Draft Final Audit Report of the 

Audit Division on the Utah 

Republican Party 

(January 1, 2011 - December 31, 2012) 

Why the Audit 

Was Done 

Federal law permits the 

Commission to conduct 

audits and field 

investigations of any 

political coirunittee that is 

required to file reports 

under the Federal 

Election Campaign Act 

(the Act). The 

Commission generally 

conducts such audits 

when a committee 

appears not to have m^ 

the threshold 

requirements for ^ 

substantial complianc 

with the Ac ' iit 

I complied 

tire IfflW" IS, 

prohibit I 

disclosure i , nents 

of the Act. 

Future Action 

The Commission m^ 

initiate an enforcement 

action, at a later time, 

with respect to any of the 

matters discussed in this 

report. 

About the Committe^^^^^ 

The Utah Republican Party i' ate pkrty committee 

headquartered in Salt Lak^' Jtah. For more information, see 

the chart on the Committd^re^^ ' i, p. 2. 

iduals 

Financial Ac^vity (p. 2) 

• Receipts ^ 

o Contribul 

and Political ittees 

o transfers" from A iated and 

litical Ci 

o " Non-! 

/ 

o OthS 5ip 

Total Rii s 4^ 

Disbursem-1.: » 

mti xpenditures 

_ . ^.^jj^M^lection Activity 

o Transfers to Affiliated and Other 

political Committees 

Other Disbursements 

otal Disbursements 

. $ 753,650 

1,119,025 

880,121 

114,894 

$2,867,690 

$ 2,388,485 

390,806 

9,152 

38,475 

$ 2326,918 

Findings and Recommendations (p. 3) 

• Receipt of Prohibited Contributions (Finding 1) 

• Receipt of Contributions that Exceed Limits (Finding 2) 

• Misstatement of Financial Activity (Finding 3) 

• Recordkeeping for Employees (Finding 4) 

• Reporting of Debts and Obligations (Finding 5) 

• Apparent Excessive Contribution - Staff Advance (Finding 6) 

52 U.S.C. §30111(b). 
Draft Final Audit Report of the 

Audit Division on the 

Utah Republican Party 

(January 1, 2011 - December 31, 2012) 

\ 

V \ 

w 
Table of Contents 

Page 

Parti. Background 

Authority for Audit 1 

Scope of Audit 1 

Commission Guidance 1 

Part 11. Overview of Committee 

Committee Organization \ 2 

Overview of Financial Activity 2 

Part III. Summaries 

Findings and Recommendations ^ 

Part iV. Findings and Recom^viid.iiio^^ ^ 

Finding!. Receipt of Prohibited Contributions 5 

Finding 2. Receipt of Contributi<^ that Exceed; 8 

Finding 3. Misstatement of Finaru' i^itv 10 

Finding 4. Recordkeeping for Emi ^ 13 

Findings. Report of Debts and Obli^ioii ^ ^ 

Finding 6. Apparent Excessive Cont^ ' - TOeafece 18 

A 

A 

/ 
Parti 

Background 

Authority for Audit 

This report is based on an audit of the Utah Republican Party, undertaken by the Audit 

Division of the Federal Election Commission (the Commission) in accordance with the 

Federal Election Campaign Act of 1971, as amended (the Act). The Audit Division 

conducted the audit pursuant to 52 U.S.C. §30111(b), which permits the Commission to 

conduct audits and field investigations of any political committee Aat is required to file a 

report under 52 U.S.C. §30104. Prior to conducting any audit subsection, the 

Commission must perform an internal review of reports filei^^^elected committees to 

determine if the reports filed by a particular committee m^^^' shold requirements 

for substantial compliance with the Act. 52 U.S.C. §30 l^(b). 

Scope of Audit ^ 

Following Commission-approved procedures^! adit s^ evaluated v^T :fisk 

factors and as a result, this audit examined: ^ 

1. the receipt of excessive contributions and loan: 

2. the receipt of contributions fiom pcphibited source?; 

3. the disclosure of contributions i 

4. the disclosure of disbursements, deB^^^ ions; 

5. the disclosure of expenses allocated ^wei .d qi^-federal accounts; 

6. the consistency between reported fig 

7. the completeness id ^ 

8. other committc atio cssary to preview. 

Commission Gilid.inc'v ^ 

Reques^- I •• •; ^Consideration of a Legal Question 

^o the Comi^^^'s "^^^^tement Establishing a Program for Requesting 

Coii^dl^^on of Legal ^^tions ^me Commission," several state party committees 

unafiiliat' i URP req^ted evly consideration of a legal question raised during 

audits covenng ' 2010 el^ion cycle. Specifically, the Commission addressed whether 

monthly time 1 ^der § 106.7(d)(1) were required for employees paid with 100 

percent federal 

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

coimnittees to keep a monthly log for employees paid exclusively with federal hinds. 

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 

siich. The Audit staff informed URP representatives of the payroll requirement and the 

Commission's decision not to pursue recordkeeping violations for failure to keep payroll 

logs for salaries paid and correctly reported as 100 percent federal. This audit report does 

not include any findings or recommendations with respect to URP employees paid with 

100 percent federal funds and reported as such. 
Part II 

Overview of Committee 

Committee Organization 

Important Dates 

• Date of Registration March 16,1978 

• Audit Coverage January 1,2011 - ^cember 31,2012 

Headquarters Salt Lake City 

Bank Information 

• Bank Depositories One ^ 

• Bank Accounts Four and t^^on-Federal 

Treasurer 

• Treasurer When Audit Was Conducted D^ Crittenden (9/20/ 7Q5/14) 

^^aeron ^fbinson (S/Oi sent) 

• Treasurer During Period Covered by Audit Mi^- / 

Management Information 

• Attended Commission Campaign Fit^'"> Yes 

Seminar 

Who Handled Accounting and 

Recordkeeping Tasks 

ffand 

A % ^ Overview of Fimncial Activity 

(Audited A^Kdunts) 

