Draft Final Audit Report of the 

Audit Division on the Oklahoma 

Leadership Council 

(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 

(the Act). The 

Commission generally 

conducts such audits 

when a committee 

appears not to hav 

the threshold 

requirements for 

substantiaLcoiflBHance 

with 

deterra^^ whether ^ 

commifl^Bomplied wii 

the limi 

prohibitions 

disclosure requirg^i!« s 

of the 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 Oklahoma Leadershitll^uncil is a state party committee 

headquartered in Okla^^Tity, Oklahoma. For more 

information, see th^rp^n^the Committee Organization, p. 2. 

Financial ^Itivit] 

• Receipt« 

o Coi ons from Individuals^ 

ContrijS^ns froi]i^^her Politic 

Commit 

nsfers fron^Sggffiliated/Other Party 

al and 

penditures 

ffiliated/Other Party 

nisliiirsemvi 

c ;()|: 

o 1 

Com 

Federal Election Activity 

Disbursements 

bursements 

Levin Receipts 

Levin Disbursements 

$ 570,198 

99,942 

9,336,908 

106,953. 

1,432 

S 10,115,433 

$918,520 

9,131,482 

96,855 

12,451 

$ 10,159,308 

$85,332 

$ 89,078 

Endings and Recommendations (p. 4) 

• Misstatement of Financial Activity (Finding 1) 

• Misstatement of Financial Activity - Levin Fund (Finding 2) 

• Recordkeeping for Employees (Finding 3) 

• Contributions from Unregistered Political Organizations (Finding 4) 

S2U.S.C. §30111(b). 
Draft Final Report of the Audit 

Division on the 

Oklahoma Leadership Council 

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

Part I. Background 

Authority for Audit 

Scope of Audit 

Part n. Overview of Committee 

Committee Organization 

Overview of Financial Activity 

Part III. Summaries 

Findings and Recommendations 

Page 

Part IV. Findings and RecomiB^dati^s 

Finding!. Misstatement of ^^r^al Activiti 

Finding 2. Misstatement of F^^^i»Activitv -^H^in Fund 

Finding 3. Recordkeeping for 

Finding 4. Contributions from Ul nizations 

2 

3 

6 

8 

10 

12 
Part I 

Background 

Authority for Audit 

This report is based on an audit of the Oklahoma Leadership Council (OLC), 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 

Cpmmission to conduct audits and fleld investigations of any political committee that is 

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

subsection, the Commission must perform ah internal of reports filed by selected, 

committees to determine if the reports filed by a paE^CT^iCommittee meet the threshold 

requirements for substantial compliance with they^rST^^jP. §30111(b). 

.various risk 

Scope of Audit 

Following Commission approved procedu 

factors and as a result, this audit examined: 

1. the receipt of contributions fr||r^^hibited 

2. the disclosure of individual c^mj^^s' occuj 

3. the disclosure of disbursement^^w^MlobligatT 

4. the disclosure of expenses alloca^^ew^^federal 

5. the consistency an 

6. the completenes^^^^^nd 

7. other committe^Deration^ecessary Teview. 

and name of employer; 

lon-federal accounts; 
Part II 

Overview of Committee 

Committee Organization 

Important Dates 

• Date of Registration May 13, 

• Audit Coverage Januaryj^^ ril-December 31,2012 

Headquarters QkiS^ma d ^tQklahoma 

Bank Information 

Bank Depositories 

Bank Accounts ur Fede^^One Levinl^^^JNon-" 
Overview of Financial Activity 

(Audited Amounts) 

Cash-on-hand ^ January 1,2011 S 80,801 

o Contributions from Individuals 570,198 

o Contributions from Other Political 

Committees (PACs) 99,942 

o Transfers from Affiliated/Other Party 

Committees . ^ 9,336,908 

o Transfers from Non-federal and Levin i" 

