Part II
Overview of Campaign

Campaign Organization

Important Dates

Steven Reifman for Congress

¢ Date of Registration

February 13, 2004

« Audit Coverage

February 13, 2004 — December 31, 2004

Headquarters

Farmington Hills, MI

Bank Information

«Bank Depositories

1

¢ Bank Accounts

1 Checking

Treasurer

« Treasurer When Audit Was Conducted

Mr. Andrew Glazer

e Treasurer During Period Covered by Audit

Mr. Allen Glass (2/13/04-9/23/04) and
Mr. Andrew Glazer (9/24/04-12/31/04)

Management Information

¢ Attended FEC Campaign Finance Seminar

No

e¢ Used Commonly Available Campaign
Management Software Package

No

e Who Handled Accounting and
Recordkeeping Tasks

Andrew Glazer and Allen Glass

Overview of Financial Activity

(Audited Amounts)
Cash on hand @ March 15, 2004 $0
o Contributions From Individuals 83,051
o Contributions From Political Committees 16,000
o Other Receipts 24,422
Total Receipts $123,473
o Operating Expenditures 120,136
o Other Disbursements 3,000
Total Disbursements $123,136
Cash on hand @ December 31, 2004 $337



audit report recommendation by filing amended reports which materially corrected the
disclosure errors.

Finding 2. Disclosure of Occupation and Name of
Employer

Summary

RFC either failed to disclose or inadequately disclosed the contributor’s occupation or
name of employer for a significant number of contributors. In response to the interim
audit report recommendation, RFC filed amended reports disclosing the contributor’s
occupation and/or name of employer and other missing information for a material number
of contributors lacking such information.

Legal Standard

A. Itemization Required for Contributions from Individuals. An authorized
candidate committee must itemize any contribution from an individual if it exceeds $200
per election cycle, either by itself or when combined with other contributions from the
same contributor. 2 U.S.C. §434(b)(3)(A).

B. Election Cycle. The election cycle begins on the first day following the date of the
previous general election and ends on the date of the next general election. 11 CFR

§100.3(b).

C. Required Information for Contributions from Individuals. For each itemized

contribution from an individual, the committee must provide the following information:
¢ The contributor’s full name and address (including zip code);

The contributor’s occupation and the name of his or her employer;

The date of receipt (the date the committee received the contribution);

The amount of the contribution; and

The election cycle-to-date total of all contributions from the same individual. 11

CFR §§100.12 and 104.3(a)(4) and 2 U.S.C. §434(b)(3)(A).

D. Best Efforts Ensures Compliance. When the treasurer of a political committee
shows that the committee used best efforts (see below) to obtain, maintain, and submit
the information required by the Act, the committee’s reports and records will be
considered in compliance with the Act. 2 U.S.C. §432(h)(2)(i).

E. Definition of Best Efforts. The treasurer and the committee will be considered to
have used “best efforts” if the committee satisfied all of the following criteria:
¢ All written solicitations for contributions included:
o Aclear request for the contributor's full name, mailing address, occupation,
and name of employer; and
o The statement that such reporting is required by Federal law.


Part I
Background

Authority for Audit

This report is based on an audit of Steven Reifman for Congress (RFC), 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 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 internal 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

Following Commission approved procedures, the Audit staff evaluated various risk
factors and as a result, this audit examined:

The disclosure of disbursements, debts and obligations.

The consistency between reported figures and bank records.

The disclosure of occupation and name of employer.

The completeness of records.

The receipt of loans.

Other committee operations necessary to the review.

AwWRYNE


Part III
Summaries

Findings and Recommendations

Finding 1. Disclosure of Disbursements

For disbursements requiring itemization, RFC failed to adequately disclose the required
information for 93 disbursements, totaling $63,640. RFC complied with the interim audit
report recommendation by filing amended reports which materially corrected the
disclosure errors.

Finding 2. Disclosure of Occupation and Name of
Employer

RFC either failed to disclose or inadequately disclosed the contributor’s occupation or
name of employer for a significant number of contributors. In response to the interim
audit report recommendation, RFC filed amended reports disclosing the contributor’s
occupation and/or name of employer and other missing information for a material number
of contributors lacking such information.


¢ Within 30 days after the receipt of the contribution, the treasurer made at least one
effort to obtain the missing information, in either a written request or a
documented oral request.

¢ The treasurer reported any contributor information that, although not initially
provided by the contributor, was obtained in a follow-up communication or was
contained in the committee’s records or in prior reports that the committee filed
during the same two-year election cycle. 11 CFR §104.7(b).

Facts and Analysis

The Audit staff’s review of itemized contributions from individuals indicated that RFC
either failed to disclose or inadequately disclosed the contributor’s occupation and/or
name of employer for 36 contributions, totaling $19,155. For 11 itemized transactions
the required information was blank. For the remaining 25 errors, RFC disclosed only the
contributor’s occupation or name of employer.

