Final Audit Report of the 

Commission on tlie 

Tennessee Democratic Party 

January 1, 2005 - December 31, 2006 

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 direshold 

requirements for substantial 

compliance with the Act.^ 

The audit determines 

whether the committee 

complied with the 

limitations, prohibitions and 

disclosure requirements of 

die Act. 

Future Action 

The Commission may 

initiate an enforcement 

action, at a later time, with 

respect to any of the 

matters 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 Committee Organization chart on p. 2. 

Financial Activity (p. 2) 

• Federal Receipts 

o Contributions from Individuals 

o Contributions from Other Political 

Committees 

o Transfers from Affiliated Party Committees 

o Transfers from Non-federal and Levin Funds 

o Other Receipts 

Total Federal Receipts 

• Federal Disbursements 

o Operating Disbursements 

o Transfers to Affiliated Committees 

o Independent Expenditures 

o Coordinated Party Expenditures 

o Federal Election Activity 

o Other Federal Disbursements 

Total Federal Disbursements 

• Levin Receipts 

• Levin Disbursements 

$ 1,771,653 

234,775 

3,022,463 

797,430 

48,176 

$5,874,497 

$1,691,580 

211,950 

912,496 

712,459 

2,237,958 

160,981 

$5,927,424 

$319,869 

$319,869 

Commission Findings (p. 3) 

• Non-allocable Federal Election Activity Disclosed on 

Schedule H6 (Finding 1) 

• Disclosure of Disbursements (Finding 2) 

2U.S.C. §438(b). 
Final Audit Report of the 

Commission on the 

Tennessee Democratic Party 

January 1, 2005 - December 31, 2006 
Table of Contents 

Page 

Parti. Background 

Authority for Audit 1 

Scope of Audit 1 

Audit Hearing I 

Part II. Overview of Committee 

Committee Organization 2 

Overview of Financial Activity 2 

Part III. Summaries 

Commission Findings 3 

Part IV. Commission Findings 

Finding 1. Non-allocable Federal Election Activity Disclosed on 

Schedule H6 4 

Finding 2. Disclosure of Disbursements 11 
Parti 

Background 

Authority for Audit 

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

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

widi 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 

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 disbursements, debts and obligations. 

5. The disclosure of expenses allocated between federal, non-federal, and Levin 

accounts. 

6. The consistency between reported figures and bank records. 

7. The completeness of records. 

8. Other committee operations necessary to the review. 

Audit Hearing 

TDP requested a hearing before the Conunission. The request was granted and the 

hearing was held on November 4,2009. At the hearing, TDP only addressed issues 

relating to polls and campaign rallies. 
Part II 

Overview of Committee 

Committee Organization 

Important Dates 

• Date of Registration May 18,1983 

• Audit Coverage January 1,2005 - December 31,2006 

Headquarters Nashville, Tennessee 

Bank Information 

• Bank Depositories Two 

• Bank Accounts Seven Federal, Three non-Federal, One 

Levin 

Treasurer 

• Treasurer When Audit Was Conducted Chip Forrester 

• Treasurer During Period Covered by Audit Robert Tuke & Delainia Davis 

Management Information 

• Attended FEC Campaign Finance Seminar Yes 

• Who Handled Accounting and Recordkeeping 

Tasks 

Paid Staff 

Overview of Financial Activity 

(Audited Amounts) 

Federal Cash on hand @ January 1,2005 $128,779 

o Contributions from Individuals $1,771,653 

o Contributions from Other Political Committees 234,775 

0 Transfers from Affiliated Party Committees 3,022,463 

o Transfers from Non-federal and Levin Funds 797,430 

0 Other Receipts 48,176 

Total Federal Receipts $5,874,497 

o Operating Disbursements $1,691,580 

o Transfers to Affiliated Committees 211.950 

o Independent Expenditures 912.496 

o Coordinated Party Expenditures 712.459 

o Federal Election Activity 2,237.958 

o Other Federal Disbursements 160.981 

Total Federal Disbursements $5,927,424 

Federal Cash on hand @ December 31,2006 $75,852 

Levin Cash on hand @ September 26,2006 $0 

Total Levin Receipts $319,869 

Total Levin Disbursements $319,869 

Levin Cash on hand @ December 31,2006 $0 
Part III 

Summaries 

Commission Findings 

Finding 1. Non-allocable Federal Biection Activity 

Disclosed on Schedule H6 

During audit fieldwork, a review of disbursements identified what appeared to be nonallocable federal election activity that was reported on Schedule H6 (Disbursements of 

