Interini Audit Report of the 

Audit Division on 

Kind for Congress Committee 

(January 1, 2013 - December 31, 2014) 

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 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 Campaign (p. 2) 

Kind for Congress Committee is the principal campaign 

TOipmittee for Ronald Kind.'Derhpeil^tic ((^idldafe for th£ Unifbd 

States Houseof Reprjesentativesi.^rn the s^t^of ^iseonsin,^^^= 

Congressional District, and is headquartered in La Crosse, 

Wisconsin. For more information, see the Campaign 

Organization chart, p.2. 

Financial Activity (p. 2) 

• Receipts 

o Contributions from Individuals 

o Contributions from Political 

Committees 

o Offsets to Operating 

Expenditures 

o Other Receipts 

Total Receipts 

• Disbursements 

o Operating Expenditures 

Total Disbursements 

$ 602,932 

1,564,507 

5,001 

1,316 

S 2,173,756 

S 1,180,511 

$ 1,180,511 

Finding and Recommendation (p. 3) 

• Untimely Deposit of Receipts 

52 U.S.C. §30111(b). 
in£e^fiii Atidlt olT 

Audit ijitrision 

fAT Congress Committee 

(January 1, 2013 - December 31, 2014) 
Table of Cohteiits 

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 

Untimely Deposit of Receipts 4 
Part I 

Background 

Authority for Audit 

This report is based on an audit of Kind for Congress Committee (KFCC), 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 S2 U.S.C. §30111 (b), which permits the 

Commission to conduct audits and field investigations of any political committee that is 

required to file a report under 52 U.S.C. §30104. Prior to conducting any audit under this 

subsection, the Conunission 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. 52 U.S.C. §30111(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 and loans; 

2. the receipt of contributions from prohibited sources; 

3. the disclosure of contributions received; 

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

5. the consistency between reported figures and bank records; 

6. the completeness of records; and 

7. other committee operations necessary to the review. 
Part II 

Overview of Campaigh 

Campaign Organization 

Imp.ortant Dates 

• Date of Registration January 30,1996 

• Audit Coverage January 1,2013 - December 31,2014 

Headquarters La Crosse, WI 

Bank Information 

• Bank Depositories Seven 

• Bank Accounts One pheeking, Sixsavings 

Treasurer 

'• Treasurer When Audit Was Conducted Brent Smith (February 10,2016 - present) 

Charles Marx (January 30,2009 -

February 9,2016) 

• Treasurer. During- Period Covered by Audit Charles Marx 

Management Information 

• Attended Commission Campaign Finance 

Seminar 

No 

• Who Handled Accounting and 

Recordkeeping T asks 

Paid Staff 

Overview of Financial Activity 

(Audited Amounts) 

Cash-on-hand ^January 1,2013 S 458,874 

Receipts. 

o Contributions from Individuals 602,932 

o Contributions from Political Committees 1,564,507 

o Offsets to Operating Expenditures. 5,001 

o Other Receipts 1.316 

Total Receipts S 2,173.756 

Disbursements 

o Operating Expenditures 1.18Qi511 

Total Disbursements $l,180i511 

Cash-on-hand ^ December 31,2014 $1,4^,119 
Part HI 

Pl&lling and Reco;tnia«siiati(m 

Untimely Deposit of Receipts 

During audit fieidwork, a review of contributions from political committees determined 

that KFCC failed to deposit, within 10 days of receipt, contributions totaling $581,719 

received during the 2014 election cycle. The Audit staff recommends that KFCC provide 

evidence demonstrating that the contributions in question were deposited timely or 

submit any comments it. deems relevant to this matter. (For more detail, see p. 4.) 
Part IV 

Finding and Rec9in:nien4atidti 

Untimely Deposit of Receipts 

Summary 

During audit fieldwork, a review of contributions from political committees determined 

that KFCC failed to deposit, within 10 days of receipt, contributions totaling $581,719 

received during the 2014 election cycle. The Audit staff recommends that KFCC provide 

evidence demonstrating that the contributions in question were deposited timely or 

submit any comments it deems relevant to tbis matter. 

