Final Audit Report of the 

Commission on the 2012 

Democratic National Convention 

Committee, Inc. 

(September 1, 2011- September 30, 2014) 

Why the Audit 

Was Done 

Federal law requires the 

Commission to audit the 

national committee of a 

party who receives 

payments for presidential 

nominating conventions.' 

The audit examines the 

receipt and use of Federal 

flmds and whether the 

conunittee otherwise 

complied with the 

limitations, prohibitions 

and disclosure 

requirements of the 

election law. 

Future Action 

The Commission may 

initiate an enforcement 

action, at a later time, 

with respect to the matter 

discussed in this report. 

About the Committee (p. 2) 

The 2012 Democratic National Convention Committee, Inc. 

(DNCC) was responsible for the day-to-day arrangements and 

operations of the Democratic Presidential nomination convention. 

DNCC is headquartered in Washington, DC. For more 

information, see chart on the Committee Organization, p. 2. 

Financial Activity (p. 2) 

• Receipts 

o Federal Funds 

o Offsets to Convention 

Expenditures 

Total Receipts 

• Disbursements 

o Convention Expenditures 

Total Disbursements 

$ 18,248,300 

495,733 

$ 18,744,033 

$ 18,558,723 

S 18,558,723 

Commission Finding (p. 3) 

• Net Outstanding Convention Expenses 

' 26 U.S.C. §9008(g). EfTective April 3,2014, the Gabrieiia Miller Kids First Research Act, Public Law 

113-94,128 Stat. 108S (2014), terminates the right of any major or minor political party to a payment 

under 26 U.S.C. §9008. Because the entitlement of the DNCC to payment under 26 U.S.C. §9008 

precedes the effective date of the Gabrieiia Miller Kids First Research Act, the payment that the DNCC 

received is not affected by this Act. 
Final Audit Report of the 

Commission on the 2012 

Democratic National Convention 

Committee, Inc. 

(September 1, 2011- September 30, 2014) 
Table of Contents 

Page 

Part 1. Background 

Authority for Audit 1 

Scope of Audit 1 

Inventory of Committee Records 1 

Audit Hearing 1 

Part II. Overview of Committee 

Committee Organization 2 

Overview of Financial Activity 2 

Part III. Summary 

Commission Finding 3 

Part IV. Commission Finding 

Net Outstanding Convention Expenses 4 
Parti 

Background 

Authority for Audit^ 

This report is based on an audit of the 2012 Democratic National Convention Committee, 

Inc. (DNCC), undertaken by the Audit Division of the Federal Election Commission (the 

Commission) as mandated by Section 9008(g) of Title 26 of the United States Code. 

That section directs the Commission to conduct an examination and audit of the 

payments for presidential nominating conventions no later than December 31 of the 

calendar year in which the presidential nominating convention involved is held. 

Scope of Audit 

This audit examined: 

1. the disclosure of receipts; 

2. the disclosure of disbursements, debts and obligations; 

3. the recordkeeping process and completeness of records; 

4. the consistency between reported figures and bank records; 

5. the accuracy of the Statement of Net Outstanding Convention Expenses; 

6. the committee's compliance with requirements concerning expenditures for 

convention expenses; and 

7. other committee operations necessary to the review. 

Inventory of Committee Records 

The Audit staff routinely conducts an inventory of committee records before it begins the 

audit fieldwork. DNCC records were materially complete and the fieldwork began 

immediately. 

Audit Hearing 

Pursuant to Directive 70, committees are eligible to request a hearing to respond to 

allegations in the Draft Final Audit Report that the committee violated the FECA. This 

report did not contain any such findings so no hearing was offered. 

2 EfTective April 3,2014, the Gabrieiia Miller Kids First Research Act, Public Law 113-94, 128 Stat. I08S 

(2014), terminates the right of any major or minor political party to a payment under 26 U.S.C. §9008. 

Because the entitlement of the DNCC to payment under 26 U.S.C. §9008 precedes the effective date of 

the Gabrieiia Miller Kids First Research Act, the payment that the DNCC received is not affected by this 

Act. 
Part II 

Overview of Committee 

Committee Organization 

Important Dates 

e Date of Registration August 10,2011 

e Audit Coverage September 1,2011- September 30,2014 

Headquarters Washington, DC 

Bank Information 

a Bank Depositories Four 

a Bank Accounts Six 

Treasurer 

a Treasurer When Audit Was Conducted Andrew Tobias 

a Treasurer During Period Covered by Audit Andrew Tobias 

Management Information 

a Attended Commission Campaign Finance 

Seminar 

No 

a Who Handled Accounting and 

Recordkeeping Tasks 

Paid Staff 

Overview of Financial Activity 

(Audited Amounts) 

Cash-on-hand ® September 11,2011 SO 

Receipts 

o Federal Funds 18,248,300 

o Offsets to Convention Expenditures 495,733 

Total Receipts $18,744,033 

Disbursements 

o Convention Expenditures 18,558,723 

Total Disbursements $ 18,558,723 

Cash-on-hand @ December 31,2012 S 185310 
Part III 

Summary 

Commission Finding 

Net Outstanding Convention Expenses 

DNCC received $18,248,300 in federal funds to finance the Democratic National 

Convention. The Statement of Net Outstanding Convention Expenses (NOCE), as 

calculated by the Audit staff, indicates that DNCC did not receive payments of federal 

funds in excess of its entitlement. 

In response to the Preliminary Audit Report recommendation, the DNCC requested no 

adjustment and had no further comments. 

