FEDERAL ELECTION COMMISSION 

WASHINGTON, D.C. 20463 

March 11,2015 

MEMORANDUM 

To: 

Through: 

From: 

The Commission 

Alec Palmer 

Staff Director 

Patricia C. Orrock 

Chief Compliance Officer 

Thomas E. Hintermistei^>!s. 

Assistant Staff Director 

Audit Division 

RickidaMorcomb 

Audit Manager 

Marty Favin 

Audit Manager 

By: 

Subject: 

Michelle Grant 

Lead Auditor 

Audit Division Recommendation Memorandum on Amodei for Nevada 

(AFN) (A13-03) 

Pursuant to Commission Directive No. 70 (FEC Directive on Processing Audit Reports), 

the Audit staff presents its recommendation below and discusses the finding in the 

attached Draft Final Audit Report (DFAR). The Office of General Counsel has reviewed 

this memorandum and concurs with the recommendation. 

Misstatement of Financial Activity 

In response to the Interim Audit Report, AFN filed an amendment that materially 

complied with the recommendation. AFN did not file an additional response to the 

DFAR. 

The Audit staff recommends that the Commission find that AFN misstated their 

financial activity for calendar year 2012. 

AFN did not request an audit hearing. 
If this memorandum is approved, a Proposed Final Audit Report will be prepared within 

30 days of the Commission's vote. 

In case of an objection, Directive No. 70 states that the Audit Division Reconunendation 

Memorandum will be placed on the next regularly scheduled open session agenda. 

Documents related to this audit report can be viewed in the Voting Ballot Matters folder. 

Should you have any questions, please contact Michelle Grant or Rickida Morcomb at 

694-1200. 

Attachment: 

- Draft Final Audit Report of the Audit Division on Amodei for Nevada 

cc: Office of General Counsel 
Draft Final Audit Report 

of the Audit Division on 

Amodei for Nevada 

(May 11, 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' 

(the Act). The 

Commission generally 

conducts such audits 

when a committee 

appears not to have met 

the threshold 

requirements for ^ 

substantial conriplianc<ii;|jo^ 

with the Act.^ The audit . . 

determine^ys^hi^Egie 

commits complied^sy^ 

the lin^ions, '^^1;, 

prohibifidi^,and 

disclosure i^uirements 

of the Act. t 

Future Actibii|#--'' 

The Commission may' 

initiate an enforcement 

action, at a later time, 

with respect to the matter 

discussed in this report. 

About the Campaign (p,;2) 

Amodei for Nevada is the prin^u Campaign committee for 

Mark Amodei, Republican 

Representatives from the 

he^quartered in 

see the Campaign 

Financial' 

• Receipts 

o^,. Contributioi • 

ibutions 

for the US House of 

ada, 2nd District, and is 

For more information. 

.:?• 

o Tf^ferSf^QAer 

CofitoiW^s 

o Offs^0o Operad^ 

Expen%ures 

ithorized 

iting Expenditures 

Jransfers to Other Authorized 

P'" Committees 

d Contribution Refunds 

o Other Disbursements 

Total Disbursements 

$ 612,917 

693,646 

956 

4,039 

S 1,311,558 

$ 1,122,607 

4,500 

2,350 

1,250 

S 1,130,707 

Finding and Recommendation (p. 3) 

• Misstatement of Financial Activity 

On September 1,2014, the Federal Election Campaign Act of 1971, as amended ("the Act"), was 

transferred from Title 2 of the United States Code to new Title 52 of the United States Code. 

52 U.S.C §30111(b) (Formerly 2 U.S.C. §438(b)). 
Draft Final Audit Report 

of the Audit Division on 

Amodei for Nevada 

(May 11, 2011 - December 31, 2012) 

m /=• 
Table of Contents 

Page 

Part I. Background 

Authority for Audit 

Scope of Audit 

Part II. Overview of Campaign 

Campaign Organization 

Overview of Financial Activity 

Part III. Summary 

Finding and Recommendation 

Mk 

Part IV. Finding and Recomnie1^|Ltioilv 

Misstatement of Financial Activity 

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I 
Part I 

Background 

Authority for Audit 

This report is based on an audit of Amodei for Nevada (AFN), 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) (formerly 2 U.S.C. §438(b)), which 

permits the Commission to conduct audits and field investigatioi^i^ any political 

committee that is required to file a report under 52 U.S.C. (fb'nnerly 2 U.S.C. 