Federal and Levin Funds for Allocated Federal Election Activity). Payments, totaling 

$98,321—for polls ($24,500), automated phone banks ($36,400), and campaign rallies 

($37,421, including $900 for custom-labeled botded water)—were reportedly allocated 

21% federal and 79% Levin. However, the telephone scripts for the automated phone 

banks referred to a clearly identified candidate running for federal office, as did 

documentation associated with the other programs. In response to the Interim Audit 

Report, TDP agreed that the automated phone banks were not allocable federal election 

activity, but maintained that the rallies were correcdy classified. TDP also amended its 

reports to reflect the cost of the polls as allocable operating costs. In addition to its 

response to the Interim Audit Report and the Draft Final Audit Report, TDP was granted 

a hearing for Commission consideration of the issues. 

The Commission: 

• approved the finding of the Audit Division with respect to automated phone banks 

and custom-labeled water botdes; 

• concluded that the cost of the polls were properly reported on Schedule H4 

(Disbursements for Allocated Federal/Nonfederal Activity) as shared operating 

expenditures as TDP had done in response to the Interim Audit Report; and, 

• concluded that, with the exception of the invoice for custom-labeled bottled water 

that identified a specific federal candidate, there was insufficient evidence 

regarding the rallies to determine that they were not allocable federal election 

activity. (For more detail, see p. 4) 

Finding 2. Disclosure of Disbursements 

During audit fieldwork, a sample review of itemized expenditures revealed that for 

approximately 18% of the items tested, TDP did not disclose the payee's address. In 

response to the Interim Audit Report, TDP filed amended reports that materially 

disclosed the missing information. The Commission approved this finding. (For more 

detail, seep. 11) 
Part IV 

Commission Findings 

Finding 1. Non-allocable Federal Election Activity 

Disclosed on Schedule H6 

Summaiy 

During audit fieldwork, a review of disbursements identified what appeared to be nonallocable federal election activity that was reported on Schedule H6 (Disbursements of 

Federal and Levin Funds for Allocated Federal Election Activity). Payments, totaling 

$98,321—for polls ($24,500), automated phone banks ($36,400), and campaign rallies 

($37,421, including $900 for custom-labeled bottied water)—were reportedly allocated 

21% federal and 79% Levin. However, the telephone scripts for the automated phone 

banks referred to a clearly identified candidate running for federal office, as did 

documentation associated with the other programs. In response to the Interim Audit 

Report, TDP agreed that the automated phone banks were not allocable federal election 

activity, but maintained that the rallies were correctly classified. TDP also amended its 

reports to reflect the cost of the polls as allocable operating costs. In addition to its 

response to the Interim Audit Report and the Draft Final Audit Report, TDP was granted 

a hearing for Conunission consideration of the issues. 

The Commission: 

• approved the finding of the Audit Division with respect to automated phone banks 

and custom-labeled water bottles; 

• concluded that the costs of the polls were properly reported on Schedule H4 

(Disbursements for Allocated Federal/Nonfederal Activity) as shared operating 

expenditures as TDP had done in response to the Interim Audit Report; and 

• concluded that, with the exception of the invoice for custom-labeled bottled water 

that identified a specific federal candidate, there was insufficient evidence 

regarding the rallies to determine that they were not allocable federal election 

activity. 

Legal Standard 

A. Categories of Allocable Federal Election Activity. A State, district, or local 

political party committee may allocate disbursements between Federal funds and 

Levin funds for: 

• Voter Registration Activity; 

• Voter Identification; 

• Get-Out-The-Vote Activity; and 

• Generic Campaign Activity. 11 CFR §300.33(a)(l) and (2). 

B. Categories of Non-Allocable Federal Election Activity. Costs incurred by State, 

district, and local party committees and organizations for public communications that 

refer to a clearly identified candidate for federal office and that promote, attack. 
support or oppose any such candidate for federal office must be paid only with federal 

funds. llCFR§300.33(c). 

