Michael Toner 

DiiGct: (202) 508-<il75 

Vas: (202) 220-7475 

July 14.2010 

CONFIDENTIAL 

VIA ELECTRONIC MAIL 

Joseph F. Stoltz 

Assistant Staff Director 

Fedeial Elecdon Commission 

999 E Street, NW 

Washington, DC 20463 

Re: Republican Party of Minnesota Response to Interim Audit Report (January 1, 

2007-December 31,2008) 

Dear Mr. Stoltz: 

I am in receipt of your May 25, 2010 letter to David Sturrock enclosing the Audit 

Division's interim audit report of the Republican Party of Minnesota (*'RPM") for the 

2007-2008 elecdon cycle. RPM is filing this response to the interim audit report in 

accordance with an extension of time granted on June 14,2010. 

RPM provides the following additional informadon in response to the 

recommendadons contained in the interim audit report. 

L Amended Reports 

The interim audit report appears to use data &om RPM's original reports or from 

amended reports that are older than the most recent amendment. RPM has filed 

amendments to its reports which made a number of changes that impact the findings 

in the interim audit report 

We understand based on correspondence with the Audit Division that findings in 

audit reports generally do not reflect changes made in amendments filed after an audit 

nodficadon is sent. However, as is detailed below, some changes to RPM's reports 

were made on amendments that were filed with the Commission prior to the audit 

nodficadon. Further, the Audit Division correspondence indicated that the final 

audit report would also note that amendments have already been filed to correct 

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Joseph F. Stoltz 

July 14,2010 

Page 2 

certain issues when amendments were filed after the date of the audit notificadon. As is detailed 

below, RPM requests that the Audit Division adjust the final audit report accordingjly to reflect 

amendments already filed. 

A. Unreported Transfers 

The interim audit report notes on Page 6 diat RPM failed to disclose $204,166 in transfers £com 

nonfederal accounts in 2008. Of this amount, 3202,981.67 was disclosed on amended reports as 

outlined bdow. 

The following transfers to RPM's federal account were first disclosed' on an amendment to RPM's 

2008 April Monthly report filed on May 30, 2008, which was prior to the issuance of the audit 

notification letter:^ 

c r \ i :rii iUii r 1 r:!n-rc r 1 );n:c IJ A'.iin l 

1 M:l\ ' . -ill ^1)1 IS 

$22,461.00 

$29i911.00 

$23,440.25 

$68,658.06 

$32,057.00 

3/17/08 

3/18/08 

3/24/08 

3/25/08 

3/27/08 

28991203277 

28991203277 

28991203277 

28991203278 

28991203278 

The following transfers were disclosed as one transaction on an amendment to RPM's 2008 July 

Monthly report filed on September 21,2009. 

rr.in-tcr D. 1 ic 1 1 ,( , 1 \ umlicr 

1 !^ C P re 1-,l)c 1 r ^, 1, :ii(i ' ^ A mciulmc 

$4,494.37 

$5,205.63 

$16,754.36 

6/10/08 

6/10/08 

6/10/08 

29934553760 

29934553760 

29934553760 

^ These transfers were also disclosed on all subsequent amendments to RPM's 2008 April Monthly 

Report. 

^ The audit notification letter for die audit of RPM's 2007-2008 activity is dated March 23,2009. 
Joseph F. Stoltz 

July 14.2010 

Page 3 

B. August/September 2008 Cash Discrepancy 

The interim audit r^ort indicates in footnote 2 that there was a discrepancy between the closing cashon-hand on the 2008 August Monthly report and the beginning cash-on-hand of the 2008 September 

Monthly report This issue was corrected by RPM on amended reports filed on September 21.2009. 

C. December 2008 Cash Discrepancy 

The reported cash-on-hand as of December 31,2008 noted on Page 6 of the interim audit report does 

not reflect the cash-on-hand disclosed on RPM's most recent amendment to that report If the 

ending cash-on-hand disclosed in RPM's most recent amendment to the 2008 Year End report is 

used, the cash-on-hand understatement as of December 31, 2008 is actually $84,607.92 rather than 

$174,238. 