Accounts A V 106,953 

o Offsets and Other Receipts ^ 1,432 

Total Receipts 

o Operating Expenditures 

o Transfers to Affiliated/Other Party 

Committees 

o Federal Election Activi^ 

o Other Disbursements 

Total Disbursements 

Cash-on-hand @ December 31,2012^ 

Levin Cash-on-hand 

Total Levin Receli 

Total Levin Disbars 

Levin Cash-on-hand 
Part III 

Summaries 

Findings and Recommendations 

Finding 1. Misstatement of Financial Activity 

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

records revealed a misstatement of receipts, disbursements and ending cash-on-hand 

balance for calendar year 2011. OLC understated its 201 l^^ipts and disbursements by 

$28,491 and S73,S43, respectively; and overstated its en^^rash-on-hand by $44,550. 

In response to the Interim Audit Report recommendati^^LC filed a Form 99 

(Miscellaneous Text) and disclosed all misstateme^^m^^ppropriate reference to 

individual disclosure reports. Likewise, OLC^g^ametv3^^12 Year End report 

and corrected its ending cash-on-hand balai -.-'^Por more det^^^e o. 6.) 

Finding 2. Misstatement of 

During audit fieldwork, a comparison of O! 

bank records revealed a misstatement of disbu 

calendar year 2011, and a missti^fent of beeinni 

calendar year 2012. For 2011, oj^a^^ted its 

overstated its ending cash-on-hand Iz^^For 20 

by $10,000. In response^the Inter^^^udit 

99 (MikellaneousJ^p^^^sclo: 

from its Levin F ui^^terei^l accoun 

unreported $10.0§feceipt fr^^012 in r 

it adjusted its Levin^sk-on-h^ balance. 

cial Activitv^Bi^vin Fund 

in Fund ac^ty with its 

inding cash-or^hnd for 

hon-hand and recelps for 

ments by $15,039 and 

C understated its receipts 

jmlT^dation.. OLC filed a Form 

isclo^^Ol 1 transfers made 

not disclose the 

nse to the^terim Audit Report, nor has 

more detail, see p. 8.) 

Findin^g^^^eco: 

jdit field^^ the 

moHtKM payroll log^ 

spenti^^nection wi 

staff idem^d payments 

maintain moiMy payroll I 

with both fede^rand non-f< 

recommendation, 

employees to comp 

with federal elections. T'M)r 

«ping j^^^n^loyees 

staff de^^ed that OLC did not maintain any 

luirea^odocumei^he percentage of time each employee 

leral^^ion. For calendar years 2011 and 2012, the Audit 

C en^^ees totaling $178,305 for which OLC did not 

This entire amount consisted of payroll that was allocated 

ral funds. In response to the Interim Audit Report 

details of the system it has implemented that requires 

ly logs detailing the percentage of time spent in connection 

more detail, see p. 10.) 

Finding 4. Contributions from Unregistered Political 

Organizations 

During audit fieldwork, a review of all contributions from unregistered political 

organizations indicated that OLC received contributions totaling $8,150 that may not 

have been made with permissible funds. OLC transferred $7,150 of these contributions 

to its non-federal and Levin accounts but not in a timely manner. In response to the 

Interim Audit Report recommendation, OLC stated it had transferred $1,000 ifrom its 
federal account to its state account and indicated that the transfer would be disclosed in 

OLC's 2016 April Monthly report. (For more detail, see p. 12.) 

' • • ^ 
Part IV 

Findings and Recommendations 

I Finding 1. Misstatement of Financial Activity 

Summary 

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

ending cash-on-hand 

ipts and disbursements by 

cash-on-hand by $44,550. 

iC filed a Form 99 

ipriate reference to 

.12 Year End report 

records revealed a misstatement of receipts, disbursements 

balance for calendar year 2011. OLC understated its 20] 

