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REPORrr OF TIlE AUDIT DIVISION

ON 'rIlE

:~ational Republican Congressional Committee

I. l3(lck<J~ound

1'his report covers an audi t of the National Republican

Conqrcssional Committee (lithe Committee"), undertaken by the

Audit Division of the Federal Election Commission in accordance with the Commission's audit policy to determine whether

there hus been compli~lnce wi th the provisions of the Federal

Election CLlmpai~Hl Act of 19~/1, aSilmended C'~' t~h~~l\Qt:"). The

audi t \vas conducted pursuan t to 2 U. S.C. 438 (a) (8) which

directs the Conunission to make from time to time audits and

field invcstiyations with respect to reports and statements

filed under the provisions of this chapter.

The Committl~l.~ r('qistcrL~d with the Cl(.'t~k of the u.S.

Ilou~,e of p. ·prC'sl'n~·at.i\'~~s on ;\i.)ril 17, 1~)'12, and maintains its

h~ c.ld q u art l~ r sin \.:ashi nljLo11, 1).C •

'l'hl.~ tludi t covcr\.'d thL"' period J ulluary 1, 1975 through

JilHuary 31, 1977, thL' final covcraCfc date of the latest report

filed b~l the Comnli ttCL' at the tiI:1C of the audit. During the

period audited the Committee reportcu $348,824.56 in beginninq

cash, tot~ll rec(~ipts of $12,574,609.92, total expenditures of

$9,250,520.46 and ending C.:lsh of ~;;3,672,914.02.

Thjs audit report is based on documents and working

papers supporting each of its factual statements. They

form parl of th2 r(~cord upon \oJhich the Commission based its

li0ci~)ion3 on the matters in. this rt'port and \vere available to

Cornmissicners and appropriate st.:lff for review •

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The principal officers of the Conunittee at the time

of the audit were the Honorable GUy Vander Jagt, Chairman, and

George Olmsted, Treasurer.

C. Scope

The audit included such tests as verification of totdl

reported receipts and expenditures and individual transactions;

review of required supporting documentation and analysis of

Committee debts and obligations; and, such other audit procedures

as deemed necessary under the circumstances.

II. Auditor's Statement

It is the opinion of t.he Audit staff,b-as-ed -uponexam-ination

of the r0!)Orts and statements filed and the records presc_ntcd,

that, except for the deficiencies noted below, thL~ reports and

statements of the National Republican Congressional Committee fairly

present the financial activities of the Committee for the period

covered by the audit. Further, except as noted below, no

m~tcriL11 problems in complying with the FClleral Election C~mp:li.:~~1

Act were discovered during the course of the audit.

III. Fin<..1inqs and Conclusions

:\. Occupation and Principal Place of Business ~ot

Reported

Section 434(b) (2) of Title 2 United States Code requiros

that a co~mittee report the full name and mailing addrcss (occuputio

and principal place of business, if any) of each person who hu5 m~~c

one or I:1ore contributions to or for such committee within the

c'llc~nd~l.· ~"car in an aggregate amount or value in excess of S100.00.

A review of contributor records and reports filed b~"

the Co~::::1i t tee re\9ca10d tha t during the period audited the Cor.-.:::i t t,__·~,

did not (~isclose the occupation for approximately 58% of thos~

contributors requiring such information. In addition the Corr;mi tt~c

did not uisclose the principal place of business as required for

~ppro:·:il~:3tcly 74'~ of its contributors. This matter was referred to

tih::: l:(.)::-.~;l.:;sion' s Office of General Counsel on June 23, 1977 \-;r:.·2;:t.:

~lr~ SOl ",-:as initiatcLl. On r-.1ay 17, 1978, the Commission found
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n'clsonablc cause to believe that the Committee had violated

2 u.S.C. 434(b) (2) by failinq to report the occupation and

principal place of business for certain of its contributors.

The Commission approved a L:onciliation ayrccmcnt on Scptemuer

13, 1978 in which the Committee agreed to contact its 1975 and

1976 contributors whose occupation and/or principal place of

business were inadequately reported. In addition, the Committc'\'

agreed to prc's('nt evidence of its e:forts to conLdct th(~se

contrilJutors lllHl file ampnded rC[Jo!"ts for 1975 and 197G wi th th(..~

informlltion obtained. Based on t:-:csc actions thl~ Commi~;sion

voted to close the file on this nattcr on November 9, 1978.

The Committee subsequentl~' provided the Office of

General Counsel with evidence of its efforts to obtain the

missing cantriL" tor infornlation for 1975 and 1976. In add.i tion,

the Committee f i It~d amended reports for 1975 and 1976 on fvlarch

9, 19 79, inc 1. ud i 1\q the occupa t i on and p r inc i pal p 1u C l) 0 f b IIsines ~~

fot thl? contribut.ors.