Cash-on-hara ^ Jan^- 1 20 1 $ 421 

Receip^ \ ^ 

o Coritnou^ &om IndivH^ls an^olitical 

Committei ^ M 

753,650 

o Transfers fro^ iated ^ Other Political 

Corrmiittees ^ M 

1,119,025 

o Transfers fix)m No^^^eral Accounts 880,121 

o Other Receipts /' 114,894 

Totai Receipts $2,867,690 

Disbursements 

o Operating Expenditures 2,388,485 

o Federal Election Activity 390,806 

o Transfers to Affiliates and Other Political 

Committees 

9,152 

o Other Disbursements 38,475 

Total Disbursements $2^26,918 

Cash-on-hand @ December 31,2012 S 41,193 
Part III 

Summaries 

Findings and Recommendations 

Finding 1. Receipt of Prohibited Contributions 

During audit fieldwork, a review of contributions revealed that URP deposited five 

apparent prohibited contributions totaling $23,600 into its feder^^^unt. URP 

transferred $23,600 into a non-federal account, albeit in an u^^lymanner, to correct 

this matter. In response to the Interim Audit Report recoils i, URP did not 

provide any documentation to demonstrate the fimds wei^an within thirty days 

of the date on which it discovered the contributions j^K^hibitei s counsel 

stated that URP has long since remedied the issue^J^rilibd for this m. The Audit 

staff concludes that URP untimely resolved pi ted contributions tot^^ 600. 

(For more detail, see p. 5) < ^ 

M V ^ 

Finding 2. Receipt of Cqntributioiis lh.it Earceeds Limits 

' fied appare cessive contributions from 

by $42,^1 h^se errors occurred as 

con^butions by issuing a 

tl account in a timely 

Cessive i^iraon of the contributions to a 

ly. In resp%se to the Interim Audit Report 

ivide any doi mtation to demonstrate the fimds were 

thee sivecontributions. URP'scounsel 

identified for this finding. The Audit 

resolved excessive contributions totaling $42,925. 

During audit fieldwork, the Audit staS^'' 

three individuals that exceeded contrib 

a result of URP not resolving the excess^ 

refund to the contributor or making a 

maimer. Subsequently sferred 

non-federal account^toeit 

recommendation, not 

transferred within sixl '^s o 

stated that I ' ang 

staff coi^- uni 

(For detail, se 

Finding^ 

During audiffi 

records reveah 

$107,013 and ant 

URP had a mii 

MisKl.-

/ork, a 

tKt of Financial Activity 

iparison of URP's reported financial activity with its bank 

it of financial activity for receipts in 2011 totaling 

ending cash-on-hand bdance totding $10,028. In addition, 

of receipts and disbursements for 2012. In 2012, URP 

understated its receipts and disbursements by $I 14,582 and $96,176, respectively. In . 

response to the Interim Audit Report recommendation, URP amended its disclosure 

reports to materially correct the misstatements for both 2011 and 2012 reports. 

(For more detail, see p. 10) 

Finding 4. Recordkeeping for Employees 

During audit fieldwork, the Audit staff identified that URP did not maintain any monthly 

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

connection with a federal election. For 2011 and 2012, the Audit staff identified 
payments to URP employees totaling $285,242 for which URP did not maintain monthly 

payroll logs. This consisted of $269,776 for which payroll was allocated with federal and 

non-federal funds, and $15,466 for which payroll was exclusively paid with non-federal 

funds. In response to the Interim Audit Report recommendation, URP's counsel stated 

that URP has long since remedied the issue identified for this finding. URP has complied 

with the Interim Audit Report recommendation by implementing a plan to maintain 

monthly payroll logs in the future. 

(For more detail, see p. 13) 

Finding 5. Reporting of Debts and Obligati 

During audit fieldwork, the Audit staff noted that URP failed ^^[^Ibse debts and 

obligations to five vendors and one staff member totaling $2g^.23 on Schedule D (Debts 

and Obligations). In response to the Interim Audit Vjsjpoj^^am dation, URP filed 

amended reports to disclose debts and obligations reg^^^g the 

$101,710.79. However, URP did not disclose the^^i^fing $94, 

member because it disagrees that these items sl^^be considered as 

URP did not materially correct the reporting and 6 ;ations. 

(For more detail, see p. 14) \ 

Finding. 6. Apparent Excessive Coniri 

One URP staff member received reim 

$46,904 that appear to have been reimi 

member's credit card billing statements 

60 days after the closir 

Report recommendatig^. 

URP was not awa^ 

provide any docume 

proper time linujations. 

member. 

itilth. 

: was eve 

(Form ill, seep. 1 

memi 

tion-Staff Advance 

its for credi^^d exnenditures totaling 

iy. UR^^^t provide the staff 

were made within 

lenl ponse to the Interim Audit 

disagre^ with this assertion because 

s when they were incurred. URP did not 

bursements were made within the 

untimely reimbursements to the staff 

: $2lSn^^^excessive contributions from the staff 

ibursed. No further action will be taken since the 

for the expenses. 

he hi 

•ted it 

table exj 

onstrate the 
Part IV 

Findings and Recommendations 

Finding 1. Receipt of Prohibited Contributions 

Summary 

During audit fieldwork, a review of contributions revealed that deposited five 

apparent prohibited contributions totaling $23;600 into its URP 

transferred $23,600 into a non-federal account, albeit in an ely manner, to correct 

this matter. In response to the Interim Audit Report recom URP did not 

provide any documentation to demonstrate the funds we^rans^^ 'ithin thirty days 

of the date on which it discovered the contributions^^se^ohibite > 's counsel 

stated that URP has long since remedied the issu|^^tJ^d for this I The Audit 

staff concludes that URP untimely resolved ] id contributions tot^ 3>,600. 

Legal Standard ^ ^ 

A. Receipt of Prohibited Corporate^Contributions itical committees may not 

accept contributions from the gene ' asuryfrmaso^ orations.. This prohibition 

applies to any type of corporations ^^^a non-sto( sanation, as incorporated 

membership organization, and an ' ersh^rganization, and an 

incorporated cooperative. 52 U.S.C. Pj)l IjL 

Ibutions - < 

ibutions i 

B. Receipt of Prohii» ed 

committees ma, cept 

or loans): 

2. the foiling prohibited sources: 

• Corpi (t incorporated organization, including a non-

/ stock coi^^tion. ^^corporated membership organization, and an 

ions; or 

eral Prohibition. Candidates and 

p form of money, in-kind contributions 

3. Feders^n lunent Contractors (including partnerships, individuals, and sole 

proprieto lo have contracts with the federal government); and 

4. Foreign iCationals (including individuals who are not U.S. citizens and not 

lawfully admitted for permanent residence; foreign governments and foreign 

politick parties; and groups organized under the laws of a foreign country or 

groups whose principal place of business is in a foreign country, as defined in 

22 U.S.C. §611(b)). 52 U.S.C. §§30118,30119,30121, and 30122. 

C. Questionable Contributions. If a committee receives a contribution that appears to 

be prohibited (a questionable contribution), it must follow the procedures below: 
1. Within 10 days after the treasurer receives the questionable contribution, the 

committee must either: 

• Retum the contribution to the contributor without depositing it; or 

• Deposit the contribution (and follow the steps below). 11 CFR 

§103.3(b)(l). 

