JONES DAY 

51 LOUISIANA AVENUE. N.W. • WASHINGTON. D.C. 20001.2113 

TELEPHONE:+1.202.879.393S • FACSIMILE: +1.202.626.1700 

DIRECT NUMBER: (202)879-3732 

WMCOINLEY9JONESDAV.COM 

March 21,2016 

VIA E-MAIL TOBRlEN@FEC.GOV 

Mr. Terry O'Brien 

Auditor 

Audit Division 

Federal Election Commission 

999 E Street, NW 

Washington, DC 20463 

Re: Oklahoma Leadership Council Interim Audit Report Response 

Dear Mr. O'Brien: 

On behalf of our client, the Oklahoma Leadership Council ("OLC!' or the "Committee"), this 

responds to the Interim Audit Report C'lAR") that was delivered to our client January 28,2016. 

As discussed below, the Committee has fully complied with the Audit Division's 

recommendations as set forth in the lAR and as modified in Mr. O'Brien's February 19, 2016 

email. 

Introduction 

As stated in the Exit Conference response, OLC, like many other state party conunittees, 

operates on a shoestring budget and relies on a few paid staff and volunteers to manage its daily 

operations and political duties as well as the burdensome and often confusing recordkeeping and 

reporting requirements of both state and federal regulators. Beginning near the end of the audit 

period and prior to the commencement of the instant audit, OLC made changes to its compliance 

infrastructure and protocols in an effort to satisfy its internal standards. First, OLC hired the 

FEC bookkeeping and reporting firm Red Curve Solutions to assist with reports and compliance 

matters. Second, upon the Commission's issuance of a memorandum regarding state party 

committee recordkeeping guidelines in.2013, the Conunittee implemented the FEC's guidelines. 

Finally, during this audit, OLC voluntarily raised with the Auditors an issue concerning the 

Committee's cash-on-hand totals in an effort to be as transparent as possible during the audit and 

to seek assistance in resolving the issue. 

The Committee remains committed to cooperating with the Audit Division, while also preserving 

all of its rights and defenses. Accordingly, it is our expectation that the Audit Division, Office of 

ALKHOBAR • AMSTERDAM • ATLANTA • BEIJING • BOSTON • BRISBANE • BRUSSELS i CHICAGO • CLEVELAND • COLUMBUS • DALLAS 

DETROIT • OUBAI • OOSSELOORF • FRANKFURT • HONGKONG • HOUSTON • IRVINE • JEODAH • LONDON • LOS ANGELES 

MADRID • MEXICO CITY • MIAMI • MILAN • MOSCOW • MUNICH • NEW YORK • PARIS i PERTH • PITTSBURGH i RIYADH 

SAN DIEGO • SAN FRANCISCO • SAO PAULO i SHANGHAI • SILICON VALLEY • SINGAPORE • SYDNEY • TAIPEI • TOKYD • WASHINGTDN 
JONES DAY 

Terry O'Brien 

March 21,2016 

Page 2 

the General Counsel, and the Commission itself will review the lAR and the Committee's 

response in a fair and objective manner. 

OLC's Responses to the lAR Findings and Recommendations 

Findings 1 & 2: Misstatement of Financial Activities & Misstatement of Financial Activities 

(Levin Funds) 

In the lAR Finding 1, the Audit Division states that OLC understated its 2011 receipts and 

disbursements and overstated its ending cash-on-hand. In lAR Finding 2, the Audit Division 

states that OLC understated its disbursements and overstated its ending cash-on-hand regarding 

Levin Funds in 2011. For 2012, the lAR states that the OLC understated its receipts. As a result 

of these findings and after consulting with the Audit Division, OLC was instructed that it may 

correct the public record in these matters by filing a Form 99 with the Committee's next due 

monthly report rather than filing amended 2011 and 2012 reports. In addition, the Audit 

Division requested OLC make a one-time audit adjustment and file an amended 2012 Year-End 

report. A copy of the Form 99 that was filed with the Committee's March 20 monthly report is 

attached as Exhibit A, and the amended 2012 Year-End Report making the one-time audit 

adjustment is attached as Exhibit B. 

Finding 3: Recordkeeping for Employees 

As stated in our response to the Exit Conference, after the 2012 election cycle and prior to the 

commencement of this audit, the Committee implemented timekeeping protocols in response to 

the FEC's December 2013 memorandum concerning tiniekeeping requirements for state parties. 

The Committee's Chairman verbally instructed the Committee's employees to comply with the 

guidelines set forth in the FEC's memorandum. The Conunittee recently memorialized this 

policy and a copy of OLC's recordkeeping policy for its employees is attached to this response 

as Exhibit C. 

Finding 4: Contributions from Unregistered Political Organizations 

On March 1, 2016, OLC transferred $1,000 from its federal account to the state account in 

accordance with the Audit Division's recommendation for Finding 4, as modified by Mr. 

O'Brien's February 19, 2016 email. The transfer will be disclosed in the Committee's April 20 

monthly report. 
JONES DAY 

Terry O'Brien 

March 21,2016 

Page 3 

Conclusion 

We respectfully request that the Audit Division, Office of the General Counsel, and the 

Commission fairly and objectively review the lAR and the responses submitted on behalf of our 

client, OLC. The record in this matter clearly demonstrates that OLC has fiilly cooperated with 

the Audit Division in an effoh to resolve this audit as expeditiously as possible. 

Attachments