$28,491 and $73,543, respectively; and overstated its^ 

In response to the Interim Audit Report recommenc 

(Miscellaneous Text) and disclosed all misstatemgnp^ith" 

individual disclosure reports. Likewise, 01C an amenc 

and corrected its ending cash-on-hand baU 

Legal Standard 

Contents of Reports. Each repox^ must disclol 

• the amount of cash-on-hand^l^^ginning af 

• the total amount of receipts fo^^^^grting peric 

• the total amount of disbursemen^fortr^aportine | 

and 

• certain transa^ S^lpouire itei^iMtion j 

Schedule B d ^^isement^ 

Facts and Anal: 

As^^of audit fi^ 

witn^^ank records' 

OLC m^^jted its receipt 

following'^ti outlines the 

records. Thi^^.. .iding | 

y. 

le reporting period; 

I for the calendar year; 

i^and for the calendar year; 

le A'^^mized Receipts) or 

(b)(1), (2), (3), (4) and (5). 

lit staff todl^'ciled OLC's reported financial activity 

12011 and 2012. The reconciliation revealed that 

Its, and ending cash-on-hand for 2011. The 

srepai^es between OLC's disclosure reports and its bank 

aphs explain why the discrepancies occurred. 

2011 Committee'li^ivi^ _ 

f Reported . Bank Records Discrepancy 

Beginning Cash Balance 

@ January 1,2011 

$80,299 $80,801 $502 

Understated 

Receipts $276,679 $305,170 $28,491 

Understated 

Disbursements $238,640 $312,183 . $73,543 

Understated 

Ending Cash Balance 

® December 31,2011 

$118,338 $73,788 $44,550 

Overstated 
The beginning cash balance was understated by $S02 and is unexplained, but likely 

resulted from prior-period discrepancies. 

The understatement of receipts resulted from the following: 

• One transfer from non-federal account not reported^ 

• Four transfers from Levin account not reported^ 

• Unexplained difference 

Understatement of Receipts 

The understatement of disbursements resulted from 

• Net Under Reporting of Payroll Expenses 

• Unreported disbursements clearing bank 

• Non-federal account disbursements 

• Other reported disbursements not 

• Incorrect disbursement amount repo 

Net Understatement of Disbursements 

$10,376 

15,039 

1076 

mm 

wing: 

federal 

bank records 

The $44,550 overstatement of tl. 

receipt and disbursement reportini 

understatement of beginning cash-oi 

B. Interim And 

The Audit staff 

at the exit conferei 

responded to the exit 

pavrol^i^fesiseems 

adr^^^lu^ 

likq^related to tax< 

be nol^^at there 

to its pi^^^yendor, whi 

ash-on-l 

descrT 

$61,867 

15,889 

(3,259) 

^ (1,204) 

250 

^3.g43 

lance was the result of the 

ibove along with a $502 

viiiimu-fldaiinii 

icial a^^y with OLC representatives 

detailing the differences. OLC Counsel 

it a portion of the under-reporting of 

taxes and payroll vendor 

Ibunsel that most of the differenceis are 

vendor in 2011. However, it should also 

in 2011 where OLC did not report any payments 

le salaries as well as taxes and fees. 

The Interim /fBlfitiReDort r.-. -mmended that OLC amend its disclosure reports to correct 

the misstatemenre^ted aj^^and reconcile the cash balance on its most recent report to 

identify any subsequ^d^^pancies that could affect the recommended adjustments. 

The Interim Audit Rep^pmrther recommended that OLC adjust the cash balance as 

necessary on its most recent report, noting that the adjustment is the result of prior-period 

audit adjustments. 

C. Committee Response tolnterim Audit Report 

In response to the Interim Audit Report recommendation, OLC filed a Form 99 

(Miscellaneous Text) and disclosed all 2011 receipt and disbursement misstatements with 

This transfer was for allocable activity and did riot result in over-fiinding of federal activity by a nonfederal account. 
an appropriate reference to individual disclosure reports. Likewise, OLC filed an 

amended 2012 Year-End disclosure report and corrected its ending cash-on-hand balance. 

As such, OLC has materially complied with the Interim Audit Report recommendation. 