2. If the committee deposits the questionable contribution, it may not spend the 

fimds and must be prepared to refund them. It must therefore maintain 

sufficient fimds to make the refunds or establish a separate account in a 

campaign depository for possibly illegal contributions. 11 CFR §103.3 (b)(4). 

3. The committee must keep a written record explainingly the contribution 

may be prohibited.and must include this informatinn^^iuieporting the 

receipt of the contribution. 11 CFR §103.3(b)(^ 

4. Within 30 days of the treasurer's receipt of tl^p e contribution, the 

committee must make at least one written m ^1 reqi evidence that the 

contribution is legal. Evidence of legali^^^&s, for e^^le. a written 

statement from the contributor expla^^ why the contribi^^ .egal or an 

oral explanation that is recorded bW^ smmifl in a memoi 11 CFR 

§103.3(b)(l). ^ 

5. Within these 30 days, the committee n r: 

• Confirm the legali^f the contribu 

• Refund the contrib^^^^Ae contribi^^ 

report coveriiig the p®^^ ' . the re 

§103.3(b)(l). 

D. Federal V. 

that are permi 

contain fimds 

law), such as contri 

from ' :( 

te the reflmd on the 

a made. 11 CFR 

accou^ may contain only those fimds 

law; the nonfederal account may i 

law (but are legal under state 

its of the federal law and contributions 

IS and labor organizations. 11 CFR 102.5 

E. Ill hi-, every ol i'l 

respo as under 

received losii 

organizatioi n 

but later discc 

[bited^ntribution. If the treasurer m exercising his or her 

FR 103.3(b) determined that at the time a contribution was 

did not appear to be made by a corporation, labor 

ional or Federal contractor, or made in the name of another, 

it is illegal based on new evidence not available to the political 

committee at theJSfhe of receipt and deposit, the treasurer shall refund the 

contribution to the contributor within thirty days of the date on which the illegality is 

discovered. If the political committee does not have sufficient fimds to reflmd the 

contribution at the time of the illegality is discovered, the political conunittee shall 

make the refund from the next funds it receives. 11 CFR 103.3(b)(2). 
Facts and Analysis 

A. Facts 

During audit fieldwork, the Audit staff reviewed contributions to URP from other 

political committees and identified five contributions totaling $23,600 from apparent 

prohibited sources. Each of these contributions appeared to be from corporations; 

however, the Audit staff could not verify the corporate tax status with the Utah Secretary 

of State. It is noted that the state of Utah allows unlimited contributions from 

corporations. In accordance with 11 CFR §103.3(b)(4), URP depo-sited these 

questionable funds into its federal account and maintained suffiG -deral funds to 

refund them. 

Prior to notification of the audit, URP realized the questiV^ble 'ere in fact 

prohibited contributions that were mistakenly depo^^^ the fe« ^^^count and 

subsequently transferred $20,000 of the $23,600^^ohibited contribi^^ »a nonfederal account. The transfer was made morej^^thirty d^ys from disct ig^fhe 

contributions were prohibited pursuant to 11 -31 ^ ^ Therefore, 

conclusion of audit fieldwork, the $20,000 transfer isidered untimely resolved and 

the amount of prohibited contributions totaling $3,60- ed unresolved for two of 

the contributors. 

B. Interim Audit Report & Audit Di 

The Audit staff discussed this matter with 

and provided 

URP representath ted 1 ne of the 

resolved and that rtinj 

In responsi ' c 

hadalr^. 

For t' laining prof 

earlfi ^rortunity to i 

the remM^^S3.600 prot 

account on 11,201 i 

iiiiiii ii-latiSii 

f^es during the exit conference 

contentions identified in the review, 

ihibited contributions had already been 

•cuments ha\ Iready been provided to the Audit staff. 

ives reiterated that a $20,000 transfer 

a 1 Tal account to resolve three prohibited contributions, 

ai stated it would disgorge the $3,600 at its 

wit]^^ Audit staffs recommendation. URP transferred 

intributions fixim the federal account to a non-federal 

The transfers, totaling $23,600, were untimely. 

The Interim Aud: ^^^^^ecommended URP demonstrate that transfers totaling $23,600 

to resolve the imper^^ible contributions were made within thirty days of the date on 

which it discovered me contributions were prohibited. Absent such a demonstration, the 

Audit staff would conclude that U^ transferred the prohibited contributions totaling 

$23,600 in an untimely manner. 

C. Committee Response to Interim Audit Report 

In response to the Interim Audit Report recommendation, URP's counsel stated that URP 

has long since remedied the issue identified for this finding. URP did not provide any 

documentation to demonstrate the funds were transferred within thirty days of the date on 
which it discovered the contributions were prohibited. The Audit staff concludes that 

URP untimely resolved prohibited contributions totaling $23,600 

Finding 2. Receipt of Contributions that Exceeds Limits 

Summary 

During audit fieldwork, the Audit staff identified apparent excessive contributions from 

three individuals that exceeded contribution limits by $42,925. These errors occurred as 

a result of URP not resolving the excessive portion of the contri^^s by issuing a 

reflmd to the contributor or making a transfer to a non-federalj^mmtw a timely 

manner. Subsequently, URP transferred the excessive le contributions to a 

non-federal account, albeit untimely. In response to the Report 

recommendation, URP did not provide any documei ' den eate the funds were 

transferred within 60 days of receiving the exces^ dbutions. counsel stated 

that URP has long since remedied the issue id( ed for this finding, 

concludes that URP untimely resolved excess! nbuti totaling $4^ 

.udit staff 

Legal Standard 

A. Party Committee Limits. For 

receive more than a total of $10,000 

§30116(a)(1)(D) and 11 CFR §110.9. 

