FEDERAL ELECTION COMMISSION 

WASHINGTON, D.C.-20463 

MEMORANDUM 

JUNO 4 

TO: 

FROM: 

Patricia C. Orrock 

Chief Compliance Ofilicer 

Thomas E. Hintennister 

Assistant Staff Director 

Audit Division 

Lisa J. Stevenson 

Deputy General Counsel - Law 

Lorenzo Holloway 

Assistant General Counsel 

Compliance Advice 

Margaret J. Forman yy) ^ ^ 

Attorney * 

SUBJECT: Draft Final Audit Report on Jill Stein for President (LRA 91S) 

I. INTRODUCTION 

The Office of the General Counsel has reviewed the Draft Final Audit Report ("DFAR") 

on Jill Stein for President ("Committee"). The DFAR contains six findings: Net Outstanding 

Campaign Obligations (Finding 1); Misstatement of Financial Activity (Finding 2); Disclosure of 

Debts and Obligations (Finding 3); Reporting of Receipts (Finding 4); Reporting of Expenditures 

(Finding 5); and Itemization of Candidate Loans (Finding 6). We comment on the Committee 

Structure paragraph under the Part I Background section, and the Financial Activity and Overview 

of Financial Activity sections of the DFAR. We otherwise concur with the DFAR. If you have 

any questions, ple^e contact Margaret J. Forman, the attorney assigned to this audit. 
Jill Stein for President - LRA 915 

DFAR Comments 

Page 2 of2 

II. DFAR SHOULD EXPLAIN EFFECT OF THE COMMITTEE'S STRUCTURE ON 

THE FINDINGS, AND WHY CANDIDATE LOAN IS NOT EXCESSIVE 

The DFAR includes a "Committee Structure" paragraph in the Background section. This 

paragraph states that Jill Stein for President was the only committee for the presidential candidate, 

and it disclosed both primary and general election receipts and disbursements. Nothing in this 

paragraph, or in the DFAR in general, however, explains how, and if, the structure of the 

Committee affects the audit findings. 

This is a mandatory audit under the Presidential Primary Matching Payment Account Act, 

and as such, the audit must focus on the qualified campaign expenses of the candidate who 

received public funds. 26 U.S.C. § 9038(a). In this case, the candidate only received public funds 

for the primary elections. The audit report, therefore, should focus on that portion of the campaign 

that relates to the primary elections. We recommend that the Audit Division include an 

explanation in the DFAR of whether, and if so how, the Committee's structure of using one 

committee for the primary and general elections affects any of the findings, including a statement 

of the amount of any general election receipts or disbursements, if any, that are addressed in any of 

the findings. 

We also recommend that the Audit Division revise the Financial Activity and Overview of 

Financial Activity sections of the DFAR. These sections indicate that the candidate made $64,000 

in loans to the Committee. Candidates who. receive public funds for the primary elections have a 

$50,000 personal expenditure limitation. 26 U.S.C. § 9035(a); II C.F.R. § 9035.2. The DFAR 

does not explain if the candidate exceeded her personal expenditure limitation. 

According to the Audit Division, however, $20,000 of the candidate's loans were not for 

the primary elections but rather for the general election. These facts are not explained in the audit 

report. We, therefore, recommend that the Audit Division include these facts in the DFAR to 

explain why the candidate loans do not exceed the $50,000 limitation.