Finding 2. Misstatement of Financial Activity - Levin 

Fund 

Summary 

During audit fieldwork, a comparison of OLC's reported L^n Fund activity with its 

bank records revealed a misstatement of disbursements an^^ing cash-on-hand for 

calendar year 2011, and a misstatement of beginning ca^^^hand and receipts for 

calendar year 2012. For 2011, OLC understated ita^^^ments by $15,039 and 

overstated its ending cash-on-hand by $12,229. F^^^ir^g^understated its receipts 

by $10,000. In response to the Interim Audit^^^rt recomm^Mion. OLC filed a Form 

99 (Miscellaneous Text) and disclosed all pi^B^lv undisclosefll^l 1 transfers made 

from its Levin Fund to its federal accounti^^ever, OLC did noto^tose the 

unreported $10,000 receipt from 2012 in its^Wnse to th&Interim Aira^Repoit. nor has 

it adjusted its Levin cash-on-hand balance. 

Legal Standard 

A. Contents of Levin Reports. 

• the amount of cash-on-hand for 

period; 

• the total am(^ L>v.;.^nd recei; 

transfers) fo^ areoortin^^riod and 

• certain transacts 

Levis 

; <()()^ 

and end of the reporting 

(including allocation 

r; and. 

rdulcl.-

itemizatHl^n Schedule L-A (Itemized Receipts of 

iiii sementsof Levin Funds). IICFR 

B. i.f\in Fund Trai 

iiKi litany Federal 

other^^e. district, or^ 

disburser^t for Fedei 

local comirmoeof a pol 

expenditure oPIfibui 

11 CFR §§300.; 

,^district,^local committee of a political party must 

sd to it from or otherwise accepted by it from any 

nl comi^ee as the Federal component of an expenditure or 

|,ection activity under 11 CFR §300.32. A State, district, or 

I party must itself raise the Federal component of an 

: allocated between federal funds and Levin funds under 

).33. 1.1 CFR §300:34(a). 

. Levin funds must be raised solely by the State, district, or local committee of a 

' political party that expends or disburses the funds. A.State, district, or local 

committee of a political party must not use as Levin funds any funds transferred or 

otherwise provided to the committee by any State, district, or local committee of a 

political party of the national committee of any political party. 11 CFR §300.34(b). 
Facts and Analysis 

A. Facts 

As part of the audit fieldwork, the Audit staff reconciled OLC's reported Levin activity 

with its Levin bank records for 2011 and 2012. The reconciliation revealed that OLC 

misstated its disbursements and ending cash for 2011, and misstated its beginning cashon-hand.and receipts for 2012. The following charts outline the discrepancies between 

OLC's disclosure reports and its Levin bank records, and the succeeding paragraphs 

explain why these discrepancies occurred. 

2011 Committee Levin Fund Activity 

Beginning Cash Balance 

@ January 1,2011 

Receipts 

Disbursements 

Ending Cash Balance 

@ December 31,2011 

The understatement of disbursemem 

$15i039 that OLC "..- "ts Levi; 

OLC's ending 

the understated 

and receiots in the ch 

Discrepancy 

$2,190 

Overstated 

$S,000 

Understated 

$15,039 

iderstated 

12,229 

Overstated 

ited transfers totaling 

hand -.^oversta-.-j H 1,229.difference resulted from 

lents^ng with s^!^.- differences in beginning cash-on-hand 

m Committee^xin Fin^Activity 

^ '' Kc|ii>rted Bank Records Discrepancy 

BegiiM^ Cash BalaK^^ 

^ Janua^t'.. 2012 

^$27,287 $15,058 $12,229 

Overstated 

Receipts • $30,000 $40,000 $10,000 

Understated 

Disbursements ^ ^ $40,730 $43,117 $2,387 

Understated 

Ending Cash Balance . 