B. Handling Contribi 

contribution that api^ 

1. Retum the ouesl^able d 

2. Deposit the cliec^^Jts 

• Keen enough mi 

election i 

n any one"! 

isive. 

litte^ust either: 

[party committee may not 

utor. 52U.S.C. 

a 

:lude th 

fore its lega 

^ reattribul 

m ts^mission i 

If the^hmittee 

receivini 

11 CFR § 

II- That Appeal 

live, 

to the done 

account! ^ 

•ver all potential refunds; 

the contribution may be illegal; 

lule A if the contribution has to be itemized 

pf the^cessive portion, following the instructions provided 

jations (see below for explanation of reattribution); and 

not receive a proper reattribution within 60 days after 

live contribution, refund the excessive portion to the donor. 

(b)(3),(4) and (5) and 110.1(k)(3)(ii)(B). 

C. Joint Contributions. Any contribution made by more than one person (except for a 

contribution made by a partnership) must include the signature of each contributor on the 

check or in a separate writing. A joint contribution is attnbuted equally to each donor 

unless a statement indicates that the funds should be divided differently. 11 CFR 

§110.1(k)(l)and(2). 

D. Reattribution of Excessive Contributions. Commission regulations permit 

committees to ask donors of excessive contributions whether they had intended their 

contribution to be a joint contribution fixim more than one person and whether they would 
like to reattribute the excess amount to the other contributor. The committee must 

inform the contributor that: 

1. The reattribution must be signed by both contributors; 

2. The reattribution miist be received by the committee within 60 days after the 

committee received the original contribution; and 

3. The contributor may instead request a refund of the excessive amount. 11 CFR 

§110.1(k)(3). 

Within 60 days after receiving the excessive contribution, the conunittee must either 

receive the proper reattribution or refund the excessive portion to ' donor. 11 CFR 

§§103.3(b)(3) and 110.1(k)(3)(ii)(B). Further, a political coni^ njust retain written 

records concerning the reattribution in order for it to be effe"*^ 11 CFR § 110.1 (1)(S). 

Facts and Analjraia 

A. Facts 

The Audit staffs review of contributions indii 

excessive contributions fix)m three individuals 

These excessive contributions were a result of 

excessive portion to a non-federal ac^unt in a timely 

sufficient funds in its federal account^ ' ihe refun« 

three individuals each made the contril is2P12with 

accountholders. It is unclear if the 

URP's federal or non-federal accounts. 

^t deposited a] 

$42^4into itsfed^Elaccount. 

unding or transferring the 

. URP did maintain 

the audit cycle. The 

imprinted with single 

ibutions to be for the 

Prior to notification 

reported the $42, 

federal account on Scl 

subsequent' nsf 

RPreali: 

itributions 

rei 

a a\/ vv w wn 

thei ' ' Icontribu dai 

contributions were excessive. URP 

hedules A as well as debt to the non-

«the excessive portions, URP 

a non-federal account in January and 

were required to be made within 60 days of receipt of 

"ore considered untimely. 

B. Intel Repoi i AlAudit Division Recommendation 

The Audit s^^ ' :ussed t^ matter at the exit conference and provided URP 

representatives hedul^f the apparent excessive contributions. URP representatives 

stated the contrib^^ deposited into the federal account but should have been 

deposited into a non ral account. Once discovered, URP reported the transactions as 

debt owed to a non-^deral account until the transfers were made. URP representatives 

added that documentation had already been provided to the Audit staff. 

In response to the exit conference, URP representatives stated they have already taken 

corrective action and do hot believe any further remedial measures are needed at this 

time. Supporting documentation was ^so provided. The Audit staff acknowledges the 

subsequent transfers totaling $42,925 to a non-federal account as a remedy for the 

excessive amount was made in an untimely manner. 
10 

The Interim Audit Report r^mmended URP demonstrate that the funds were transferred 

timely (within 60 days of receiving the excessive contribution). Absent such a 

demonstration, the Audit staff would conclude that URP transferred the $42,925 

excessive contributions in an untimely manner. 

C. Committee Response to Interim Audit Report 

In response to the Interim Audit Report recommendation, URP's counsel stated that URP 

has long since remedied the issue identified for this finding. URP did not provide any 

documentation demonstrating the funds were transferred within 60 days of receiving the 

excessive contributions. The Audit staff concludes that URP untimely resolved excessive 

contributions totaling $42,925. \ 

I Finding 3. Misstatement of Financ: 

Summafy 

During audit fieldwork, a comparison of URR^ 

records revealed a misstatement of financial activr 

$107,013 and an overstated ending cash-on-hand ba 

URP had a misstatement of receipts sQ^^bursements 

understated its receipts and disbursem^p ~ 14,582 

response to the Interim Audit Report 

reports to materially correct the 

icial activity V|pn^ bank 

in 2011 toting 

Dtaling $10,028. In addition, 

12. In 2012, URP 

6, respectively. In 

URP led its disclosure 

jB^d 2012 reports. 

Leg»l Standard ^ 

Contents of Repi-i ~ ch ref^ must discf 

• the amount of^^^on-^d at the beg^^g and end of the reporting period: 

• the total amoun^^^ ^ing period and for the calendar year; 

ofm ' sementsTor the reporting period and for the calendar 

r, and; 

^ transai diat i itemization on Schedule A (Itemized Receipts) 

• dule B (I ized D^bursements). 52 U.S.C. 30104 (b)(l),(2),(3),(4) and 

(5 J 

Facta and \H ilysi^ 

A. Facts 

As part of audit fieldwork, the Audit staff reconciled URP's reported financial activity 

with its bank records for 2011 and 2012. For the 2011 bank reconciliation, the Audit 

staff identified a misstatement of receipts and of the ending cash-on-hand balance. For 

the 2012 bank reconciliation, URP understated both its receipts and disbursements. The 

following charts detail the discrepancies between URP's disclosure reports and its bank 

records, and the succeeding paragraphs explain why the discrepancies occurred. 
11 

2011 Committee Activity 

Reported Bank Records Discrepancy 

Beginning Cash Balance @ 

January 1,2011 

$183 $421 $238 

Understated 

Receipts $542,049 $532,991 $9,058 

Overstated 

Disbursements $537,131 $538,339 $1,208 

Understated 

Ending Cash Balance @ 

December 31,2011 

$5,101 ($4^ $10,028 

Overstated 

Receipts in 2011 were overstated by $9,058. However, ^en the identified 

errors, regardless of whether the errors were nositiv^i^^ative (a^ e value), the 

receipts were misstated by $ 107,013. In additioii^^Tn);028 oversi of ending 

cash-on-hand balance resulted fom the fdlloA^i justm^nts that should de to 

correct the reporting of receipts totaling $107^ 

Transfers from non-federal accounts, over i 

Transfers fiom non-federal adii s, not 

Contributions fiom individual? 

