Final Audit Report of the 

Commission on the Tennessee 

Democratic 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 committee that is 

required to file reports 

under the Federal 

Election Campaign Act 

(tiie Act). The 

Commission generally 

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 the matter 

discussed in this report. 

About the Committee (p. 2) 

The Tennessee Democratic Party is a state party committee 

headquartered in Nashville, Tennessee. For more information, 

see the chart on the Committee organization, p. 2. 

Financial Activity (p. 3) 

• Receipts 

o Contributions firom Individuals $1,371,485 

o Political Committee 

Contributions 160,485 

o Transfers firom Affiliates 426,007 

o Transfers from Non-federal and 

Levin Accounts 647,358 

o Other Receipts 79,155 

Total Receipts $2,684,490 

Disbursements 

o Operating Expenditures $1,536,893 

o Transfers to Affiliates 10,185 

o Independent Expenditures 20,100 

o Coordinated Party Expenditures 975 

o Federal Election Activity 1,091,186 

o Other Disbursements 46,828 

Total Disbursements $2,706,167 

Levin Receipts $150,000 

Levin Disbursements $137,180 

Commission Finding (p. 4) 

Filing of Levin Schedules 

2 U.S.C. §438(b). 
it Report of the 

Commission on the Tennessee 

Democratic Party 

(January 1, 2011 - December 31, 2012) 
Table of Contents 

Page 

Part I. Background 

Authority for Audit 1 

Scope of Audit 1 

Audit Hearing 1 

Part II. Overview of Committee 

Committee Organization 2 

Overview of Financial Activity 3 

Part III. Summary 

Commission Finding 4 

Part IV. Commission Finding 

Filing of Levin Schedules 5 
Part I 

Background 

Authority for Audit 

This report is based on an audit of the Tennessee Democratic Party (TDP), undertaken by 

the Audit Division of the Federal Election Commission (the Conunission) in accordance 

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

Division conducted the audit pursuant to 2 U.S.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 U.S.C. §434. Prior to conducting any audit under this 

subsection, the Commission must perform an intemal 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 U.S.C. §438(b). 

Scope of Audit 

Following Commission-approved procedures, the Audit staff evaluated various risk 

factors and as a result, this audit examined: 

1. the receipt of excessive contributions; 

2. the disclosure of individual contributors' occupation and name of employer; 

3. the disclosure of disbursements, debts and obligations; 

4. the disclosure of expenses allocated between federal, non-federal, and Levin 

accounts; 

5. the consistency between reported figures and bank records; 

6. the disclosure of independent expenditures; 

7. the completeness of records; and 

8. other committee operations necessary to the review. 

Audit Hearing 

TDP declined the opportunity for a hearing before the conunission on the matter 

presented in this report. 
Part II 

Overview of Committee 

Committee Organization 

Important Dates 

• Date of Registration May 19,1983 

• Audit Coverage January 1,2011 - December 31,2012 

Headquarters Nashville, Tennessee 

Bank Information 

• Bank Depositories Two 

• Bank Accounts Five federal. Three non-federal. One 

Levin 

Treasurer 

• Treasurer When Audit Was Conducted Wade Munday 

• Treasurer During Period Covered by Audit Matt Langley: January 1,2011-October 

10,2011 

David Garrison: October 11,201 l -

December 31,2012 

Management Information 

• Attended Commission Campaign Finance 

Seminar 

Yes 

• Who Handled Accounting and 

Recordkeeping Tasks 

Paid Staff 
Overviewr of Financial Activity 

(Audited Amounts) 

Cash-on-hand @ January 1,2011 $45,680 

Receipts 

o Contributions firom Individuals 1,371,485 

o Political Committee Contributions 160,485 

o Transfers firom Affiliates 426,007 

o Transfers from Non-federal and Levin 

Accounts 

647,358 

o Other Receipts 79,155 

Total Receipts $ 2,684,490 

Disbursements 

o Operating Expenditures 1,536,893 

o Transfers to Affiliates 10,185 

o Independent Expenditures 20,100 

o Coordinated Party Expenditures 975 

o Federal Election Activity 1,091,186 

o Other Disbursements 46,288 

Total Disbursements $ 2,706,167 

Cash-on-hand @ December 31,2012 $ 23,804^ 

Levin Cash-on-hand @ January 1,2011 $0 

Total Levin Receipts $ 150,000 

Total Levin Disbursements $ 137,180 

Levin Cash-on-hand @ December 31,2012 $ 12,820 

TDP's ending cash-on-hand was understated by $199 due to immaterial reporting errors. 
Part III 

Summary 

Commission Finding 

Filing of Levin Schedules 

A review of Levin activity indicated that TDP received and disbursed Levin funds during 

calendar year 2012 tiiat totaled $150,000 and $137,180, respectively. TDP did not, 

however, disclose this activity on Schedule L (Aggregation Page: Levin Funds), Schedule 

L-A (Itemized Receipts of Levin Funds), or Schedule L-B (Itemized Disbursements of 

Levin Funds). After the Audit staff brought this omission to TDP's attention, TDP filed 

the missing schedules. In response to the Interim Audit Report recommendation, TDP 

stated that its omission of Levin Schedules L on its Post-General report was inadvertent 

and the information for those schedules was entered into its compliance software for 

inclusion on the 2012 Post-General report. However, the data was omitted when the 

report was filed. 