^ December 31,2012 

$16,557 $11,941 $4,616 

Overstated 

' OLC transferred these Levin funds to its federal allocation account for the purpose of paying allocable 

payroll expenses in accordance with 11 CFR §300.33. Also, all Levin funds were raised by OLC in 

accordance with 1 l.CFR § 300.34; Therefore, the transfers of Levin funds did not present any funding 

issue related to the Levin account. 
10 

Notwithstanding the incorrect cash balance carried over from 2011, OLC's 

understatement of receipts was the result of an unreported deposit in the amount of 

$10,000. The $4,616 overstatement of ending cash resulted from the discrepancies in 

beginning cash, receipts, and disbursements displayed in the chart above. 

B. Interim Audit Report & Audit Division Recommendation 

The Audit staff discussed the misstatements with OLC representatives at the exit . 

conference and provided work papers detailing the misstatements. In response to the exit 

conference, OLC Counsel explained that the differences identified are. small sums and 

constitute a ininimal portion of OLC's overall activity durin&the audit period. 

The Interim Audit Report recommended that OLC: 

• amend its 2011 disclosure reports to i.nclu< 

that OLC made from its Levin Fund to^f^eral 

• amend its 2012 disclosure report to •nf'^e the unrepoi 

and 

• adjust the Levin cash balance as ne^Wy on its inmost receni 

the adjustment is the result of prior-p»^..audit.^dikstments. 

isfers totaling $15,039 

lenosit of $10,000; 

;, noting that 

C. Committee Response to Inl 

In response to the Interim Audit 

(Miscellaneous Text) and disclose! 

$15,039 made 

corrected its 2011 a@OB^^id not di: 

nor did it adjust ^^pvin casl^in-hand 

filed to.correct thi 

outstanding. 

•LC filed a Form 99 

2011 transfers totaling 

/n^iugh OLC materially 

$1^00 receipt from 2012, 

ipriate amendments are 

ining hii>statement^^ Audit staff considers the matter 

ing 3. feftcordkecpiii ployees 

Sui 

idit st¥:^etermined that OLC did not maintain any 

', to document the percentage of time each employee 

1 election. For calendar years 2011 and 2012, the Audit 

!C employees totaling $178,305 for which OLC did not 

This entire amount consisted of payroll that was allocated 

with both federal and r!^P!ederal funds. In response to the Interim Audit Report 

recommendation, OLC provided details of the system it has implemented that requires 

employees to complete monthly logs detailing the percentage of time spent in connection 

with federal elections. 

During H^^ieldwork, 

monthly pg^HJogs, as 

spent in connel^ji with a fi| 

staff identified 

maintain monthly pi 

Legal Standard 

Maintenance of Monthly Logs. Party committees must keep a monthly log of the 

percentage of time each employee spends in connection with a federal election. 

Allocations of salaries, wages, and fringe benefits are to be undertaken as follows: 
11 

employees who spend 25 percent or less of their compensated time in a given 

month on federal election activities must be paid either from the federal account 

or be allocated as administrative costs; 

employees who spend more than 25 percent of their compensated time in a given 

month on federal election activities must be paid only from a federal account; and, 

employees who spend none of their compensated time in a given month on federal 

election activities may be paid entirely with funds that comply with state law. 11 

CFR§ 106.7(d)(1). 

Facts and Anal3rsis 

A. Facts 

During audit fieldwork, the Audit staff reviewed 

maintain any monthly payroll logs or equivali 

time each employee spent in connection wi 

required to document the proper allocatioi 

employee salaries and wages. For 2011 aiil 

for $178,305 in payroll.^ This amount is m; 

on Schedules H4 (Disbursementsrfbr Allocated 

for payroll. OLCdidnot 

Is to dement the percentage of 

feral election^^ese logs were 

leral and non-fecB^|6inds used to pay 

2, OLC did not maim^|monthly logs 

xclusi^ly of expend^es reported 

N>n-federal Activrg^nd paid 

with a mixture of federal and nc funds dun^- • same month. 

