDP declined the opportunity for a hearing before the Commission on matters presented 

in this report. 
Part II 

Overview of Committee 

Committee Organization 

Important Dates 

• Date of Registration February 8,1982 

• Audit Coverage January 1,2009 - December 31,2010 

Headquarters Jackson, Mississippi 

Bank Information 

• Bank Depositories One 

• Bank Accounts Six federal and one non-federal 

Treasurer 

• Treasurer When Audit Was Conducted Melton Harris 

• Treasurer During Period Covered by Audit Audrey Seale 

Management Information 

• Attended the Commission Campaign 

Finance Seminar 

No 

• Who Handled Accounting and 

Recordkeeping Tasks 

Paid Staff 

Overview of Financial Activity 

(Audited Amounts) 

Cash-on-hand @ January 1,2009 $ (10,177)^ 

Receipts 

o Contributions from Individuals 153,038 

o Contributions from Other Political 

Committees 

30,550 

o Transfers from Affiliated/Other Party 

Committees 

568,534 

o Transfers from Non-federal Account 88,144 

o Other Receipts 951 

Total Receipts $ 841,217 

o Disbursements 

o Operating Disbursements 437,223 

o Other Disbursements 389,693 

Total Disbursements $ 826,916 

Cash-on-hand @ December 31,2010 $ 4,124 

^ MDP's bank statement did not show a negative cash-on-hand balance as of January 1,2009, due to an 

outstanding check that had not cleared its federal bank account. 
Part III 

Summaries 

Commission Findings 

Finding 1. Misstatement of Financial Activity 

During audit fieldwork, a comparison of MDP's reported financial activity with its bank 

records revealed a misstatement of receipts and disbursements in calendar year 2009. In 

response to the Interim Audit Report recommendation, MDP filed amended reports that 

materially corrected the misstatements. 

In addition, MDP materially understated its receipts by $221,646 in the reports that it 

originally filed for 2010. Specifically, MDP's original reports understated receipts by 

$221,646 in 2010. MDP did amend its reports prior to the notification of this audit to 

correct the misstated receipts activity for 2010. In response to the Interim Audit Report 

recommendation, MDP noted that it has made improvements to its reporting and 

accounting system to ensure more accurate reporting. 

The Commission approved a finding that MDP misstated its financial activity for 

calendar years 2009 and 2010. (For more detail, see p. 5.) 

Finding 2. Disclosure of Disbursements 

The Audit staff reviewed disbursements itemized on the disclosure reports and identified 

disbursements totaling $361,109 with missing payee addresses. In response to the 

Interim Audit Report recommendation, MDP materially corrected its reports by filing 

amended reports to disclose the missing payee infonnation. 

The Commission approved a finding that MDP omitted information related to 

disbursements totaling $361,109. (For more detail, see p. 8.) 

Finding 3. Disclosure of Occupation/Name of Employer 

A review of all contributions from individuals requiring itemization indicated that 73 

contributions totaling $17,426 lacked disclosure of occupation and/or name of employer. 

Furthermore, MDP did not sufficientiy document "best efforts" to obtain, maintain and 

submit information concerning these contributions. 

In response to the Interim Audit Report recommendation, MDP amended its reports to 

materially correct the disclosure of the missing occupation and/or name of employer 

information. MDP also described the best efforts procedures that have been developed 

and implemented since the audit. 

The Conunission approved a finding that MDP failed to report information related to 

occupation/name of employer totaling $17,426. (For more detail, see p. 9.) 
Finding 4. Recordkeeping for Employees 

During audit fieldwork, the Audit staff determined that MDP did not maintain any 

monthly payroll logs, as required, to document the percentage of time each employee 

spent on federal election activity. For 2009 and 2010, the Audit staff identified payments 

to MDP employees totaling $138,741,^ for which MDP did not maintain monthly payroll 

logs. In response to the Interim Audit Report recommendation, MDP implemented a 

plan to track employees' time spent on federal election activities. 

The Commission approved a finding that MDP failed to maintain logs to document the 

time employees spent on federal election activity totaling $138,741. (For more detail, see 

p. 11.) 