C. Coordinated Party Expenditures. National party committees and state party 

committees are permitted to purchase goods and services on behalf of candidates in 

the general election, over and above the contributions that are subject to contribution 

limits. Such purchases are referred to as "coordinated party expenditures." They are 

subject to the following rules: 

• The amount spent on "coordinated party expenditures" is limited by statutory 

formulas that are based on a Cost of Living Adjustment and the voting age 

population. 

• Party conunittees are permitted to coordinate the spending with the candidate 

committees. 

• The parties may make these expenditures only in connection with the general 

election. 

• The party committees—^not the candidates—are responsible for reporting these 

expenditures. 

• If the party conunittee exceeds the limits on coordinated party expenditures, the 

excess amount is considered an in-kind contribution, subject to the contribution 

limits. 

• A national or state party committee may assign all or part of its coordinated party 

spending authority to another party conunittee. 2 U.S.C. §441a(d) and 11 CFR 

§§ 109.32(b) and 109.33(a) and (b). 

Facts and Analysis 

A. Automated Phone Banks 

1. Facts 

TDP paid $36,400 for two automated phone bank programs. The phone scripts for 

both programs refer to a clearly identified candidate running for federal office. The 

reported Levin share of this expense was $28,756 ($36,400 x 79%). 

The fu:st phone script was narrated by the Govemor of Tennessee (Govemor Script), 

who was running for re-election. He asked for "your support and your vote." He also 

asked that "you support Harold Ford, Jr.," and continued to speak on his behalf He 

closed by stating, "vote for me, Harold Ford, Jr., and all of our great democratic 

candidates running for election." The script concluded with a second speaker stating, 

"paid for by the Tennessee Democratic Party" and "approved and authorized by 

Harold Ford, Jr. for Tennessee." The cost of die program was $18,900. 

The second phone bank script was narrated by former president Bill Clinton (Clinton 

Script). He asked that "everyone go to die polls and take someone with you who 

hasn't voted." He also stated that 'Tennessee has an historic chance to send Harold 

Ford, Jr. to the United States Senate," and continued talking on his behalf He ended 

by telling "everyone to go to the polls and vote." The script concluded with a second 
speaker stating, "paid for by the Tennessee Democratic Party" and "approved and 

authorized by Harold Ford, Jr. for Tennessee." The cost of die program was $17,500. 

The contracts for each phone bank program were signed by Jim Hester, representing 

TDP, Hester's email addresses at both TDP and at the candidate's campaign 

headquarters were listed on one of the contracts, and prior to the date of each contract 

Mr. Hester was employed by the Ford Conunittee. 

2. Interim Audit Report & Audit Division Recommendation 

In the Interim Audit Report, the Audit staff questioned whether the cost of phone 

banks whose scripts referred to a clearly identified candidate running for federal 

office could be allocable federal election activity. The Audit staff also questioned 

whether the automated phone program was coordinated with Harold Ford, Jr. for 

Tennessee (the "Ford Committee"), because: (1) each script concluded with the 

statement that the call was paid for by the Tennessee Democratic Party, and approved 

and authorized by Harold Ford, Jr. for Tennessee, and (2) Mr. Hester's involvement. 

As coordinated expenditures, the Audit staff allocated the cost of the Govemor Script 

among candidates as follows: one-third Govemor, one-third Harold Ford, Jr., and 

one-third to all other (unnamed) candidates running for election. On that basis, 

$6,300 ($18,900 X 33%) would represent a coordinated expenditiure on behalf of 

Harold Ford, Jr. Further, since Harold Ford, Jr. is the only candidate named in the 

Clinton Script, the entire cost ($17,500) would represent a coordinated expenditure on 

behalf of Harold Ford, Jr. 

In 2006, TDP's coordinated expenditure limit for a United State Senate candidate was 

$362,200. The national party conunittee had the same limit, which was assigned to 

TDP. Therefore, TDP could make coordinated expenditures on behalf of Harold 

Ford, Jr. in die amount of $724,400. 

TDP reported on Schedule F (Itemized Coordinated Party Expenditures) coordinated 

party expenditures on behalf of Harold Ford, Jr. totaling $712,459. Widi the addition 

of die cost of die automated phone bank ($23,800 [$6,300 + $17,500]) and bottled 

water (See section C. Campaign Rallies) $900,^ it appeared that TDP exceeded die 

limitation by $12,759 ($737,159 - $724,400). 