Legal Standard 

Timing of Deposits. A treasurer of a political committee is responsible for making 

deposits of contributions. These deposits must be made within 10 days of the receipt of 

the contribution. 11 CFR § 103.3(a). 

Receipt of Contributions. Every person who receives a contribution in excess of $50 

for a political committee which is an authorized committee shall, no later than 10 days 

after receipt of the contribution, forward to the treasurer of the committee: The 

contribution, the name and address of the contributor; and the date of receipt of the 

contribution. If the arnount of the contribution is in excess of $200, such person shall 

forward the contribution, the identification of the contributor in accordance with 11 CFR 

100.12, and the date of receipt of the contribution. Date of receipt shall be the date such 

person obtains possession of the contribution. 52 U.S.C. §30102(b)(1) and 11 CFR 

§ 102.8(a). 

Facts and Analysis 

A. Facts 

During audit Heldwork, the Audit staff utilized a combination of sample testing and 

focused reviews to identify untimely deposit of contributions received from political 

committees. The sample testing and focused reviews identified untimely deposit errors 

totaling $581,719.^ This amount represents approximately 37% of all contributions from 

political committees. On average, the time between receipt and deposit of these 

contributions was 26 days, ranging from 14 to 100 days. 

During this review, the Audit staff inquired about the receipt date utilized by KFCC in its 

disclosure reports. A KFCC representative responsible for the daily input of its 

contributions informed the Audit staff, on more than one occasion, that the receipt date 

* The sample enor amount was projected using a Monetary Unit Sample with a 9S percent confidence level 

plus the result of a focused review of contributions not included in the sample population. The sample 

estimate could be as low as S492,04S and as high as S62S,394. 
reported in its FEC disclosure filings was the date the contribution was received by 

KFCC. Based on this affirmation, the Audit staff used the date of receipt provided in 

KFCC's receipts database (which also was the date of receipt in its FEC disclosure 

reports) to determine the number of days until deposit. 

However, because KFCC representatives later expressed some uncertainty about the 

actual dates of receipt (see discussion below), the Audit staff revised its calculation and 

used the date. of the=contributor check plus three days for mailing.as the date of receipt in 

determining the number of days from fecdipt 'bf the bonfrihutor cheek to its deposit. 

B. Interim Audit Report & Audit Division Recommendation 

The Audit staff discussed this matter with KFCC representatives during the exit 

conference at the conclusion of fieldwork, and provided work papers detailing the 

untimely deposited contributions. The representatives stated that the contributions from 

political committees, were received by a representative .in A^ashjpgtpn, D.C. and mailed to 

their Wisconsin office for dCpipsit.* According tp the reprisentetives, the mail delivery 

from Washington, D.C. to its office in Wisconsin sometimes took up to 10 days. As a 

result, KFCC was not able to timely deposit these contributions. Furthermore, the 

representatives stated that they were uncertain of the actual date of receipt of these 

contributions and they questioned whether it should be the date the contributions were 

received in Washington, D.C. or La Crosse, Wisconsin. They added that, in the future, 

they would look at various ways to ensure its contributions would be timely deposited, 

llie Audit staff suggested that the representative in Washington, D.C. make the deposits 

since KFCC utilized a national bank with many locations within the city. Then, the 

representative could email a list of the contributions to KFCC for reporting purposes, etc; 

The Audit staff also suggested the use of express shipping to reduce the mail delivery 

time to Wisconsin. The representatives said they would consider these options. No 

additional information was provided in KFCC's response to the exit conference. 

In accordance with 11 CFR § 102.8(a), the date of receipt is the day the KFCC 

representative in Washington, D.C. obtains possession of the contribution. Therefore, 

KFCC must ensure that its deposit is made within 10 days of receiving the contribution in 

Washington, D.C. to comply with the requirements of 11 CFR §103.3(a). 

The Audit staff recommends that, within 30 calendar days of service of this report, KFCC 

provide evidence demonstrating that the contributions in question were deposited timely 

or submit any additional comments relevant to this matter. 

^ This method of determining a receipt date is utilized by the Audit staff when the actual receipt date is 

unknown. There was a minor decrease in the error total using this method. 

* Contributions from individuals were usually mailed directly to the KFCC office in Lacrosse, Wl.