^ This total does not include payroll for employees paid with 100 percent federal funds and reported as 

such. (See Part I, Background, Commission Guidance, Request for Early Consideration of a Legal Question 

on Page 1.) 
Part IV 

Commission Findings 

Finding 1. Misstatement of Financial Activity 

Summary 

During audit fieldwork, a comparison of MDP's reported financial activity with its bank 

records revealed a misstatement of receipts and disbursements for calendar year 2009. In 

response to the Interim Audit Report recommendation, MDP filed amended reports that 

materially corrected tiie misstatements. 

In addition, MDP materially understated its receipts by $221,646 in the reports tiiat it 

originally filed for 2010. Specifically, MDP's original reports understated receipts by 

$221,646 in 2010. MDP did amend its reports prior to the notification of tiiis audit to 

correct the misstated receipts activity for 2010. In response to the Interim Audit Report 

reconunendation, MDP noted that it has made improvements to its reporting and 

accounting system to ensure more accurate reporting. 

The Commission approved a finding that MDP misstated its financial activity for 

calendar years 2009 and 2010. 

Legal Standard 

Contents of Reports. Each report must disclose: 

• the amount of cash-on-hand at the beginning and end of tiie 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 tiiat require itemization on Schedule A (Itemized Receipts) or 

Schedule B (Itemized Disbursements). 2 U.S.C. §434(b) (1), (2), (3), (4) and (5). 

Facts and Analysis 

A. Misstatement of Financial Activity - 2009 

1. Facts 

The Audit staff reconciled MDP's reported activity with its bank records and 

identified a misstatement of receipts and disbursements for calendar year 2009. 

The following chart details the discrepancies and succeeding paragraphs explain the 

reasons for the misstatements. 
MDP overstated the beginning cash balance as of January 1,2009 by $34,750 because of 

prior-period discrepancies. 

2009 Activity 

Reported^ Bank Records Discrepancy 

Beginning Cash Balance 

@ January 1,2009 

$24,573 ($10,177) $34,750 

Overstated 

Receipts $202,756 $210,042 $7,286 

Understated 

Disbursements $174,855 $199,388 $24,533 

Understated 

Ending Cash Balance 

©December 31,2009 

$46,366 $477 $45,889 

Overstated 

The understatement of receipts was the result of the following: 

• Receipts not reported $ 8,607 

• Transfer from the non-federal account not reported 6,803 

• Transfer from the non-federal accoimt reported twice (6,747) 

• Over-reported receipts (1,080) 

• Unexplained difference (297) 

Net Understatement of Receipts S 7.286 

The understatement of disbursements was the result of the following: 

• Disbursements not reported $ 25,780 

• Disbursements reported but not supported by check or debit (1,135) 

• Unexplained difference (112) 

Net Understatement of Disbursements $ 24.533 

The $45,889 overstatement of tiie ending cash balance was the result of tiie reporting 

discrepancies noted above. 

2. Interim Audit Report & Audit Division Recommendation 

Audit staff and MDP representatives discussed the misstatement of financial activity 

at the exit conference and the Audit staff provided relevant schedules detailing the 

transactions. An MDP representative acknowledged the discrepancies in the reports 

and indicated that corrective amendments would be filed. 

The Interim Audit Report reconunended that MDP: 

• amend its reports to correct the misstatements for 2009; and 

• amend its most recently filed report to correct the cash-on-hand balance with 

an explanation that the change resulted from a prior-period audit adjustment 

and reconcile the cash balance on its most recent report to identify any 

^ This column does not total because MDP amended the Ending Cash Balance on its 2008 Year-End 

Report but did not carry forward this adjustment on subsequent reports. 
subsequent discrepancies that may impact the $45,889 adjustment 

recommended by the Audit staff. 

3. Committee Response to Interim Audit Report 

In its response, MDP noted that it amended the 2009 reports and made corresponding 

amendments to subsequent reports. The Audit staff noted that as a result of these 

amendments, MDP materially corrected the misstatements. 

4. Draft Final Audit Report 

The Draft Final Audit Report acknowledged that MDP amended its reports to correct 

the misstatements. 

5. Committee Response to the Draft Final Audit Report 

MDP's response to the Draft Final Audit Report provided no additional conunents. 

