FEDERAL ELECTION COMMISSION 

WASHINGTON, D.C. 20463 

November 14, 2008 

Shirley J. Simmons, Treasurer 

Talent For Senate, Inc. 

21 N Meramec 

2l1d Floor 

Clayton, MO 63105 

Attn: Garrett Lott 

Dear Ms. Simmons: 

Attached, please find the Report of the Audit Division on Talent for Senate, Inc. The 

Commission approved this report on November 5,2008. 

The Commission approved Final Audit Report will be placed on the public record on 

November 24, 2008. Should you have any questions regarding the public release of this 

report, please contact the Commission's Press Office at (202) 694-1220. 

Any questions you may have related to matters covered during the audit or in the report 

should be directed to Robert Morcomb or Thomas J. Nurthen of the Audit Division at 

(202) 694-1200 or toll free at (80C) 424-9530. 

Sincerely, 

Wanda J. Thomas 

Acting Assistant Staff Director 

Audit Division 

Attachment as stated 
Report of the 

Audit Division on Talent for 

Senate, Inc. 

January 1, 2005 - December 31, 2006 

Why the Audit 

Was Done 

Federal law permits the 

Commission to conduct 

audits and field 

investigations of any 

political committee that is 

required to file reports 

under the Federal 

Election Campaign Act 

(the Act). The 

Commission generall y 

conducts such audits 

when a committee 

appears not to have met 

the threshold 

requirements for 

substantial compliance 

with the 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. 

2 u.s.c. §438(b). 

About the Campaign (p. 2)
 

Talent for Senate, Inc. (TFS) is the principal campaign committee
 

for James M. Talent, Republican candidate for the United States
 

Senate from the state of Missouri. TFS is headquartered in St.
 

Louis, Missouri. For more information, see chart on the
 

Campaign Organization, p. 2.
 

Financial Activity (p. 2) 

•	 Receipts 

o	 From Individuals $ 8,961,464 

o	 From Political Party Committees 35,000 

o	 From Other Political Committees 3,458,700 

o	 From Other Authorized 1,405,346 

Committees 

o	 Offsets to Operating Expenditures 83,098 

o	 Other Receipts 172,595 

o	 Total Receipts $ 14,116,203 

•	 Disbursements 

o Operating Expenditures	 $ 14,202,656 

o Refunds of Contributions	 155,260 

o Total Disbursements	 $ 14,357,916 

Finding and Recommendation (p.3) 

•	 Failure to File 48-Hour Notices 

I 
Table of Contents 

Page 

Part I. Background
 

Authority for Audit 1
 

Scope of Audit 1
 

Part II. Overview of Campaign
 

Campaign Organization 2
 

Overview of Financial Activity 2
 

Part III. Summary 

Finding and Recommendation 3
 

Part IV. Finding and Recommendation 

Failure to File 48-Hour Notices 4
 
Part I 

Background 

Authority for Audit 

This report is based on an audit of the Talent for Senate, Inc. (TFS), 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 2 US.c. §438(b), which permits the Commission to 

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

report under 2 US.c. §434. Prior to conducting any audit under this subsection, the 

Commission must perform an internal review of reports filed by selected committees to 

determine if the reports filed by a particular committee meet the threshold requirements 

for substantial compliance with the Act. 2 US.c. §438(b). 

Scope of Audit 

This audit examined: 

1. The receipt of excessive contributions and loans. 

2. The receipt of contributions from prohibited sources. 

3. The disclosure of contributions received. 

4. The disclosure of disbursements, debts and obligations. 

5. The consistency between reported figures and bank records. 

6. The completeness of records. 

7. Other committee operations necessary to the review. 
2 

Part II 

Overview of Campaign 

Campaign Organization 

Important Dates Talent for Senate, Inc. 

• Date of Registration July 14,2003 

• Audit Coverage January 1,2005 ­ December 31,2006 

Headquarters St. Louis, Missouri 

Bank Information 

• Bank Depositories 3 

• Bank Accounts 4 

Treasurer 

• Treasurer When Audit Was Conducted Shirley J. Simmons 

• Treasurer During Period Covered by Audit Garrett M. Lott & Shirley J. Simmons 

Management Information 

• Attended FEC Campaign Finance Seminar Yes 

• Used Commonly Available Campaign 

Management Software Package 

Yes 

•	 Who Handled Accounting and Recordkeeping Garrett M. Lott 

Tasks 

Overview of Financial Activity 

(Audited Amounts) 

Cash on hand @ January 1, 2005 $ 245,500 

0 From Individuals $8,961,464 

0 From Political Party Committees 35,000 

0 From Other Political Committees 3,458,700 

0 From Other Authorized Committees 1,405,346 

0 Offsets to Operating Expenditures 83,098 

0 Other Receipts 172,595 

Total Receipts $ 14,116,203 

0 Operating Expenditures $14,202,656 

0 Refunds of Contributions 155,260 

Total Disbursements $ 14,357,916 

Cash on hand @ December 31, 2006 $ 3,787 
3 

Part III 

Summary 

Finding and Recommendation 

Failure to File 48-Hour Notices 

A review of contributions by the Audit staff identified 38 contributions totaling $62,300 

for which TFS did not file the required 48-hour notices. In response, TFS agreed with the 

amount addressed in the interim audit report. In addition, TFS stated that it intended to 

file 48-hour notices for all contributions requiring this notice. (For more detail, see p. 4) 
4 

Part IV
 

Finding and Recommendation
 

IFailure to File 48-Hour Notices 

Summary 

A review of contributions by the Audit staff identified 38 contributions totaling $62,300 

for which TFS did not file the required 48-hour notices. In response, TFS agreed with the 

amount addressed in the interim audit report. In addition, TFS stated that it intended to 

file 48-hour notices for all contributions requiring this notice. 

Legal Standard 

Last-Minute Contributions (48-Hour Notice). Campaign committees must file special 

notices regarding contributions of $1,000 or more received less than 20 days but more 

than 48 hours before any election in which the candidate is running. This rule applies to 

all types of contributions to any authorized committee of the candidate, including: 

• Contributions from the candidate; 

• Loans from the candidate and other non-bank sources; and 

Endorsements or guarantees of loans from banks. 11 CFR §104.5(f) 

Facts and Analysis 

TFS was required to file 48-hour notices for the primary and general elections for those 

contributions of $1,000 and greater, received less than 20 days but no more than 48 hours 

before the election. The Audit staff reviewed those contributions. TFS failed to file 48­

hour notices for 38 contributions totaling $62,300. Those contributions are summarized 

below: 

Contribution Type Primary General Total 

Contributions from Individuals $6,000 $29,300 $35,300 

Contributions from Political Committees $21,000 $6,000 $27,000 

Total 48-Hour Notices not Filed $27,000 $35,300 $62,300 

At the exit conference, the Audit staff informed TFS representative of the finding. The 

representative stated that TFS tried to file all notices and that they believe multiple pages 

of the 48-hour notice faxes may have gotten stuck together. 

Interim Audit Report Recommendation and Committee Response 

The Audit staff recommended that TFS provide evidence that 48-hour notices were filed 

timely for those contributions mentioned above or provide any comments it has regarding 

this matter. In response, TFS agreed with the amount addressed in the interim audit 

report. In addition, TFS stated that it intended to file 48-hour notices for all the 
5 

contributions requiring this notice. TFS believes that when the notices were faxed to the 

FEe several pages did not transmit properly. However, they did not include copies of the 

faxed 48-hour notices with the response. Finally, TFS stated that in the future notices 

will be transmitted electronically to prevent this from happening again.