The Commission approved a finding that DNCC did not receive payments of federal 

funds in excess of its entitlement. (For more detail, see p. 4.) 
Part IV 

Commission Finding 

I Net Outstanding Convention Ebcpenses 

Summaiy 

DNCC received $18,248,300 in federal funds to finance the Democratic National 

Convention. The Statement of Net Outstanding Convention Expenses (NOCE), as 

calculated by the Audit staff, indicates that DNCC did not receive payments of federal 

funds in excess of its entitlement. 

In response to the Preliminary Audit Report recommendation, the DNCC requested no 

adjustment and had no further comments. 

The Commission approved a finding that DNCC did not receive payments of federal 

funds in excess of its entitlement. 

Legal Standard 

A. Entitlement to Payments From the Fund. The national committee of a major party 

shall be entitled to payments with respect to any presidential nominating convention, in 

amounts that, in the aggregate shall not exceed $4,000,000, as adjusted by the Consumer 

Price Index. The major party entitlement for the 2012 nominating convention was 

$18,248,300. 26 U.S.C. §9008(b)(l) & (5). 

B. Repayments. Any portion of the entitlement that remains unspent after all convention 

expenses have been paid shall be returned to the Secretary of the Treasury. The national 

committee or convention committee shall make an interim repayment of unspent funds 

based on the financial position of the committee as of the end of the ninth month 

following the last day of the convention, allowing for a reasonable amount as determined 

by the Commission to be withheld for unanticipated contingencies. The interim 

repayment shall be made no later than 30 calendar days after the end of the ninth month 

following the last day of the convention. 11 CFR §9008.12(b)(S). 

C. Repayment Determination Procedures. The Commission will follow the same 

repayment determination procedures, and the committee has the same rights and 

obligations as are provided for repayment determinations involving publicly funded 

candidates under 11 CFR §9007.2(c) through (h). 11 CFR §9008.12(c). 

D. Net Outstanding Convention Expenses (NOCE). A convention committee shall 

file, no later than 60 days after the last day of the convention, a statement of that 

committee's "net outstanding convention expenses." This statement must contain, among 

other things: 

• The total of all committee assets including cash on hand, amounts owed to the 

committee and capital assets listed at their fair market value; 

• The total of all outstanding obligations for qualified convention expenses; and 

• An estimate of necessary winding-down costs. 11 CFR §9008.10(g). 
Facts and Anal3rsis 

A. Facts 

For the 2012 national conventions, each major political party was entitled to receive 

federal funds of $18,248,300 to finance its national presidential nominating convention. 

The 2012 Democratic National Convention ended on September 6,2012. The DNCC 

filed a Statement of Net Outstanding Convention Expenses as of October 21,2012. The 

most recent NOCE statement was submitted on September 12,2013. The Audit staff 

reviewed the financial activity through September 30,2014, and estimated the winding 

down costs in preparing the figures shown below. 

2012 Democratic National Convention Committee, Inc 

Statement of Net Outstanding Convention Expenses 

As of October 21, 2012 

Prepared Through September 30, 2014 

Assets 

Cash in Bank $1,288,428 

Accounts Receivable 588,886 

Total Assets $1,877,314 

Liabilities 

Accounts Payable for Qualified Convention 

Expenditures at 10/21/2012 $ 456,195 

Winding Down Costs: 

Actual (10/22/12 - 9/30/14) 1,419,452 

Estimated (10/1/14-3/31/15) [a] 667 1,420,119 

Total Liabilities $1.876.314 

Net Outstanding Convention Expenses 

(Surplus) as of October 21,2012 $ 1,000 

Less: Interim Repayment to the U.S. Treasury ($1,000) 

on 7/26/13 

Amount Repayable to the U.S. Treasury 

[a] Estimated winding down costs will be compared to actual winding down costs and adjusted accordingly. 
The NOCE as calculated by the Audit staff indicates that DNCC did not receive 

payments of federal funds in excess of its entitlement. 

At the exit conference held at the end of audit fieldwork, DNCC representatives were 

informed of the NOCE as calculated by the Audit staff. This NOCE indicated that the 

DNCC had a surplus of approximately $17,000. The Audit staff explained that 

adjustments to the NOCE calculations would be necessary based upon any additional 

documentation provided. Such documentation was provided to the Audit staff 

subsequent to the exit conference and resulted in a reduction of the initial NOCE surplus 

to a balance of $1,000. On July 26,2013, the DNCC made an interim repayment to the 

United States Treasury in the amount of $1,000 pursuant to 11 CFR §9008.12(b)(5). 

Subsequently, DNCC representatives were provided a copy of the NOCE updated by the 

Audit staff which indicates the amount repayable to the United States Treasury is $0. 

B. Preliminary Audit Report & Audit Division Recommendation 

The Preliminary Audit Report recommended that DNCC demonstrate if any adjustment is 

required to any component of the NOCE statement or provide other comments if it so 

desired. 

C. Committee Response Preliminary Audit Report 

In response to the Preliminary Audit Report recommendation, the DNCC requested no 

adjustments and had no further comments. 

D. Draft Final Audiit Report 

In the Draft Final Audit Report, the Audit staff maintained that the DNCC had not 

received federal funds in excess of its entitlement. 

E. Committee Response to the Draft Final Audit Report 

The DNCC had no further comments on the Draft Final Audit Report. 

F. Commission Conclusion 

On March 10,2015, the Commission considered the Audit Division Recommendation 

Memorandum in which the Audit staff recommended that the Commission find that the 

DNCC did not receive funds in excess of its entitlement and that no repayment to the 

U.S. Treasury is necessary. 

The Commission approved the Audit staffs recommendation.