B. Misstatement of Financial Activity - Increased Activity 

1. Facts 

The Audit staff compared the original reports filed with the bank records and 

discovered a $228,932 understatement of receipts from January 1,2009 tiirough 

December 31,2010. This amount represents the difference between receipts as 

originally reported and the amoimt of receipts per the bank records. This figure also 

includes the $7,286 understatement of receipts from 2009 in Section A (Misstatement 

of Financial Activity - 2009) noted above. The increase in activity in 2010 was 

largely due to MDP not reporting transfers totaling $198,597 from the national party 

committee on its original reports. 

2. Interim Audit Report & Audit Division Recommendation 

The Audit staff discussed tiie misstatements for 2009 and 2010 witii MDP 

representatives during the exit conference. The Audit staff recommended that MDP 

submit any additional information or written comments it considered relevant to the 

matter. 

3. Committee Response to Interim Audit Report 

In its response, MDP noted that the increased disclosed activities relate to minor 

bookkeeping errors that occurred during the 2009 calendar year and that it has made 

improvements to its reporting and accounting system to ensure more accurate 

reporting now and in the future. 

4. Draft Final Audit Report 

The Draft Final Audit Report acknowledged MDP's explanation regarding the 

increased activity. 

5. Committee Response to the Draft Final Audit Report 

MDP's response to the Draft Final Audit Report provided no additional conunents. 
Commission Conclusion 

On August 22,2013, the Conunission considered the Audit Division 

Recommendation Memorandum in which the Audit staff recommended that the 

Commission adopt a finding that MDP misstated its financial activity for calendar 

years 2009 and 2010. 

The Commission approved the Audit staffs recommendation. 

Finding 2. Disclosure of Dishursements 

Summary 

The Audit staff reviewed disbursements itemized on the disclosure reports and identified 

disbursements totaling $361,109 with missing payee addresses. In response to the 

Interim Audit Report recommendation, MDP materially corrected its reports by filing 

amended reports to disclose the missing payee information. 

The Commission approved a finding that MDP omitted information related to 

disbursements totaling $361,109. 

Legal Standard 

Reporting Operating Expenditures. When operating expenditures to the same person 

exceed $200 in a calendar year, the committee must report: 

• the amount; 

• the date when the expenditures were made; and 

• the name and address of the payee and purpose. 11 CFR § 104.3(b)(3). 

Facts and Analjrsis 

A. Facts 

During audit fieldwork, the Audit staff reviewed all disbursements and identified 172 

itemized transactions totaling $361,109 that did not include the payees' addresses. 

This accounted for 54 percent of the total dollar value of itemized disbursements. The 

majority of these omitted addresses were in connection with disbursements made in 2010. 

B. Interim Audit Report & Audit Division Recommendation 

The Audit staff discussed this matter with MDP representatives at the exit conference and 

subsequentiy provided them with a schedule of disbursements with missing payee 

addresses. At the exit conference, MDP representatives agreed to file amended reports to 

disclose the missing addresses. The Interim Audit Report reconunended that MDP 

amend its reports to disclose these omissions. 

C. Committee Response to Interim Audit Report 

In its response, MDP noted that it has amended the reports to provide the missing payee 

information. The Audit staff noted that as a result of these amendments, MDP materially 

corrected its disclosure of payee information. 
D. Draft Final Audit Report 

The Draft Final Audit Report acknowledged that MDP amended its reports to include the 

missing payee information related to disbursements. 

E. Committee Response to the Draft Final Audit Report 

MDP's response to the Draft Final Audit Report provided no additional comments. 

Commission Conclusion 

On August 22,2013, the Conmiission considered the Audit Division Reconunendation 

Memorandum in which the Audit staff recommended that the Commission adopt a 

finding that MDP omitted information related to disbursements totaling $361,109. 

The Conunission approved the Audit staffs recommendation. 

Finding 3. Disclosure of Occupation/Name of Employer 

Summary 

A review of all contributions from individuals requiring itemization indicated that 73 

contributions totaling $17,426 lacked disclosure of occupation and/or name of employer. 

Furthermore, MDP did not sufficiently document *'best efforts" to obtain, maintain and 

submit information concerning these contributions. 

In response to the Interim Audit Report reconunendation, MDP amended its reports to 

materially correct the disclosure of the missing occupation and/or name of employer 

information. MDP also described the best efforts procedures that have been developed 

and implemented since the audit. 