Contributions over reported (nof 

Unitemized contributions, over 

SumofRepor in* iiTMoments 

$36,301 

49,026 

25 

15,500 

6.161 

S 107.013 

2012 Committee'^^^ity ^ 

Bank Records Discrepancy 

Beg^^^ - fflc^i ^^1 

J^Mry 1,20 ^ ^ 

($4,927) $10,028 

Overstated 

s W220,117 $2,334,699 $114,582 

Understated 

Disbui^ s W $2,192,403 $2,288,579 $96,176 

Understated 

Ending Casli'^l^^^^^ 

December 31, 

$32,816'' $41,193 $8,377^ 

Understated 

The understatement of receipts resulted from the following: 

• Transfers from non-federal accounts, over reported 

• Transfer fiom non-federal accounts, not reported 

• Contributions from political committees, individuals & refunds 

not reported 

• Contributions from individuals and political committees 

($20,584) 

133,058 

66,758 

' This total does not foot due to dollar amount rounding. 

^ This total does not foot due to dollar amount rounding. 
12 

over reported 

• Unitemized contributions, over reported 

• Unexplained differences 

Net Understatement of Receipts 

The understatement of disbursements resulted from the following: 

• Payroll and payroll taxes, not reported 

• Bank fees, not reported 

• Vendor payments, transfers to the non-federal account, 

and other disbursements, not reported 

• Bank fees, over reported 

• Operating disbursements, over reported 

• Federal Election Activity, over reported ^ 

• Transfers to affiliated/other party commit 

• Unexplained differences 

Net Understatement of Disbui -• inThe $8,377 understatement of the ending cash-oi 

misstatements described above. 

B. Interim Audit Report & Ainl 

The Audit staff discussed this matter wi' 

provided supporting schedules of the 

questions for clarificati ted they 

supporting schedules.^vidgd he Audit 

In response to the exil :ei 

"at a time th~ ission 

instruci 

(15,668) 

(11.351) 

(37,631) 

S114.582 

$48,105 

1,387 

75,201 

(5,887) 

(2,695) 

(1,173) 

(904) 

(17,858) 

mm 

anc&resulted frof^ the 

Ret iiiiiiiiendation 

itativ he exit conference and 

j^sentatives asked 

arecomect. 

_)orts if they determine the 

ives stated they will amend the reports 

accordance with the Audit Division's 

Thq^ Audit Rq 

i noted abo^ 

report to id@^^any sub 

adjustments. ' erin 

on-hand balance 

•mi URP amend its disclosure reports to correct the 

1 rec^cile the cash-on-hand balance on its most recent 

.mt discrepancies that could affect the recommended 

lit Report further recommended that URP adjust the cashon its most recent report, noting that the adjustment is the 

result of prior-perioi^^it adjustments. 

C. Committee Response to Interim Audit Report 

In response to the Interim Audit Report recommendation, URP amended its disclosure 

reports to materially correct the misstatements for both 2011 and 2012 reports. 
13 

Finding 4. Recordkeeping for Employees 

Summary 

During audit fieldwork, the Audit staff identified that URP did not maintain any monthly 

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

connection with a federal election. For 2011 and 2012, the Audit staff identified 

payments to URP employees totaling $285,242 for which URP did not maintain monthly 

payroll logs. This consisted of $269,776 for which payroll was allocated with federal and 

non-federal funds, and $15,466 for which payroll was exclusively paid with non-federal 

funds. In'response to the Interim Audit Report recommendatioii^^^'s counsel stated 

that URP has long since remedied the issue identified for this^^r^URP has complied 

with the Interim Audit Report recommendations by imple ^ plan to maintain 

monthly payroll logs in the future. 

Legal Standard 

Maintenance of Monthly Logs. Party commi 

percentage of time each employee spends in 

Allocations of salaries, wages, and fringe benefit* 

• employees who spend 25 percent or less of theu 

month on federal election act" lust be paii 

or be allocated as administrat 

• employees who spend more 

month on federal election activitii 

• employees who le of their'' 

election activ^i aid entire]^ inthfun 

CFR§106 

I federal i 

lows: 

pensated time in a given 

from the federal account 

sir I -sated time in a given 

'^m a federal account; and, 

in a given month on federal 

that comply with state law. 11 

Facts and \n.i1>si8 

fleldworl 

maintai mthlypa; 

time each« spen 

to document r all 

salaries and wag 

vu« previewed disbursements for payroll. URP did not. 

logsJr equivalent records to document the percentage of 

Jsonnection with a federal election. These logs ^ required 

tion of federal and non-federal funds used to pay employee 

[ 1 and 2012, URP did not maintain monthly logs for 

$285,242^ in payro s amount includes payroll paid as follows to URP employees. 

1. 

2. 

Employees reported on Schedule H4(Shared Federal/Non-Federal Activity) 

and paid with a mixture of federal and non-federal funds during the same 

month (totaling $269,776); 

Employees reported on Schedule H4 and also paid with both a mixture of 

federal and non-federal funds and exclusively non-federal funds during the 

same month (totaling $962); and 

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

such (see Part I, Background, Commission Guidance, Request fbr Early Commission Consideration of a 

Legal Question, Page I). Payroll amounts are stated net of taxes and fringe benefits. 
14 

3. Employees paid exclusively with non-federal funds in a given month and not 

reported by URP (totaling $14,504). 

B. Interim Audit Report & Audit Division Recommendation 

The Audit staff discussed the recordkeeping requirement with URP representatives 

during the exit conference. URP representatives stated they believed the payroll was 

allocated correctly. URP has not located any payroll logs and noted that Ae plan moving 

forward is to keep payroll logs. 

In response to the exit conference, URP representatives stated thayhe "[p]arty undertook 

efforts to ensure that staff time and other expenses were propei^^^qpted between its 

federal and non-federal accounts. The Party did not howev intain monthly pa^ll 

logs during the 2012 election cycle." URP representative ited they intend to 

maintain such payroll logs in the future. 