This matter was discussed at the exit conference. TDP's response to the exit 

conference did not address automated phone banks. 

The Audit staff recommended diat TDP demonstrate that die automated phone banks 

represent federal election activity, or file amended reports disclosing the expenditures 

as coordinated party expenditures on behalf of Harold Ford, Jr. 

2 TDP also agreed that the cost of bottled water labeled Ford for Tennessee represented a coordinated party 

expenditure. 
3. Committee Response to Interim Audit Report 

In response. Counsel for TDP (Counsel) acknowledged that the automated phone 

calls included advocacy for a Federal candidate and should not have been disclosed 

on Schedule H6. Accordingly, TDP filed amended reports to disclose 50% of die cost 

of die Govemor Script on Schedule B.($9,450) and 50% on Schedule F (Itemized 

Coordinated Party Expenditures). The entire cost of the Clinton Script was disclosed 

on Schedule F. 

4. Draft Final Audit Report 

The Audit staff and Counsel agreed that the expenditures were coordinated and 

reportable on Schedule F, although TDP has concluded that 50% of the cost of die 

Govemor's Script represented coordinated spending, whereas, the Audit staff 

concluded a lesser percentage (33%). TDP's allocation was acceptable. 

The normal remedy would have been for the Ford Committee to reimburse TDP 

$12,759. However, since the Ford Committee transferred $154,000 in excess 

campaign funds to TDP on November 6,2006, the Audit staff considered this matter 

to have been timely resolved. 

The Audit staff reconunended that the Conunission adopt the finding that TDP 

misreported expenditures for the automated phone banks and bottled water as 

allocable federal activity, rather than coordinated expenditures. Accordingly, the 

Audit staff reconunended that the Commission further adopt the finding that these 

expenses resulted in TDP exceeding its coordinated party expenditure limit by 

$12,759. However, as a result of a prior transfer from the Ford Committee to TDP, 

the Audit staff reconunended that the Conmiission also adopt the finding that TDP is 

not required to take further corrective action with regards to these expenditures. 

Commission Conclusion 

The Commission approved the finding of the Audit Division with respect to automated 

phone banks and custom-labeled botded water. 

B. Polls 

1. Facts 

TDP paid $24,500 for two statewide tracking polls conducted during the period 

October 14, 2006, dirough October 28,2006. TDP reported allocating diese costs as 

21% federal and 79% Levin. The reported Levm share of this expense was $19,355 

($24,500 X 79%). 

The poll program consisted of telephone interviews of 1,200 likely voters in October 

2006. Poll questions related to candidates running for election to the United States 

Senate and candidates for Govemor of Tennessee. Among the questions asked of 

callers were: if they favored either of the federal candidates; whether they would vote 

for a certain federsd candidate if the election were held that day; their opinion of 

attack ads against one of the federal candidates; and, their opinions of various 

positions of each federal candidate. 
8 

2. Interim Audit Report & Audit Division Recommendation 

The proper classification of the polling expenses was discussed at the exit conference. 

TDP's response to the exit conference did not address the polls. 

In the Interim Audit Report, the Audit staff questioned whether TDP's expenditures 

for these polls should have been made entirely from the Federal account rather than 

being reported as allocable federal election activity. 

The Interim Audit Report reconunended that TDP demonstrate that each payment 

represented allocable federal election activity or file amended reports properly 

disclosing the payments. 

3. Committee Response to Interim Audit Report 

In response. Counsel acknowledged that the cost of the polls should not have been 

reported on Schedule H6 but indicated this cost should have been reported on 

Schedule H4 as a shared operating expenditure. Counsel further stated that, the 

tracking polls were conducted to get a sense of issues and voting trends based on 

general polling principles; the polls did not promote, support, attack or oppose any 

federal candidate; the polls did not constitute generic campaign activity; the polls did 

not constitute voter registration activity; the polls did not constitute get-out-the-vote 

activity; and, most importandy, the polls did not constitute voter identification 

activity. 

TDP amended its reports to refiect the cost of the polls on Schedule H4; allocating 

$5,145 (21%) to die federal account and $19,355 (79%) to die non-federal account. 