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S 0 c t ion 4 3·1 (b) (1) t h r 0 :l~; ~1 ( 4), ( 8), ( 9 ) ancl ( 11 ) 0 f

Ti.tle 2 United St~1tCS Code rcqui~:LS that a political committl'(~

i:1clud(\ in it~-; rl'port.s the tlPloun::. c: cu~~ll on hand, the iclcnt.i ~-.icZlt.ion of c'ach p~rson and politic.:ll committ~c from \'Jhom it hus

rc:~~ivcd contributions or mauc c:-:~cndilures \·:hich in the aqqrcq.-l t (~

e:·:cocd $100 and the dZltc, amount 3:'..,::l total sum of such contribut i (}n~

a:1d expend i tur<.'s \-:i thin the cdlc~c:'ar :·car.

Our r()v ic\·: of the CO!.''''::'..:.:. ::.~~e 's bllnk records revealed d

checking account \.;as opened by tl:c Comnli ttee on January 14, 197 ')

witll RiUgs National Bank cntitlcj ~0vublican Extra Assistance

for Communications Help (Rr.;;\CH i\cc~). rrhc account was created by

former individuals of the Committee to defray cxpenses incurred by

i:-:cur.:bcnt H~publican House mCl!1b·.:~_-s for services. 'the majorit~· of

p.:t::-::"Lcnts \-ler0 to the House recor,-~i:-.\:1 studio. After adjusting

$100,000 for intcr-o.ccount tr~ns~-~;.:--s, tl1l~ account totaled

$194,418.56 in reportable recei!._'::'::3 alld ~~293, 597.08 in report:-tbl c

e:·:~)endi t.ures for tl-:e ca10ndar Y0':'1-:: 1975, the on] 'l year "~do til

r~:\ort:l.b10 (let Lvi t~·. 'j'hc balCll1cc in the:, ilccount on 12/31/76 \-JZlS

$122 .15 t;~kin~l i:1tO considcro.tic:: ~'r.·:O out~-)tandiny checks from

1 9 I' :) t: 0 L':l 1 in\; ~~ G9 9 • 3 3 •

1'!v) Cc::~!ni t toc has f i l..::·,-~ ..1.!1 ,:1!~\pnded report cover. inu tho

F\.·~-ic,J J~lnUal:'/ 1, 1<)7::>, through =0~c~bcr 31, 1975, cont3i.ninq

.,11 ~cti\·it'::" ~-rom the HE1\ClI .:lCcc·~::.:.•
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We also recommended that the Committee stop payment on

til(' L\-JO outstanding checks and transfer the balance of the REJ\Cll

aCC(Hlnt into the committee's operating account. The Committee'~~

report filed on April 10, 1977, reflects this adjustment.

Recommendation

\ve reconunend that no further action be taken on this

matter since the Committee has now filed the required lltlll'ndeJ

reports.

Section 434 (b) (9) of 'ritle 2 United States Code requir(':;

a committee to report the idt~nti[ication of each person to WhO:;1

expenditures -have- been madl' by the commi-t tee wi thin the c_alcndar

yC'Zlr in an aggregate amounL in cxcess of $100.

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c. Expenditures Aggregating In Excess of $100

Not Reported

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A revi8\'w' of invoicl's maintained by the Committee rcvcalc'd

230 reportable expcnJiturcs totaliny $262,916.29 not itemized on

the Commi.ttee's year end r('port filed on .L.lnuary 31, 1977.

Ih:'cOmI1K'nda tion

\ve reconunend th~t no further action be taken on this matter

~;incl~ the omission of. the C'xpcndi tures appeared to be a clcricol

()\'l·rsi~Jht by the COl~lmittee ~nc1 thl} Committee has filed an amended

rl'port for the period to include the expenditures initially omitted.

0. Petty C.:1sh Funds_~ot Included in Cash on Hand

Section 43~(b) (1) of Title 2 United States Code requires

th~l.t a political committee report the amount of cash on hand at

tht.~ bC~J inning of the rcport: ing periad.

The Cor::::11 t tCl: maintains four (4) pc tty cash funds tot.~linl;

$·l :H). 00. 'l'he COII.~~it tee rC'ports cxpcnc1i tures to replenish the ::-und~;

!.Jut dOl-'~ not include the petty cash in its cash on hand at tho

bL"'-Jinninq of a rcport.ing period.

l~L'cc'r.m'cndation

\\C reCon~:l(~nd th~t no further action be taken on this matter

sincc th0 Committee's report filed on l\}n:il 10, 1977, incltH.lf's an

Zl(~justment for the p\..;tty cas!l balance •
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FEDERAL ELECTION COMtvUSSION

1t.!'l 1\ "1 ~H t '" \\'

\\'·'''HI'-C10flro....D ( 204h \

ADDITIONAL INFURMATION REGARDING '!HIS ORGANIZATION

MAY BE I.OCATED IN A OOMPLETED OOMPLIANCE ACrION

FnE RELEASED BY THE <lJ+nSSION AND MADE PUBLIC IN

THE PUBLIC REOORDS OFFICE. FUR 'lHIS PARrICULAR

ORGANIZATION'S COMPLETED OOMPLIANCE ACrION FnE

SlMPLY J-SK FUR 'mE PRESS SUt+1ARY OF MlJR 41 S(./

THE PRESS S'f.M.1ARY wm.. PROVIDE A BRIEF HISTORY OF

'!HE CASE AND A StH-fARY OF '!HE ACrIONS TAKEN, IF Am•
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