§434). Prior to conducting any audit under this subsection,^i|^mmission must 

perform an internal review of reports filed by selected cq^iitt'^^^. determine if the 

reports filed by a particular committee meet the thres||^i^^^quire^^^, for substantial 

compliance with the Act. 52 U.S.C. §30111(b) (fq 

Scope of Audit •fFollowing Commission-approved procedures, the Ai^t.§m evaluated various risk 

factors and as a result, this audit examined: 

1. the receipt of excessive contributiqi^.;. " 

2. the receipt of contributions from prqhiiij^ sources; 'Hf. . ... 

3. the disclosure of contributions receii^d; p'' 

4. the disclosure of individual contributors' occtiL^tioh^(d .da^ of employer; 

5. the consistency betiyj^lj^ported figure^.j^a Wk ire^drds; 

6. the completeness ,qf rec6riil|^;^^ % 

7. other campaign b^i^ations nl^essary to the'i^view. 

-fr-
Part II 

Overview of Campaign 

Campaign Organization 

Important Dates 

• Date of Registration May 9.2011 

• Audit Coverage May 11.201 U^lDecember 31,2012 

Headquarters Carson City^^^SlMa 

Bank Information 

• Bank Depositories One,vji5j^. •••• 

• Bank Accounts Qn^- -m. 

Treasurer 

• Treasurer When Audit Was Conducted Nigibfe,Neil^ii\.. ..?'• 

• Treasurer During Period Covered by Audit Nicol^'i^qiion 

Management Information 

• Attended Commission Campaign Fina^|b|i'i;f^. 

Seminar % 

Vo 

• Who Handled Accounting and \ 

Recordkeeping Tasks 

Oirli^ew of Fini 

V, 

I." '•'.•.•'•'s'l .•••rf.'X • 

^^ial Activity 

imounts) 

Cash-on'-Iiand ® May 11,2(111 $0 

Receipts 

o Contributions &om IndividiMs 612,917 

o Contributions from .Politiceyi;iCommittees 693,646 

o Transfers from OtheriAuthorized Committees 956 

o Offsets to Operating Expenditures 4,039 

Total Receipts S 1,311,558 

Disbursements 

o Operating Expenditures 1,122,607 

o Transfers to Other Authorized Committees 4.500 

o Contribution Refunds 2,350 

o Other Disbursements 1,250 

Total Disbursements S 1,130,707 

Cash-on-hand @ December 31,2012 S 180,851 
Part III 

Summary 

Finding and Recommendation 

Misstatement of Financial Activity 

During audit fieldwork, a comparison of AFN's reported financial activity with its bank 

records revealed a misstatement of ending cash-on-hand in overstated ending 

cash-on-hand by $7,700. In response to the Interim Audit Re^Sn recommendation, AFN 

amended its most recently filed disclosure report to correcyhiii^statement. 

(For more detail, see p. 4.) 

• V V 

ri,: Is 

m i 

w 

1 
Part IV 

Finding and Recommendation 

Misstatement of Financial Activity 

Summary 

During audit fieldwork, a comparison of AFN's reported financial .^tivity with its bank 

records revealed a misstatement of ending cash-on-hand in 201^^^^ overstated ending 

cash-on-hand by $7,700. In response to the Interim Audit recommendation, AFN 

amended its most recently filed disclosure report to corre^;|!md|i^.sistatement. 

Legal Standard \ 

Contents of Reports. Each report must displ^se: ' 

• The amount of cash-on-hand at the beginiiii||;^d end of the reportin|^.j^Qd', 

• The total amount of receipts for the reporting';^pd anli-^r the election^cle ; and 

• The total amount of disbursements for the repo^h^pdiiod wd for the election cycle; 

52 U.S.C. §30104(b)(l), (2). and M) (formerly 2§434(b)(l), (2), and (4)). 

Facts and Analysis 

A. Facts 

% 

% 

I?" 

During audit fieldwork,;tKg:Aft0t staff recohgiled AFN'^i'teported financial activity with 

its bank records for i^endar 

cash-on-hand balari6d|i^012 

the ending cash-on-hand^ 

im Audit 

the exit 

misstatement..';-:... 

nee and p: 

2011 and 1^12. This review indicated that the ending 

overstated %:.|!.7.700. The $7,700 overstatement of 

:0,12 resultia primarily from unreported 

|vision Recommendation 

ent for 2012 with AFN's representative during 

lies of relevant work papers detailing the 

The Interim Audit Ifeporf iiecommended that AFN amend its most recently filed 

disclosure report to cj^rfect the cash-on-hand balance with an explanation that the change 

resulted from a prior period adjustment. Further, it was recommended that AFN 

reconcile the ending cash-on-hand balance of its most recent report to identify any 

subsequent discrepancies that may affect the cash-on-hand balance. 

C. Committee Response to Interim Audit Report 

In response to the Interim Audit Report recommendation, AFN amended its most recently 

filed disclosure report. This amended report corrected the misstated cash-on-hand 

balance.