There was no evidence that RFC utilized its best efforts to obtain, maintain and submit
this information. The treasurer was provided a schedule of these errors.

Interim Audit Report Recommendation and Committee Response
The Audit staff recommended that RFC take the following action:
¢ Provide documentation that it exercised best efforts to obtain, maintain and
submit the required contributor information; or
« Make an effort to contact those individuals for whom the required information
was missing, provide documentation of such efforts (such as copies of letters to
the contributors and/or phone logs), and amend its reports to disclose any
information obtained from such efforts.

In response to the interim audit report recommendation, RFC filed amended reports
disclosing the contributor’s occupation and/or name of employer and other missing
information for a material number of contributors lacking such information.


FEDERAL ELECTION COMMISSION
Washington, DC 20463

April 27, 2007

MEMORANDUM
To: Robert W. Biersack

Press Officer
From: Joseph F. Stoltz

Assistant Staff D&tor

Audit Division
Subject: Public Issuance of the Report of the Audit Division on Steven Reifman for

Congress Committee

Attached please find a copy of the audit report on Steven Reifman for Congress
Committee, which was approved by the Commission on April 12, 2007.

All parties involved have received copies of the report and the report may be
released to the public.

Attachment as stated

ce: Office of General Counsel
Office of Public Disclosure
Reports Analysis Division

FEC Library
DSDD Website Va


Part IV
Findings and Recommendations

| Finding 1. Disclosure of Disbursements

Summary

For disbursements requiring itemization, RFC failed to adequately disclose the required
information for 93 disbursements, totaling $63,640. RFC complied with the interim audit
report recommendation by filing amended reports which materially corrected the

disclosure errors.

Legal Standard
A. Reporting Operating Expenditures. When operating expenditures to the same

person exceed $200 in an election cycle, the committee must report the:
e Amount;
e Date when the expenditures were made;

e Name and address of the payee; and
« Purpose (a brief description of why the disbursement was made—see below). 2

U.S.C. §434(b)(5) and 11 CFR §104.3(b)(4)(i).

B. Examples of Purpose

e Adequate Descriptions. Examples of adequate descriptions of “purpose” include
the following: dinner expenses, media, salary, polling, travel, party fees, phone
banks, travel expenses, travel expense reimbursement, catering costs, loan
repayment, or contribution refund. 11 CFR §104.3 (b)(4)(i)(A).

« Inadequate Descriptions. The following descriptions do not meet the requirement
for reporting “purpose”: advance, election day expenses, other expenses, expense
reimbursement, miscellaneous, outside services, get-out-the-vote, and voter
registration. 11 CFR §104.3 (b)(4)(i)(A).

Facts and Analysis

The Audit staff review of disbursements requiring itemization identified 93 disclosure
errors, totaling $63,640. For all of these disbursements an inadequate purpose was
disclosed. In addition, a number of these disbursements also included incorrect payees,
missing addresses, and missing memo entries for credit card payments.

This matter was discussed at the exit conference and schedules of the above errors were
provided to the treasurer. The treasurer agreed to file amended disclosure reports.

Interim Audit Report Recommendation and Committee Response
The Audit staff recommended that RFC amend its reports to properly disclose these
disbursements on Schedule B (Itemized Disbursements). RFC complied with the interim


Report of the Audit Division on

Steven Reifman for Congress
February 13, 2004 ~ December 31, 2004

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 threshold
requirements for
substantial compliance
with the Act.' The audit
determines whether the
committee complied with
the limitations,
prohibitions and
disclosure requirements
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.

2 U.S.C. §438(b).

About the Campaign (p. 2)

Steven Reifman for Congress is the principal campaign
committee of Steven Reifman, Democratic candidate for the U.S.
House of Representatives from the state of Michigan, 9" District,
and is headquartered in Farmington Hills, Michigan. For more
information see the chart on the Campaign Organization, p.2.

Financial Activity (p. 2)
« Receipts

o Contributions From Individuals $ 83,051
o Contributions From Political 16,000
Committees
o Other Receipts 24,422
Total Receipts $ 123,473
¢ Disbursements
o Operating Expenditures $ 120,136
o Other Disbursements 3,000
Total Disbursements $ 123,136

Findings and Recommendations (p. 3)
¢ Disclosure of Disbursements (Finding 1)
¢ Disclosure of Occupation and Name of Employer (Finding 2)


Table of Contents

Part I. Background
Authority for Audit
Scope of Audit

Part II. Overview of Campaign
Campaign Organization
Overview of Financial Activity

Part III. Summaries
Findings and Recommendations

Part IV. Findings and Recommendations
Finding 1. Disclosure of Disbursements
Finding 2. Disclosure of Occupation and Name of Employer

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