FEDERAL ELECTION COMMISSION 

WASHINGTON, D.C. 20463 

STATEMENT OF VICE CHAIR ANN M. RAVEL, 

COMMISSIONER STEVEN T. WALTHER, AND 

COMMISSIONER ELLEN L. WEINTRAUB 

Audit of the Democratic Party of Illinois (All-15) 

This audit presents concerns regarding the Democratic Party of Illinois's fiiilure to keep 

monthly time-logs for payroll payments associated with its non-federal employees. We raised 

these same concerns in our Statement on the Audit of the Republican Party of Iowa (A11-24). 

See Attachment A. We continue to assert that the Act and Commission regulations require 

committees to maintain logs documenting the time that all employees spend on federal election 

activity. 

Dam AXOL M. Ravel 

Vice Chair 

Date Steven T. Walther 

Commissioner 

/o/??//^ h U//)^ 1^ • ^ 

Date I I Ellen L. Weintraub 

Commissioner-
Attachment A 

FEDERAL ELECTION COMMISSION 

WASHINGTON, D.C. 20463 

STATEMENT OF VICE CHAIR ANN M. RAVEL, COMMISSIONER STEVEN T. 

WALTHER, AND COMMISSIONER ELLEN L. WEINTRAUB 

Audit of the Republican Party of Iowa (Ail-24) 

In the Commission's audit of the Republican Party of Iowa ("RPIA"), the Audit Division, 

in consultation with the Office of General Counsel, recommended that the Conunission approve 

a finding that RPIA failed to maintain monthly time logs for $476,442 in payroll consisting of 

both payinents allocated between federal and non-federal funds and 100% non-federal funds.' 

We supported this recommendation. The Commission could not agree by the required four 

votes, however, that $141,066 of this amount, consisting of payments to employees paid solely 

out of the RPIA's 100% non-federal account, should be included in the audit finding.' We write 

to explain why we support recordkeeping requirements for non-federal employees.^ 

The purpose of the Commission's audit process is to ensure that audited conunittees are 

conducting Aeir federal activity in accordance with the Federal Election Campaign Act, as 

amended ("the Act"). Disbursements for federal activity must be reported to the Commission 

and made with funds subject to the limitations, prohibitions, and reporting requirements of the 

Act. Whether and how a state party committee may permissibly allocate the salary, wages, and 

benefits of its employees between its federal and non-federal accounts is dependent on the 

percentage of time that its employees spend on federal election activity C'FEA") or activity in 

cormection with federal elections. ^ To document this time, our regulations require that a state 

' Documents related to Conunission audits can be accessed at www.f 

' See Certification of the Audit Division Recommendation Memorandum on the Republican Party of Iowa, dated 

January 30,2014. The Commission could agree only to include $336,369 worth of payments in the recordkeeping 

finding. Because our colleagues disagreed with the Audit Division's recommendations as to $141,066 of 100% nonfederal payments in the recommended finding, the Report discusses this issue in the "Additional Issues" secfion 

rather than in the Report's "Findings." See Proposed Final Audit Report of the Commission at 10-12. 

^ This statement does not address our additional concerns regarding this committee's recordkeeping requirement for 

its contract workers. We set out those concerns separately in our Statement on the Audits of the Vermont 

Democratic Party (A11-12), Dallas County Republican Party (A11-14), Democratic Party of South Carolina 

(A11-19), and Republican Party of Iowa (A11-24), dated March 18,2014. 

* Salaries and benefits for employees who spend more than 23% of their compensated time on PEA or activities in 

connection with a federal election in a given month must be paid only from a federal account. 2 U.S.C. § 

43 l(20)(A)(iv); 11 C.F.R. § 106.7(d)(l)(ii); see 2 U.S.C. § 441i(b)(2). Salaries and benefits for employees who 

spend 23% or less of dieir time on FEA or activities in connection with a federal election must either be paid only 

from the federal account or allocated as administrative costs. 11 C.F.R. §§ 106.7(c)(1) and 106.7(d)(l)(i). 

Employees who spend none of their compensated time on FEA or activities in connection with a federal election 

may be paid entirely with funds that comply with state law. 11 C.F.R. §§ 106.7(c)(1) and 106.7(dXI)(iii). 
A11-24 (Republican Party of Iowa) 

Statement of Vice Chair Ravel, Commissioner Walther, and Commissioner Weintraub 

Page 2 of2 

party conunittee "keep a monthly log of the percentage of time each employee spends in 

cotmection with a Federal election. In the audit process, the Commission compares these logs 

against a committee's reporting of federal activity to verify that the committee used the proper 

amount of federal funds to pay for federal activity. In the absence of such documentation, Ae 

Commission has no Avay of determining whether a state party committee has paid its federal 

employees with impermissible non-federal funds. 

The Commission's regulations make clear that state party committees have an obligation 

to. maintain appropriate records for all employees. The unwillingness to require any 

documentation for expenses that a committee simply claims to be 100% non-federal severely 

limits the Commission's ability to implement the Act. This approach is both contrary to the 

plain language of the recordkeeping requirements in the Commission's regulations and creates a 

perverse incentive for state party committees to avoid keeping records of their activities. On the 

other hand, requiring committees to keep logs of their employees' federal activity—even when 

the percentage of federal activity is zero—provides a strong prophylactic reminder to committees 

to monitor their employees' federal and non-federal activity to ensure that all employees who 

spend any time on federal activity are paid with the appropriate ^ount of federal fluids. Given 

this benefit, it is not overly burdensome for committees to maintain regular logs for their 

employees who have spent no time on federal activity. 

There is no jurisdictional question here; the Commission is empowered to review records 

of both state and federal spending for federally-registered political committees.^ Our ability to 

comprehensively audit committees that influence federal elections is central to the Commission's 

mission. 

Date jCaa M. Ravel 

Vice Chair 

Date Steven T. Walther 

Commissioner 

^1 ^ 1*^ Date ' Ellen L. Weintraub 

Commissioner 

^ 11 C.F.R. § 106.7(d)(1) (emphasis added). 

' 5ee 2 U.S.C.§ 438(b).