IL Interim Audit Report ReconMnendations 

In addition to the issues noted above which were corrected in amendments filed by RPM previously. 

RPM is taking a number of additional steps to comply with the recommendations of the interim audit 

report The interim audit report's recommendations, along with RPM's response, are provided in 

greater detail bdow. 

A. Amendments to 2007 and 2008 Reports 

RPM transfened $50,000 from a federal account to a non-federal account on October 18, 2007, then 

retumed the fimds to the federal account on October 24, 2007. The interim audit report correctly 

notes that these transfers were not reported RPM is in the process of drafting an amendment to its 

2007 November Monthly Report An amendment to disdose these transfers will be filed no later than 

July 27,2010. 

Transfers made in 2008 that are noted in the interim audit report were disdosed by RPM on amended 

reports as was outlined above. 

As was noted above, the interim audit report indicates diat RPM fiuled to disdose $204,166 in 

transfers bom nonfederal accounts in 2008, but of that amount, $202,981.67 was disdosed on 

amended reports. RPM's audit adjustment will accoimt for the additional $1,184.33 in transfers as 

well as the $1,115 in bank fees diat the interim audit report indicates were not reported in 2007. 
Joseph F. Stoltz 

July 14,2010 

Page 4 

B. Reconciliation of Cash Balance 

The interim audit report indicates that RPM should reconcile the cash balance of its most recent 

report to determine whether any subsequent discrepancies impact the $174,238 audit adjustment 

recommended by the Audit Division. As was noted above, based on amendments to 2008 reports, 

RPM has calculated a discrepancy of only $84,607.92. 

RPM has determined that the amount of the discrepancy as of May 31, 2010 is $9,821.13. RPM filed 

an amendment to its 2010 June Monthly Report to indude an audit adjustment of $9,821.13 on July 

14. 2010. 

C. Audit Adjustment 

The interim audit report recommends that RPM amend its most recent report to correct the cash-onhand balance. As was noted above. RPM amended its 2010 June Monthly Report to indude an audit 

adjusttnent of $9,821.13 on July 14.2010. 

If you have any questions regarding RPM's response to the interim audit report, please do not hesitate 

to contact me at (202) 508-6175 or Karen Trainer at (202) 508-6179. 

Sincerdy. 

Michad Toner 
RECEIVED 

FEC MAIL CENTER 

2010 JUL 28 PM3:I«6 Micliaci Toner 

Direct: (202) 508-6175 

Fax: (202) 220-7475 

July 28.2010 

CONFIDENTIAL 

VIA ELECTRONIC MAIL 

Joseph F. Stoltz 

Assistant Staff Director 

Federal Election Commission 

999 E Street, NW 

Washington. DC 20463 

Re: Republican Party of Minnesota Response to Interim Audit Report (January 1. 

2007-December 31.2008) 

Dear Mr. Stoltz: 

The Republican Part)' of Minnesota C*RPM") is filing this additional response to your 

May 25, 2010 letter to David Sturrock conceming the Audit Division's interim audit 

report of RPM for die 2007-2008 dection cycle. 

As was noted in RPM's July 14, 2010 response to the interim audit report. RPM 

transferred $50,000 from a federal account to a non-federal account on October 18, 

2007, then retumed the funds to the federal account on October 24, 2007. The 

interim audit report correctiy noted that these transfers were not reported. On July 

27, 2010, RPM duly filed an amendment to its 2007 November Monthly report to 

disclose these transfers. RPM also fiJied amendments the same day to its 2007 

December Monthly and 2007 Year End reports to carry' forward corrected year-todatc totals. 

If you have any questions regarding RPM's response to the interim audit report, 

please do not hesitate to contact me at (202) 508-6175 or Karen Trainer at (202) 508-

6179. 

Sincerely, 

Michael E. Toner 

Bryan Cave LLP 

1155 F street N.W. 

Washington, D.C. 20004 

Tel (202) 508-6000 

Fax(202)508-6200 

www.bryancave.com 

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