URP submitted an affidavit from the executive 

stating that identified employees did not sj 

compensated work time on activities in connect 

affidavit further states that the executive director al 

of his time on activities in connection.with a federal e 

ir during 2011-zu-j 

than 2§. percent of 

electioi 

it cycle 

le 

spend more than 25 percent 

The affidavit provided by URP does nt 

does not document the time an employ 

The Interim Audit 

monthly time logs cumc 

with a federal eled , "m^ 

future. 

record] i!|ffinding because it 

' m a federal election. 

lended th^pRP prov^pe evidence that it maintained 

e percenta^^f time an employee spent in cormection 

bnt a plan toT itain monthly payroll logs in the 

C. nnmwMllii III • 

In re : to the 

hasl 3ce remedied 

exit confer URP repi 

but intend b -intain mo 

m Audit Report 

recommendation, URP's counsel stated that URP 

sue >^x...fied for this finding. Again, in response to the 

itati^s stated they did not maintain monthly payroll logs 

^ payroll logs in the future. As such, URP has complied 

with the Interi^^ recommendation by implementing a plan to maintain 

monthly payroll 1« ^ 

Finding 5. Report of Debts and Obligations 

Summuy 

During audit fieldwork, the Audit staff noted that URP failed to disclose debts and 

obligations to five vendors and one staff member totaling $205,323 on Schedule D (Debts 

and Obligations). In response to the Interim Audit Report recommendation, URP filed 

amended reports to disclose debts and obligations regarding the five vendors totaling 

$101,710.79. However, URP did not disclose the debt totaling $94,132 for the staff 
15 

member because it disagrees that these items should be considered as debt. As a result, 

URP did not materially correct the reporting of debts and obligations. 

Legcd Standard 

A. Continuous Reporting Required. A political committee must disclose the amount 

and nature of outstanding debts and obligations until those debts are extinguished. 

52 U.S.C. §30104(b)(8) and 11 CFR §§104.3(d) and 104.11(a). 

B. Separate Schedules. A political committee must file separate schedules for debts 

owed by the committee and debts owed to the committee, togethi ith a statement 

explaining the circumstances and conditions under which eaci obligation was 

incurred or extinguished. 11 CFR §104.11(a). 

C. Itemizing Debts and Obligations. 

• A debt of $500 or less must be reported onc^PI^ been out^i^ 

the date incurred (the date of the transat ' ^ the committee r«. 

regularly scheduled report. ^ 

• A debt exceeding $500 must be disclost ^e renp^tiat covers 

which the debt was incurred. 11 CFR § 104. 

g 60 days from 

on the next 

uate on 

D. Advances by Committee Staff an I ( 

1. Scope. This section applies 1 

vendors. Individuals who are* 

requirements ' CFR §§11 

2. Tbetreat^ni • • •iiiributioi 

her persQ^fund^ uding a 

r Individu.-! 

whoa 

pro 

or on beha 

ices to, or 

ting as commercial 

Vendors shall follow the 

paym^ by an individual from his or 

nal credit caM, for the costs incurred in 

goods or services that are used by 

committee is a contribution unless the 

100.79, it shall be considered a 

^^^vidual uniessit h le individual's transportation expenses incurred 

ling .,whalf of a candidate or political committee of a 

or for usual and normal subsistence expenses incurred 

idual, other than a volunteer, while traveling on behalf of a 

or political committee of a political party; and 

ividual is reimbursed within sixty days after the closing date of 

tilling statement on which the charges first appear if the payment 

made using a personal credit card, or within thirty days after the 

date on which the expenses were incurred if a personal credit card was 

not used. For purposes of this section, the closing date shall be the 

date indicated on the billing statement which serves as the cutoff date 

for determine which charges are included on that billing statement. In 

addition, "subsistence expense" includes only expenditures for 

personal living expenses related to a particular individual traveling on. 

committee business, such as food or lodging. 11 §CFR 116.5(b). 
16 

3. 

4. 

5. 

Treatment as debts. A political committee shall treat the obligation arising 

from a payment described in paragraph (b) of this section as an outstanding 

debt until reimbursed. 11 CFR §116.S(c). 

Settlement or forgiveness of the debt. The individual and political 

committee may agree to the total forgives of the debt (see 11 CFR §116.8) or 

settlement of the debt if less than the entire amount owed (See 11 CFR 

§116.7), provided that the requirements of 11 CFR §116.7 or §116.8, as 

appropriate, including the submission of the information specified in these 

sections and Conunission review, are satisfied. The provision of this part 

shall not be construed to require the individual to foq r settle the debt for 

less than the entire amount owed. ^ ^ 

Reporting. The political committee shall contii report the obligation 

arising from the payment as a debt in accord^ CFR §116.7(f) or 

until the Conunission has completed a reviev^ the . to forgive the 

debt pursuant to 11 CFR § 116.8, or untij^^gpfitical co ; pays the debt, 

whichever occurs first. 1ICFR §116 

Facts and Analsrsis 

A. Facts 

During audit fleldwork, the Audit: 

disclosure reports for proper reporting ( 

debts totaling $205,323^ that URP failed^ 

concerning five vendors and one staff me 

totaling $111,191 prov^il^^ / catering,^ 

equipment rental a ' mini- veexp 

vendors based on -1 ;e demand the si 

were greater than $500 

lURP's UIO ement records and 

obligati ^^is review identified 

sdul^ during the audit period 

jgttfe records, the five vendors 

ulings/p^mng services, software, 

tThe Audit staff calculated the debts to the 

: payment date. Most of the debts 

riods ranging from 31 to 416 days. 

ret 

reimbursi 

provided 

expenses 

ts were 

form. Th( 

ition ( 

, totali^ $94,132, was for reimbursements for 

imember's personal credit card. Most 

Die 60 days from the date of the expense per the 

t anmunt for the staff member was calculated based on 

sting of an expense reimbursement form submitted by the 

staff member, WA' 'nvo^s. The Audit staff used the individual dates of incurrence 

listed on the exp( mursement form. The Audit staff did not use the date the 

reimbursement form submitted because this date was unknown. Documentation such 

as the staff member'Ccredit card billing statements, requested by the Audit staff, was not 

provided. URP provided one credit card statement with the closing billing date during 

fieldwork. 

^ Each debt in this amount was counted once even if it is a required disclosure over multiple periods. In 

order for URP to correctly file amended reports, schedules were provided that included the amount of 

each debt required to be reported for each reporting period. 