B. Interim Audit Report & Am 

The Audit staff discussed,the record! 

during audit field 

OLC Counsel 

the audit, OLC i 

memorandum concergi^timeEgBpine requif 

emplo; 

furthll^§^*tRS^lMkC wH^^inue i 

re^ranfeeping requr^ents a^allowed. 

livi 

ng ret 

le exit cS^erenc 

2012 eT 

eeping 

•mmenaiaticn 

It wn^LC representatives 

isel^he exit conference, 

^le ariilMor to the commencement of 

lis in response to the Commission 

lents. OLC's Chairman instructed its 

Jn this memorandum. The response 

Its staff to ensure payroll 

The Inf^^^Audit Repor 

jBvidence i 

mployee| 

provide^^ii- of it 

3mn:. that OLC: 

^ maintamed monthly time logs to document the percentage 

It in connection with a federal election; or 

1 to maintain monthly payroll logs in the future. 

C. Committee Resp^^^ Interim Audit Report 

In response to the Interim Audit Report recommendation, OLC stated that it has 

impleniented timekeeping protocols in response to the Commissionfs December 2013 

memorandum^ concerning timekeeping requirements. OLC's response further stated that 

its Chairman verbally instructed employees to comply with the guidelines set forth in the 

* OLC did not report or pay any payroll consisting of 100 percent federal fiindis. All payroll-related 

expenses were allocated and reported on Schedules H4. Payroll amounts are stated net of taxes and 

fringe benefits. 

' Request for Consideration of a Legal Question (LRA 917), issued on October 23,2012, and the 

Commission's policy conclusion issued on November 28,2012. 
12 

Commission's memorandum. OLC provided a copy of its employee recordkeeping 

policy, along with a memorandum OLC sent to its entire staff explaining the 

recordkeeping requirements and instructions detailing how employees are expected to 

comply. OLC also provided a copy of the time allocation sheet its employees will 

complete each month documenting their time spent on federal and state election 

activities. As such, OLC has complied with the Interim Audit Report recommendation 

by providing details of its plan to maintain monthly payroll logs in the future. 

Finding 4. Contributions from Unregistered Political 

Organizations ^ 

Summary ^ 

During audit fieldwork, a review of all contribution li . n. ur^fegistered political 

organizations indicated that OLC received con^^tions totahnmRlSO that may not 

have been made with permissible funds. Q^^nsferred $7,1 J^^^ese contributions 

to its non-federal and Levin accounts but ^^^a timely manner, n^^^nse to the 

Interim Audit Report recommendation, OL^^ted it had^nsferred^^^O from its 

federal account to its state account and indicatHmat the^i^^sfer wouldl^Misclosed in 

OLC's 2016 May Monthly repo: ^ ^ F 

Legal Standard 

A. Party Committee Limits. A pal 

$10,000 per ycag^^^ny person 

may not contmj^^mo^^an $S,i 

§§110.1(a) al®(5), 1 llW) and 

ive more than a total of 

political committee 

aXl)(D) and 11 CFR 

; Contr 

lives ai 

2?! 

rmissible or Excessive. If a 

be impermissible or excessive, the 

:k to the d5hor; or 

its'f^ral account and: 

in tn^ccount to cover all potential refunds; 

I explaining why the contribution may be illegal; 

Ition oh Schedule A if the contribution has to be itemized 

C. 

littee I 

I the qi 

}sit the chc 

;p enoughi 

La written i 

In^liP^his expll 

befoH^ .ualiivi?established. 11 CFR §103.3(b)(3), (4) and (5). 

Questionable Cont^bbtions. If a committee receives a contribution that appears to 

be prohibited (a questionable contribution), it must follow the procedures below: 

1. Within 10 days after the treasurer receives the questionable contribution, the 

committee must either: 

• Return the contribution to the contributor without depositing it; or 

• Deposit the contribution (and follow the steps below). 11 CFR § 103.3(b)( 1). 