4. Draft Final Audit Report 

In the Draft Final Audit Report, it remained the opinion of the Audit staff that the cost 

of the polls represented federal election activity that should have been paid solely by 

the federal account and not allocated as a shared activity. The Audit staff reasoned 

that the telephone interviews of 1,200 likely voters occurred within the FEA time 

frame, and represented a public communication that referred to clearly indentified 

candidates for federal office that promoted, attacked, supported or opposed the 

candidates. 

5. Audit Hearing 

TDP requested a hearing before die Conunission. The request was granted and the 

hearing was held on November 4,2009. Counsel stated that no information obtained 

from the polls was posted to the party's voter files and that a legitimate survey poll 

with a limited number of respondents should not be considered a public 

communication and, therefore, federal election activity. Counsel stated that the 

purpose of these surveys was to test messages for future activities, not to persuade 

those contacted. He noted that contacting such small numbers of persons using an 

extensive list of questions is not an effective way to persuade voters. 

Commission Conclusion 

On April 29, 2010, the Commission considered the Audit staffs recommendation that the 

Conunission adopt the finding that the cost of the polls represented federal election 
activity and should have been disclosed on Schedule B, Line 21b as Other Federal 

Operating Expenditures. 

The Conunission concluded that the cost of the polls were properly reported on Schedule 

H4 as shared operating expenditures as TDP had done in response to the Interim Audit 

Report. Three Commissioners reasoned that legitimate survey polls do not constitute 

general public political advertising and, therefore, are not public communications. Three 

Commissioners reasoned that polls diat test both positive and negative messages about 

die same candidate neither "promote" nor "support" nor "attack" nor "oppose" that 

candidate for die purposes of 2 U.S.C. 431(20)(A)(iii) (the definition of public 

communications that are federal election activity). Since the polls are not federal election 

activity in the view of these Conunissioners, the polls cannot be non-allocable federal 

election activity under 2 U.S.C. 441i(b)(l) and 11 CFR 300.33(c). 

C. Campaign Rallies 

1. Facts 

TDP reported as get-out-the-vote activity on Schedule H6 payments for 12 invoices 

totaling $37,421 for campaign rallies. 

The mvoices were dated in October 2006, and were for items such as tents, staging, 

refreshments, audio, parking, and clean-up. The 12 invoices referenced the Harold 

Ford campaign. For example, die invoices denoted, "Bill to Harold Ford Jr." or 

"Prepared for Harold Ford for Senate Campaign" or "Sold to Harold Ford Jr. 

Campaign." One invoice described the event name as a "Political Rally for Harold 

Ford, Jr." Among diese invoices is the $900 mvoice for custom-labeled bottled water 

discussed above - the label read "Ford for Tennessee Bottied Water." 

2. Interim Audit Report & Audit Division Recommendation 

At the exit conference, the Audit staff questioned whedier die payments were for getout-the-vote activity because the rallies appeared to benefit Harold Ford, Jr. The 

Audit staff noted that the invoices contained notations indicating that they were 

eidier, billed to, prepared for, or sold to the Ford Committee, and appeared to 

represent expenditures for Ford Conunittee rallies. TDP representatives received 

copies of the documentation in order to further review the issues. 

In response to the exit conference, TDP submitted a signed statement from the former 

director of Tennessee Victory 2006 (Randy Button) diat addressed four campaign 

rally invoices, totaling $17,401. Widi respect to each, he stated Tennessee Victory 

2006 expenditures were incorrectiy invoiced to the Harold Ford Jr. campaign, the 

expenditures were related to get-out-the-vote activities, the activities were not 

planned or conducted m coordination with any federal candidate, and no federal 

candidate attended these events. 

In die Interim Audit Report, die Audit staff analyzed these disbursements as 

coordinated party expenditures on behalf of Harold Ford, Jr. 
10 

The Interim Audit Report recommended that TDP demonstrate that expenditures for 

campaign rallies represented allocable federal election activity and not coordinated 

party expenditures on behalf of Harold Ford, Jr. 