' The staff member is also discussed in Finding 6 for possible violation of 11 CFR § I I6.S(b), advances by 

committee staff considered a contribution. 
17 

B. Interim Audit Report & Audit Division Recommendation 

At the exit conference, the Audit staff discussed the reporting of debts and obligations 

with URP representatives and provided a schedule detailing the transactions requiring 

disclosure on Schedule D. UBUP representatives acknowledged they understood the 

schedules for vendors. They further stated the staff member turned in the expense reports 

late so URP did not know when the expenses needed to be reimbursed or that the 

expenses had been incurred. Therefore, the expenses could not be reported correctly. 

In response to the exit conference, URP representatives noted that most of the debt items 

were related to expense reimbursements paid to the staff member ^ TRP representatives 

questioned the Audit staffs date calculation and stated they w^ l^ware of the staff 

member's expenses until after receipts and/or expense repo re presented to the 

treasurer, which frequently occurred well after the underlw ses were incurred. 

URP representatives added the regular practice was t^s^ rein lents to the staff 

member within a calendar week of receipt of the ex^^^ramburs .^form. URP 

feels that the Audit staff should not consider the^^penses as debt it^^^m the date 

they were incurred since, generally, URP was^^^ 'are b^e expense after 

the date of incurrence. 

The Audit staff acknowledges that pisQ^yiding this ind credit card statements with 

the billing cycle closing date could ha^ ;ed some o ;bt disclosure omissions 

for the staff member. However, unless credit ^ditements are provided 

to show the closing date of the billing cy%, s.^^ysis would remain 

unchanged. URP offered no further comi^ ^^^^feaegndors representing $111,191 

of the undisclosed debj^j^^^'' itiohs. 

The Interim Audits ^^^recoi 

expenditures totaling 

st^ memi 

The Int^ 

mdedURP 

cara 

itsrj' to disclose 

ade documentation demonstrating the 

iire I , )rting on Schedule D; or provide the 

l^^th the closing date of the billing cycle, 

lended absent such documentation, URP amend 

ons totaling $205,323 on Schedule D. 

C. Con Response'^nte^m Audit Report 

In response^^^Interim ^dit Report recommendation, URP filed amended reports to 

disclose $101,W^ lie %W\,\9\ in debts for the five vendors. However, URP did not 

disclose any of tt Amber's debt totaling $94,132. URP restated they were not 

aware of the staff mi r's expenses until after receipts and/or expense reports were 

presented to the trea^er. The regular practice was to issue reimbursements within a 

calendar week of receipt of the expense reimbursement form. Therefore, URP does not 

think these expenses are debt. 

It is noted URP did not provide any documentation demonstrating the date it received the 

expense reimbursement forms from the staff member. Nor did URP provide the staff 

member's credit card billing statements with the closing date of the billing cycle. 

Without this information to document alternative dates, the Audit staffs debt calculation 

continues to be based on the individual date of incurrence listed on the expense 
18 

reimbursement forms provided during fieldwork. The total debt not reported is now 

$103,612 ($94,132 + $9,480). As such, URP did not materially correct the reporting of 

debts and obligations. 

Finding . 6. Apparent Excessive Contribution- Staff Advance 

Summary 

One URP staff member received reimbursements for credit card expenditures totaling 

$46,904 that appear to have been reimbursed untimely. URP did^ttprovide the staff 

member's credit card billing statements to support the reimbi were made within 

60 days after the closing date of the billing statement. In ^ ^ to the Interim Audit 

Report recommendation, URP stated it strongly disasree^^thl^^assertion because 

URP was not aware of the reimbursable expenses w*— wer^^^ed. URP did not 

provide any documentation to demonstrate the rei^ -nents were^^^within the 

proper time limitations. As such, of the $46,9C itimely reimbursem^^o the staff 

member, the Audit staff considers $28,637 as^ §§ive ccffj^butions fiom'^ 

member until the expenses were reimbursed. No^q ' ^h,will be takeif since the 

staff member was eventually reimbursed for the expi 

Legpd Standard 

A. Advances by Committee Staff an 1 

1. Scope. This section applies 

iii-iiiiiluals. 

who are 

"1 §§116.3 

mributions. 

uding a 

^ot acting as commercial 

I vendors shall follow the 

payme 

ontributio^ 

coi 

116.4.^ 

payment by an individual from his or 

credit card, for the costs incurred in 

ig goods or services that are used by 

:al committee is a contribution unless the 

11 CFR 100.79, it shall be considered a 

unlessthe individual's transportation expenses inured 

ling on behalf of a candidate or political committee of a 

or for usual and normal subsistence expenses incurred 

lividual, other than a volunteer, while traveling on behalf of a 

e or political committee of a political party; and 

b) T^individual is reimbursed within sixty days after the closing date of 

the billing statement on which the charges first appear if the payment 

was made using a personal credit card, or within thirty days after the 

date on which the expenses were incurred if a person^ credit card was 

not used. For purposes of this section, the closing date shall be the 

date indicated on the billing statement which serves as the cutoff date 

for determine which charges are included on that billing statement. In 

addition, "subsistence expense" includes only expenditures for 

personal living expenses related to a particular individual traveling on 

committee business, such as food or lodging. 11 §CFR 116.S(b). 
19 

3. 

4. 

5. 

Treatment as debts. A political committee shall treat the obligation arising 

from a payment described in paragraph (b) of this section as an outstanding 

debt until reimbursed. 11 CFR §116.S(c). 

Settlement or forgiveness of the debt. The individual and political 

committee may agree to the total forgives of the debt (see 11 CFR § 116.8) or 

settlement of the debt if less than the entire amount owed (See 11 CFR 

§116.7), provided that the requirements of 11 CFR §116.7 or §116.8, as 

appropriate, including the submission of the information specified in these 

sections and Commission review, are satisfied. The provision of this part 

shall not be construed to require the individual to for£' )r settle the debt for 

less than the entire amount owed. 

Reporting. The political committee shall conti 

arising from the payment as a debt in 

until the Commission has completed a: 

debt pursuant to 11 CFR §116.8, or untij 

whichever occurs first. 11 CFR §116.i 

eport the obligation 

3FR§116.7(f) or 

the rea^st to forgive the 

ical com e pays the debt. 

