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AS3-40

REPORT OF THE AUDIT DIVISION

ON THE

STEVE JOACHIM FOR CONGRESS COMMITTEE

I. Background

A. Over\' iew

This report is based on an audit of the Steve Joachim

For Congress Committee ("the Committee"), undertaken by the Audit

Division of the Federal Election Commission in accordance with

the provisions of the Federal Election Caw~aign Act of 19;1, as

amended ("the Acta). The audit was conducted ?urs~ant to Section

438(b) of Title 2 of the United States Code which states, in

part, that the Commission may conduct audits and field inv~sti9ations of any political committee required to file a

report under section 434 of this title. Prior to conducting any audi~ under this section, the Commission shall 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 co~pliance with the' Act.

The Committee registered with the Clerk of the House of

Representatives on February 9, 1981. The Committee maintains its

headquarters in Bala Cynwyd, Pennsylvania. The audit covered the

period February 5, 1981 through December 31, 1982, the closing

date for the latest report which should have been filed a~ the

time the audit was approved. The Committee reported a cash

balance on February 5, 1981 of $-0-: total receipts of

$316,843.60; total expenditures of $296,044.42: a~d a cash

balance on November 2, 1982 of $20,718.69. 1/

This audit report is based on cocuments and work papers

which support each of its factual statements. They form part of

the record upon which the Commission based its decisions on the

matters in the report and were available to the Commissioners and

appropriate staff for review.

1/ The reported totals do not calculate correctly due to

mathematical errors.
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B. Rev Personnel

The Treasurer of the Committee during the period

covered by the audit was Murray A. Felzer.

C. Scope

The audit included such tests as verification of total

reported receipts a~d expenditures and individual transactions;

review of required supporting documentation; analysis of

Committee debts and obligations; and such other audit procedures

as deemed necessary under the circumstances•

. II. Audit Findings and Recommendations

A. Itemization of Contributions from

?olitical Committees

Section 434(b) (3) (B) of Title 2 of the United States

Code states that each report shall disclose the identification of

each political committee which makes a contribution to the

reporting committee during the reporting period, together with

the date and amount of any such contribution.

During the course of the audit it was noted that the

Committee failed to itemize 36 contributions totaling $21,991.00,

or 13.14% of total contributions from political committees.

The Committee was provided with a schedule of this information•

On September 6, 1983, the Committee filed an amended

report disclosing the above contributions.

Recommendation

The Audit staff recommends no further action on this matter.

B. Failure to Reoort Expenditures

Section 434(b) (4) of Title 2 of the United States Code

states, in part, that each report shall disclose for the

reporting period and the calendar year, the total amount of all

disbursements.

Section 434(b) (5) (A) of Title 2 of the United States

Code states, in part, that each report shall disclose the name

and address of each person to whom an expenditure in an aggregate

amount or value in excess of $200 within the calendar year is

made by the reporting committee together with the date, amount,

and purpose of such operating expenditure.
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In the course of the revie~ of disbursements for the

period January 1, 1982 through November 2, 1982, it was noted

that the Committee failed to report 34 items totaling $48,058.99

or 16.23% of total reported expenditures. The Co~~ittee was

provided with a schedule of this information. The Committee

stated the failute to tepott these expenditutes was caused by oversight.

On September 6, 1983, the Committee filed amendments to

its reports which disclosed the above disbursements as required.

Recommendation

Based on the above, the Audit staff recommends no further

action on this matter.

c. Debts and Obligations

Section 434(b) (2) (8) of Title 2 of the United States

Code states, in part, that each report shall disclose the amount

and nature of outstanding debts and obligations owed by such

political committee; and where such debts or obligations are

settled for less than their reported amount or value, a statement

as to the circumstances under which such debts or obligations

were extinguished and the consideration therefor.

In addition, Section 104.1l(a) and (b) of Title 11 of

the Code of Federal Regulations states, in part, that debts and

obligations owed by a political committee shall be continuously reported until extinguished. These debts and obligations shall

be reported on separate schedules together with a ~tatement

explaining the circumstances and conditions under which each debt

and obligation was incurred or extinguished. Also, a debt,

obligation, or other promise to make an expenditure, the amount

of which is $500 or less, shall be reoorted as of the time

payment is made or no later than 60 days after such obligation is

incurred, whichever comes first. Any loan, debt or obligation, the amount of which is over $500 shall be reoorted as of the time

of the transaction. •

During the audit, it was noted that the Committee

failed to report 20 debts totaling $27,609.92 as of November 2,

1982. These debts were still outstanding as of December 31,

1982. The Committee was provided with a schedule of this

information.

On September 6, 1983, the Committee filed an amended

report disclosing the above debts.

Recommendation

The Audit staff recommends no further action on this matter.
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D. Matters Referred to the Office of General Counsel

Certain matters noted during the audit were referred to

the Commission's Office of General Counsel on October 18, 1983.