If the committee deposits the questionable contribution, it may not spend the 

funds and must be prepared to refund them. It must therefore maintain sufficient 

funds to make the refunds or establish a separate account in a campaign 

depository for possibly illegal contributions. 11 CFR §103.3(b)(4). 

2. 
13 

3. 

4. 

5. 

The committee must keep a written record explaining why the contribution may 

be prohibited and must include this information when reporting the receipt of the 

contribution. 11 CFR § 103.3(b)(5). 

Within 30 days of the treasurer's receipt of .the questionable contribution, the 

committee must make at least one written or oral request for evidence that the 

contribution is legal. Evidence of legality includes, for example, a written 

statement from the contributor explaining why the contribution is legal or an oral 

explanation that is recorded by the committee in a memorandum. 11 CFR 

§l03.3(b)(l).. 

Within these 30 days, the committee must either: 

• Confirm the legality of the contribution; or 

• Refund the contribution to the contributor; 

covering the period in which the refunc 

the refund on the report 

11 CFR § 103.3(b)(2). 

Facts and Analysis 

A. Facts 

During audit fieldwork, the Audit staff identi'fi'^tive coi] 

five state and local political organizations. 0L( 

totaling $2,150 in January 2011 ^transferred tlil 

2011. Along with its entry on its^^^^ejosure i 

memo text stating that an employe^hon^JMOLC SI 

2Utions totglilBl&i$8.150 from 

of these cOTMbutions 

; non-federal account in June 

^the transfer, OLC included a 

was asked to transfer 

funds in February 20iyL^LC stated 

and it later discoveitSffl^^e transferl 

the funds had nqt^Pn transited, 0LC1 

a state account ai^mrovided b^ stateme 

transaction. 

$5,0001 

federal accr^ 

Loccurrgj^uring a transitional time 

3sse^ Upon discovery that 

.-.^0 th^g^ilgs. from its federal account to 

me Comm^ion in support of this 

^Unregistered committee in September 

Levin fOT^Ccount in January 2013. Along with its 

the transfer, OLC included a memo text stating that 

sly dS^ited into the federal account. Both the $2,150 and 

itions abov^« consioi^ untimely resolved since the transfers from the 

-. e made -ind thirty days of each contributions receipt. 

ich was 

FEC disc" 

ition was ei 

Lastly, OLC recer 

2011, which has not 

contribution is considei 

contribution from an unregistered committee in April 

ierred or refunded from its federal account. This 

unresolved. 

B. Interim Audit Report & Audit Division Recommendation 

The Audit staff discussed this matter with OLC's representatives during the exit 

conference and provided copies of relevant work papers. Prior to audit fieldwork, OLC 

transferred $7,150 of the $8,150 referred to in the section above from its federal account 

to its non-federal and Levin Fund accounts. In response to the exit conference, OLC 

Counsel stated that the committee will research the remaining contribution of $1,000 and 
provide additional information regarding the permissibility of the funds as it becomes 

available. 

14 

The Interim Audit Report recommended that OLC: 

• provide evidence that the transfers for the contributions totaling $7,150 were 

made timely; and 

• provide evidence demonstrating that the remaining contribution of $1,000 was 

made with permissible funds; or 

• refund the remaining impermissible funds ($1,000) and provide evidence of such 

refund (a copy of the front and back of the negotia^^fund check); or 

• if funds are not available to make the necessaryj^po; disclose the refund due on 

Schedule D (Debts and Obligations) until fundsl^ome'avallable to make the 

refund. 

C. Committee Response to Interim Audi| 

In response to the Interim Audit Report i 

$1,000 from its federal account to its stated 

activity documentation to support this transfi^ 

plans to disclose this transfer in itSt2016 April 

considers $7,150 untimely reso 

state account will remain outstani 

substantiate the transfer. 

V 

iendation, OLC & . had transferred 

int on March 1,20ll|^^ver, no bank 

provid^ OLC fur^^gited that it 

in. As such, ^^feudit staff 

dition, 1 

nk docu? 

)0 that OLC transferred to its 

Dtation is provided to 

V