B. Travel Expenses Exceeding S2,000 Exem[ 

expenses^ that exceed the $2,000 travel exemptil 

the committee reimburses them: ^ 

• Within 60 days', if the paymera nade on a 

• Within 30 days, if the payment ith cas 

§116.5(b) and 100.79(a)(2); 

for transpc^tion 

nsfdered contributions unless 

aid; or 

f^heck. 11 CFR 

ittee may ^t receive more than a total of 

itributor.%2U.S.C. §30116(a)(1)(D). 

C. Party CommitteeJ, i -iii 

$10,000 a yeai any 

Facts and Analjrsis 

A. Fag^ 

Dur litfieldwoi \A Reviewed individuals who received 

reiif ^^ntsfiximUI^ )nes uember received reimbursements totaling 

$197,850 u^^hout the a t cycle for expenditures paid mostly with the employee's 

personal cre^^^.' Of 1 e reimbursements, $46,904 was more than 60 days from the 

date of the expen th mbursement form. The Audit staff calculated the days 

outstanding by us _ mdividual dates of incurrence listed on the expense 

r 

Including usual and normal subsistence expenses (such .as food and lodging) incurred while traveling on 

behalf of the candidate. 

Sixty days after the closing date of the credit card billing statement where the charge first appeared. 

Based on the documentation provided, the Audit staff could not verily if five transactions were paid using 

the employee's personal credit card versus cash or check. 
20 

reimbursement form. Of the $46,904 untimely reimbursements, $28,637 ($46,904 -

$18,267) is considered an excessive contribution from the staff member, pursuant to 11 

CFR§116.5(b).'° 

URP provided invoices, receipts, and expense reimbursement forms to support the 

expenditures but provided only one credit card statement with the closing billing date 

during audit fieldwork. None of these untimely reimbursements were for travel expenses 

that were reimbursed within 60 days from the date of the expense per the reimbursement 

form, or within 30 days if paid wift cash or check, per 11 CFR§116.5(b) and 

100.79(a)(2). 

B. Interim Audit Report & Audit Division Re< iniiiiiendation 

At the exit conference, the Audit staff discussed the rein^ Is for the one staff 

member and provided a schedule detailing the transa^^(witirfi ^cussion of debts 

and obligations at Finding 5 above). URP represe^'^bi^s^ted th ff member turned 

in the expense reports late so URP did not know^^n the expenses n^l be 

reimbursed or that the expenses had been incui^^' V ^ 

In response to the exit conference, URP represent, 

calculation and stated they were not tu^ue of the si 

receipts and/or expense reports were p " ' »the 

well after the underlying expenses wei iv. URP 

practice was to issue reimbursements to 

receipt of the expense reimbursement 

cihed the Ai udit staffs date 

's expenses until after 

which frequently occurred 

^ives added the regular 

calendar week of 

The Audit staff acl^^ledge 

the billing cycle clf^i te col 

excessive contribution 

statements Tin) 

reimbu^t Imelv.^ 

$28,63^ consic 

providin^ds individual's credit card statements with 

have reducT le amount considered to be an 

ee. Ho* er, unless copies of the credit card 

provided to demonstrate the 

.udit stales analysis would remain unchanged. The 

ribution from the staff member until reimbursed. 

jmnl^ded URP provide documentation, such as the 

lent with the closing billing date, to demonstrate the 

The Intenn lit Repon 

employee's -ard 

reimbursemeni 

C. Committee Res. n to Interim Audit Report 

In response to the Ini^rim Audit Report recommendation, URP stated it strongly 

disagrees with this finding. URP restated they only became aware of the staff member's 

reimbursable expenses after he presented receipts and/or expense reports to the treasurer, 

which frequently occurred after the underlying expenses were incurred. In addition URP 

The untimely staff reimbursements totaled $50,904. The amount was adjusted to $46,904 after applying 

the $4,000 travel allowance per 11 CFR § 100.79(a)(2). The amount was further adjusted because an 

individual may contribute up to $10,000 per year to a state party. The staff member contributed $ 1,733 

in 2011 and did not make a contribution to URP in 2012. Therefore the staff member could have 

contributed $18,267 ($20,000 - $1,733). 
21 

said the regular practice was to issue staff reimbursements within a calendar week of 

presentation. Given this practice, URP feels the Commission should not consider these 

expenses as in-kind contributions as of the date they were incurred. 

The Audit staff maintains the closing date on the billing statement is important because it 

is used as the trigger date to determine if the expenses initially paid for by the staff 

member will result in a contribution to URP. Specifically, the Commission's regulations 

require payments by a committee staff member to be treated as contributions, unless the 

payments are exempt finm the definition of contribution as unreimbursed transportation 

and subsistence expenses under 11 CFR §100.79 and 11 CFR §lj^(b). If the payments 

are not exempt, they are contributions unless (1) the paymentsstaff member's 

travel expense or subsistence expenses incurr^ while trave^^n behalf of the 

committee, and (2) the committee reimburse the staff mej^^^fcin 60 days "after the 

closing date of the billing statement on which the chareei^rst a^^ ~the payment was 

made using a personal credit card, or within thirty ^^^et the da ,^^hich the 

expenses were" incurred if a personal credit can ^ot used". 11 CFm 5(b)(1) & 

(2). ^ V ' 

URP provided one credit card statement with a hi ^j^mg ^ate. Given ^at most 

credit card statements are 30 days or^e month in' _ . J-. . , 

the other closing dates based on the on 

closing date in lieu of the actual billin] 

from the staff niember would no longer 

date is not as precise as using the actual 

card billing statement^ 

reimbursed within sixw days^ 

The Audit staff notes 

staff meml " do 

le Audit staff was to infer 

card state 

staff 

Ihe closini 

was available with a 

fcessive contributions 

\ inferring the closing 

it all the necessary credit 

ify tha^e staff member was 

of the billing statement. 

tion to sh< 

1 excess 

expense! areimbursei 

eventually ra|i sed foi 

.reuni 

al^w .lecessaiy credit card statements of the 

did URP provide documentation to 

expense reimbursement form. Without this 

were made within the proper time limitations, 

"totaling $28,637 from the staff member until the 

ler action will be taken since the staff member was 

expenses. 

" If the infened billing date is used in lieu of the actual billing closing dates from the credit card statements 

as provided by the committee, the total amount of debts and obligations not disclosed for the staff 

member reduces from S94,I32 to SS0,2S9: See Finding S-Report of Debts and Obligations, page 14.