The Commission approved a finding that TDP failed to file Levin Schedules. (For more 

detail, see p. 5.) 
Part IV 

Commission Finding 

I Filing of Levin Schedules 

Summary 

A review of Levin activity indicated that TDP received and disbursed Levin funds during 

calendar year 2012 tiiat totaled $150,000 and $137,180, respectively. TDP did not, 

however, disclose this activity on Schedule L (Aggregation Page: Levin Funds), Schedule 

L-A (Itemized Receipts of Levin Funds), or Schedule L-B (Itemized Disbursements of 

Levin Funds). After the Audit stafFbrought this omission to TDP's attention, TDP filed 

the missing schedules. In response to the Interim Audit Report recommendation, TDP 

stated that its omission of Levin Schedules L on its Post-General report was inadvertent 

and the information for those schedules was entered into its compliance software for 

inclusion on the 2012 Post-General report. However, the data was omitted when the 

report was filed. 

The Commission approved a finding that TDP failed to file Levin Schedules. 

Legal standard 

A. Reporting. 

If a state, district or local party committee's combined annual receipts and disbursements 

for federal election activity (FEA) total $5,000 or more during the calendar year, the 

committee must disclose receipts and disbursements of federal funds and Levin funds 

used for FEA. 11 CFR §300.36(b)(2). 

B. Contents of Levin Reports. Each report must disclose: 

• the amount of cash-on-hand for Levin funds at the begirming and end of the 

reporting period; 

• the total amount of Levin fund receipts for the reporting period and for the 

calendar year; 

• the total amount of Levin fund disbursements (including allocation transfers) for 

the reporting period and the calendar year; and 

• certain transactions that require itemization on Schedule L-A (Itemized Receipts 

of Levin Funds) or Schedule L-B (Itemized Disbursements of Levin Funds) -

itemize receipts and disbursements of $200 or more to or firom any person for 

Federal election activities. 11 CFR §300.36 (b)(2). 

Facts and Analysis 

A. Facts 

The Audit staff reviewed TDP's Levin activity and noted that TDP received $150,000 

and disbursed $137,180 during the 2012 Post-General reporting period (October 18, 2012 
- November 26,2012).^ For this period, the beginning cash balance was $0 and the 

ending cash balance was $12,820. TDP did not, however, file the required Schedules L, 

L-A and L-B until the Audit staff brought the omission to TDP's attention during audit 

fieldwork. A TDP representative acknowledged that TDP did not file the schedules due 

to an error during transmission of the reports required for the reporting period. 

TDP maintained a separate bank account for its Levin fund receipts and disbursements. 

The 2012 Levin fund receipts consisted of transfers firom TDP's non-federal account. 

The 2012 Levin fund disbursements consisted mainly of a transfer to TDP's non-federal 

account and payments for voter identification and get-out-the-vote programs. 

B. Interim Audit Report & Audit Division Recommendation 

The Audit staff discussed this issue with TDP representatives during the exit conference. 

TDP representatives reiterated that TDP did not disclose the Levin fund activity due to an 

oversight and that as soon as the Audit staff notified TDP of this omission, it filed the 

missing Levin Schedules with the Commission. 

The Interim Audit Report recommended that TDP submit any additional information or 

comments it considered relevant to the matter. 

C. Comniittee Response to the Interim Audit Report 

In its response, TDP reiterated that an amended report was filed when the Committee was 

notified of the omission. Furtiier, TDP explained that although the Levin fund data was 

entered into the reporting software for inclusion on the Post-General report, it was 

inadvertently excluded from the report when the report was filed. TDP also noted that 

this was the first time in several years that it had reportable Levin activity which also 

contributed to this oversight. 

D. Draft Final Audit Report 

The Draft Final Audit Report acknowledged that TDP had corrected the public record by 

filing the required Levin Schedules. TDP's response to the Draft Final Audit Report 

provided no additional comments. 

Commission Conclusion 

On May 29, 2014, the Commission considered the Audit Division Recommendation 

Memorandum in which the Audit staff recommended that the Commission adopt a 

finding that TDP failed to file Levin Schedules. 

The Commission approved the Audit staffs recommendation. 

This was TDP's only Levin activity for the period covered by the audit.