3. Committee Response to Interim Audit Report 

In response. Counsel stated that TDP believed the invoices represented generic 

campaign activity, that it was not uncommon for vendors to confuse a party 

organization with the campaign of a candidate, and that the invoices were incorrectiy 

sent to the Harold Ford campaign. The response also included a second declaration 

from the Director of Teimessee Victory 2006, a project of the Tennessee Democratic 

Party. He stated that of the twelve invoices, eleven were incorrectly invoiced to the 

Harold Ford campaign. TDP agreed that the remaining invoice for custom-labeled 

bottled water was a coordinated expenditure and amended its reports to disclose this 

expense on Schedule F. 

4. Draft Final Audit Report 

After considering TDP's response, die Audit staff, based on the review of the 

invoices, did not accept that the vendors mistakenly invoiced the Ford Conunittee 

(instead of the TDP). The Audit staff, dierefore, maintamed diat the payments for 

these events represented coordinated party expenditures. 

5. Audit Hearing 

TDP requested a hearing before the Conunission. The request was granted and the 

hearing was held on November 4,2009. At the hearing. Counsel reiterated that it is 

TDP's belief that all but one of the 12 invoices identified by the Audit staff 

erroneously identified the Ford campaign as having been involved in the transactions 

and argued that such mistakes are common. The invoices from the 11 vendors 

represent at least 5 separate events. 

Counsel also objected to what he termed the cursory dismissal of Teimessee Victory 

2006 Du:ector's representations conceming the rallies. The Declaration of Teimessee 

Victory 2006's former director Randy Button generally explained his belief that the 

invoices were incorrectly invoiced to the Ford campaign. Mr. Button stated that in 

his experience it is common for vendors to make such mistakes, but did not indicate 

his personal knowledge conceming any of the activities that occurred at the events, if 

any of the materials displayed at the event mentioned Mr. Ford's campaign, or 

whether Mr. Ford was mentioned at the events. Counsel was unable to provide any 

further information at the hearing. 

Commission Conclusion 

On April 29,2010, the Commission considered the Audit staff's recommendation that the 

Conunission adopt the finding that the cost of the campaign rallies represented 

coordinated party expenditures and should have been disclosed on Schedule F as 

Itemized Coordmated Party Expenditures made on behalf of candidates for federal office. 

The Commission concluded that, with the exception of custom-labeled bottied water that 

identified a specific federal candidate, there was insufficient evidence regarding the 
11 

rallies to determine whether or not they were allocable federal election activity. The 

Conmiission concluded diat TDP is not required to take corrective action widi respect to 

diis issue. 

Finding 2. Disclosure of Disbursements 

Summary 

During audit fieldwork, a sample review of itemized expenditures revealed that for 

approximately 18% of the items tested TDP did not disclose the payee's address. In 

response, TDP filed amended reports that materially disclosed the missing information. 

The Commission approved this finding. 

Legal Standard 

Reporting Operating Expenditures. When operating expenditures to the same person 

exceed $200 in a calendar year, the coinmittee must report the: 

• Amount; 

• Date when the expenditures were made; 

• Name and address of the payee; and 

• Purpose (a brief description of why the disbursement was made). 2 U.S.C. 

§434(b)(5)(A) and 11 CFR §104.3(b)(3)(i). 

Facts and Analysis 

A. Facts 

During audit fieldwork, a sample review of itemized expenditures revealed that for 18% 

of the items tested, TDP did not disclose die payee's address. The majority of die 

disbursements lackmg addresses related to canvassers whose mailing address was noted 

in TDP's records. 

B. Interim Audit Report & Audit Division's Recommendation 

This matter was addressed during the exit conference. TDP representatives had no 

significant conunents. Therefore, the Audit staff recommended that TDP file amended 

reports to disclose the missing information. 

C. Committee Response to the Interim Audit Report 

TDP's response explained that it had, "made extensive efforts to locate this missing 

information and will file amendments to its reports to include the addresses which it has 

located." TDP filed amended reports that materially disclosed the missing information. 

D. Draft Final Audit Report 

The Audit staff recommended that the Commission adopt the finding that TDP failed to 

disclose the payees' addresses for certain itemized expenditures, but that these disclosure 

errors were materially corrected by TDP's subsequent amendments of the reports at issue. 

Commission Conclusion 

The Conunission approved the finding of the Audit Division with respect to disclosure of 

disbursements.