The Conunission approved a finding that MDP failed to report information related to 

occupation/name of employer totaling $17,426. 

Legal Standard 

A. Itemization Required for Contributions from Individuals. A political conunittee 

other than an authorized committee must itemize any contribution from an individual 

if it exceeds $200 per calendar year, either by itself or when combined with other 

contributions from the same contributor. 2 U.S.C. §434(b)(3)(a). 

B. Required Information for Contributions from Individuals. For each itemized 

contribution from an individual, the committee must provide the following 

information: 

• the contributor's full name and address (including zip code); 

• the contributor's occupation and the name of his or her employer; 

• the date of receipt (the date the committee received the contribution); 

• the amount of the contribution; and 

• the calendar year-to-date total of all contributions from the same individual. 

11 CFR §§100.12 and 104.3(a)(4) and 2 U.S.C. §434(b)(3)(A). 
10 

C. Best Efforts Ensures Compliance. When the treasurer of a political committee 

shows that the conunittee used best efforts (see below) to obtain, maintain, and 

submit the information required by the Act, the committee's reports and records will 

be considered in compliance witii tiie Act. 2 U.S.C. §432(h)(2)(i). 

D. Definition of Best Efforts. The treasurer and the committee will be considered to 

have used "best efforts" with respect to contributions if the conimittee satisfied all of 

the criteria below. 

• All written solicitations for contributions included: 

o a clear request for the contributor's full name, mailing address, 

occupation, and name of employer; and 

o the statement that such reporting is required by federal law. 

• Within 30 days of receipt of the contribution, the treasurer made at least one 

effort to obtain the missing information, in either a written request or a 

documented oral request. 

• The treasurer reported any contributor information that, although not initially 

provided by the contributor, was obtained in a follow-up communication or 

was contained in the committees' records or in prior reports that the 

conunittee filed during the same two-year cycle. 11 CFR § 104.7(b). 

Facts and Aaalysis 

A. Facts 

A review of itemized contributions from individuals indicated that 73 contributions 

totaling $17,426, or 52 percent of the dollar value of individual contributions required to 

be itemized by MDP, lacked disclosure of occupation and/or name of employer. During 

audit fieldwork, MDP provided no evidence showing that it had utilized "best efforts" to 

obtain, maintain, and submit the missing information. Most of the contributor entries 

with missing information were either disclosed with the notation "Best Effort" or left 

blank on the Schedules A (Itemized Receipts) filed with the Commission. 

The Audit staff asked MDP representatives to describe MDP's best efforts policy. MDP 

representatives responded that no policy was in effect during the period covered by the 

audit. The Audit staff provided MDP with a list of contributors for whom occupation 

and/or name of employer information was missing. MDP retumed this list to the Audit 

staff with the missing information filled in but noted that MDP had not contacted the 

contributors to obtain this information. The Committee explained that MDP 

representatives had obtained the information from personal knowledge of the individuals 

and research on the Intemet after receiving the list firom the Audit staff. 

B. Interim Audit Report & Audit Division Recommendation 

The Audit staff discussed the disclosure of occupation and name of employer with MDP 

representatives at the exit conference. MDP representatives reiterated that they had 

provided the missing information to the Audit staff and that they have established a 

standard new policy to collect all the required contributor information at the time 

contributions are accepted. 
11 

The Interim Audit Report recommended that MDP provide documentation that it 

exercised best efforts during the audit period to obtain, maintain and submit the required 

contributor information. In addition, Audit staff requested that MDP file amended 

Schedules A to disclose the contributor information obtained subsequent to audit 

fieldwork. 

C. Committee Response to Interim Audit Report 

In its response, MDP filed Schedules A that provided the missing occupation and name 

of employer information. Further, MDP explained that it has been unable to locate 

records that indicate it had made follow-up requests for donor information during the 

2010 cycle, but noted that its solicitation materials regularly included a request for 

occupation and employer information. The Audit staff noted that as a result of these 

amended reports, MDP materially corrected the disclosure of its contributors' occupation 

and name of employer. 

