Utah Democratic Party 

September 4, 2015 

Federal Elections Commission 

C/0 Paula Nurthen - Audit Division 

999 E Street NW 

Washington, DC 20463 

Re: Utah Interim Audit Report 

Federal Elections Commission, 

This letter is in response to the Interim Audit Report provided to the Utah State Democratic Committee 

on July 22, 2015. The USDC would like to respond to two of the issues outlined in the report at this 

time. 

Misstatement of Financial Activity 

The Audit staff asserts the USDC overstated its financial activity by $(92,203), the overwhelming majority 

of which is related to $(90,439) in H3 Transfers. For documentation, the Audit staff cites that $(90,439) 

appears in reports filed with the commission, but the transfers are not found on the bank statements for 

the period. 

As outlined in the February 20, 2015, letter to the Commission, the USDC contends detailed financial 

records were maintained that support the H3 transfers filed in the February 2011, April 2011, and July. 

2011 FEC Reports. The USDC acknowledges the H3 transfers do not appear on the bank statements; 

however, the USDC argues this is a result of the sweep function and the parent account holding both 

Federal and Non-Federal funds. Since a physical transfer of funds between the Federal and Non-Federal 

account would result in the money being "sweeped" back into the same account, the USDC was able to 

make the transfer as an accounting book entry. This accounting was reported to the FEC. As previously 

stated, the USDC has detailed accounting records of what was in those transfers and how the entry was 

made, and the supporting documentation, inciuding the individual line items for how the H3 transfer 

was calculated, were supplied to the Commission in February 2015. We have included that letter and 

the documentation in the attachments. 

The Utah State Democratic Committee has previously accepted the $(2,170) over reporting as a result of 

the Fidelity Investment account, and the $406 in the unexplained difference. The USDC requests this 

finding be adjusted to $(1,764) in over reporting. 

Receipt of Levin Fund Donations that Exceed the Limit 

The Utah State Democratic Committee agrees with the Commission regarding the $12,000 in excessive 

Levin donations. As proposed in the November 26, 2014, letter to the Commission, the USDC believes a 
clerical error was made and other contributions were Intended to be flagged as Levin eligible. The USDC 

proposed amending the appropriate reports to demonstrate sufficient Levin funds. 

Per our previous conversations and the letter to the Commission on February 20, 2015, the USDC is 

waiting for clearance by the FECs General Counsel to file these amendments. We will accept the 

Interim Audit Report's recommendations as agreeing to the November 26, 2014, proposed substitute 

Levin funds and will file the appropriate amendments within the next 30 days. 

The USDC does not have any additional comments as to any of the other findings In the Interim Audit 

Report. However, the committee notes that it now has procedures in place to ensure that time sheets 

are maintained for employees who are paid in whole, or in part, with non-federal funds. If there are any 

questions, please feel free to contact me at laureng)utdem.org or (801) 809-0929. 

Sincerely, 

Lauren LIttlefleld 

Executive Director 

Utah State Democratic Committee