MDP also pointed out that it has developed best efforts procedures ensuring that all 

solicitations include requests for occupation and employer information. In addition, the 

procedures include follow-up requests for donors' missing information within 30 days of 

receipt of a contribution. Furthermore, donors missing such information at the time a 

report is required to be filed trigger an intemal review to ensure that MDP has not 

inadvertentiy omitted information contained within its records at the time of filing. MDP 

will include any information received subsequent to a filed report on amended reports. 

D. Draft Final Audit Report 

The Draft Final Audit Report acknowledged that MDP amended its reports to include the 

missing occupation/name of employer information. 

E. Committee Response to the Draft Final Audit Report 

MDP's response to the Draft Final Audit Report provided no additional conunents. 

Commission Conclusion 

On August 22,2013, the Commission considered the Audit Division Recommendation 

Memorandum in which the Audit staff reconunended tiiat the Commission adopt a 

finding that MDP failed to report information related to occupation/name of employer 

totaling $17,426. 

The Commission approved the Audit staffs reconunendation. 

Finding 4. Recordkeeping for Employees 

Summary 

During audit fieldwork, the Audit staff determined that MDP did not maintain any 

monthly payroll logs, as required, to document the percentage of time each employee 

spent on federal election activity. For 2009 and 2010, the Audit staff identified payments 
12 

to MDP employees totaling $138,741,^ for which MDP did not maintain monthly payroll 

logs. In response to the Interim Audit Report recommendation, MDP implemented a plan 

to track employees' time spent on federal election activities. 

The Commission approved a finding that MDP failed to maintain logs to document the 

time employees spent on federal election activity totaling $138,741. 

Legal Standard 

Maintenance of Monthly Logs. Party conunittees must keep a monthly log of the 

percentage of time each employee spends in connection with a federal election. 

Allocations of salaries, wages, and fringe benefits are as follows: 

o employees who spend 25 percent or less of their compensated time in a given 

month on federal election activities must be paid either from the federal account 

or be allocated as administrative costs; 

o employees who spend more than 25 percent of their compensated time in a given 

montii on federal election activities must be paid only firom a federal account; 

and 

o employees who spend none of their compensated time in a given month on 

federal election activities may be paid entirely with fimds that comply with state 

law. llCFR§106.7(d)(l). 

Facts and Analysis 

A. Facts 

During fieldwork, the Audit staff reviewed disbursements for payroll. MDP did not 

maintain any monthly logs or equivalent records to document the percentage of time each 

employee spent in connection with federal election activity. These logs are required to 

document the proper allocation of federal and non-federal funds used to pay employee 

salaries and wages. For 2009 and 2010, MDP did not maintain logs for $138,741 in 

payroll.^ This amount represents the total payroll for employees paid with an allocation 

of federal and non-federal funds during the audit period. MDP had no employees paid 

with exclusively non-federal funds. 

B. Interim Audit Report & Audit Division Recommendation 

After the exit conference, the Audit staff discussed the payroll recordkeeping issue with 

MDP representatives. An MDP representative responded that MDP had not located any 

payroll logs or other payroll documentation. 

Absent provision of any montiily logs, the Interim Audit Report recommended that, MDP 

provide and implement a plan to maintain such monthly payroll logs to track the 

percentage of time each employee spends on federal election activity. 

^ This total does not include payroll for employees paid with 100 percent federal funds (see Part I, 

Background, Commission Guidance, Request for Early Consideration of a Legal Question on Page 1). 

^ Payroll is stated net of taxes and benefits. This total does not include payroll for employees paid with 

100 percent federal funds and reported as such, (see Part I, Background, Commission Guidance, Request 

for Early Consideration of a Legal Question on Page 1). 
13 

C. Committee Response to Interim Audit Report 

In its response, MDP noted that it now maintains monthly logs to track employee time 

spent on federal election activities. 

D. Draft Final Audit Report 

The Draft Final Audit Report acknowledged tiiat MDP now maintains logs to track 

employee time spent on federal election activity. 

E. Conimittee Response to the Draft Final Audit Report 

MDP's response to tiie Draft Final Audit Report provided no additional conunents. 

Commission Conclusion 

On August 22, 2013, tiie Commission considered the Audit Division Recommendation 

Memorandum in which the Audit staff recommended that tiie Commission adopt a 

finding that MDP failed to maintain logs to document the time employees spent on 

federal election activity totaling $138,741. 

The Commission approved the Audit staff's recommendation.