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FEDERAL ELECTION COMMISSION

\\'A5HI~G10""'. 0 [ 204b3

A82-S

July 28, 1983

MEMORANDUM

TO:

FROM:

SUBJECT:

FRED EILAND

PRESS OFFICER

BOB COSTA

PUBLIC ISSUA CE OF FINAL AUDIT REPORT - LIFE AMENDMENT POLITICAL ACTION COMMITTEE, INC.

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Attached please find a copy of the final audit report of

Life Amendment Political Action Committee, Inc. which was

approved by the Commission on June 16, 1983.

Informational copies of the report have been received by

all parties involved and the report may be released to the

public •

Attachment as stated

cc: FEC Library

RAD ~blic Record
FEDERAL ElEC110N COMMISSION

A82-5

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REPORT OF THE AUDIT DIVISION

ON THE

LIFE AMENDMENT POLITIChL ACTION CO~ITTEE,' INC.

I. Background

A. Overview

This report is based on an audit of the Life Amendment

Political Action Committee, Inc. ("the Corn~ittee"), undertaken by

the ~udit Division of the Federal Election Corr~ission in

accordance with the Commission's audit policy to cetermine ~hether there has been cOffioliance with the ~:ovi5ions of the

Feceral Election Campaign hct of 1971, as affienaed ("the Act").

The audit ~as concucted pursuant to Section ~3E(b) of Title 2 of

the United States Code ~hich states, in part, that the Commission ~cy concuct audits and field investigations of any political co~mittee requirec to file a report unoer section 43' of this

:itle. Prior to conducting any audit under this subsection, the Co~~ission shall perforrr an internal revie~ of reports filed by

;€lectec committees to ceterrnine if the repo:ts filec by a

particular cornffiittee meet the threshold re~uirements for

substantial compliance with the Act.

The Co~~ittee registerec with the :eceral Election

Commission on ~overnber 7, 1977. The Com~ittee maintains its

headquarters in Garrisonville, Virginia.

The auoit covered the period Jan~ary~, 1981, through

October 21, 1582. The Co~~ittee reported 2 cash balance on

January 1; 1981 of $~,~12.00; total receipts for the period of

$351,606.35; total disbursements for the period of $356,5'5.43

and a cash balance on Oc~o~er 21, 1982 of $2,337.70. 1/

This audit report is based on aoc~=ents and work papers ~~ich sUFport each of its factual state~en~s. They form part of

the record upon ~tich the Com~i5sion basec its decisions on the ~atters in tte report ana ~eIe availa~le to the Comnissioners and

cppropriate staff fo~ revie~.

1/ The:e are apparent a:ithnetical ci5cre~a~~i~s ~ithin the

Co~~ittee'5 reported totals.
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B. Key Personnel

Th~ Treasurer of the Committee dc:ing the period

covered by the audit was Mr. Paul A. Bro~n.

c. Scope

The audit included such tests as verification of total

reported receipts and disbursements and incivicual transactions:

review of required supporting documentation; analysis of

Committee debts and obligations; and such other audit procedures

as deemed necessary under the circumstances. Although the

contribution records provided by the Co~rnittee substantially met

the recordkeeping requirements of 2 U.S.C. 432(c) and 11 C.F.R.

l02.9(a), they appeared to be incomplete, thus only a partial v~rification of individual transactions ~a5 performed (see

Finding II.A. below).

11. Aucit Fincinqs and Recommendations

A. It€~izaticn of Incividual Contri~~tions

Section 43~(b) (3) of Title 2 of :he United States Code

requires a political cOffi~ittee to disclose the ioentification of

each person (other than a political cOmmittee) ~ho makes a

contribution to the reporting committee ~hich in the aggregate

Exceecs S200 ~ithin the calendar year, togethe: with the date and

amount of any such contribution.

A revie~ of the Committee's cont:ib~:ion records

incicatec that there were 39 contributions in excess of, or

aggresating in excess of $200, which were ~ot initially itemized

on Co~mittee cisclosure reports. These co~tri~utions totalec

$4,769.00 anc'represented 67.2% of the nu~~e= and '3.6% of the

dollar value of incivicual contributions rfcuirinc itemization. Co~~:ttee officials stated that these offiissio~s were due to the

fact that the Committee discontinued the cc~?~:er processing of

contributions for a portion of the perioc co~ered by the audit.

It should be noted that subs€cue~t to the commencement

of audit field~ork, the Committee performe= a ~anual aggregation

of certain co~tributions and included on t~e 1982 year-end report

27 co~tributions which were previously not it~~izec for calendar

year 1982. Our review of this report re~ealec that 12 (of the

39) contrib~tions, totaling $1,693.50, ha~e yet to be itemized.

hs noted in Section I.C., the sCO?~ of the audit was ~ocifiec cue to the u~a~ailabilitv of recc:c5 necessarv to verifv

certain receipt tra~sactions. Briefly, tte r~cords pr~sented fo~ audit review consisted of:
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Two computerized contribution listings which included

contributions received from ince~tion (1978) through

February 1983. However, one of the listings did not

include contributions received from July 1981 through December 31, 1981.

Nine containers of Committee so~rce documents

(contributor reply envelopes) ~hich appeared to

represent contributions receivec during 1981, 1982,

and 1983.

Several tests performed with respect to the above

mentioned source documents indicated that they appeared to be

incomplete both in dollar value and quantity, therefore the Audit

staff could not verify that all Committee receipts had been

properly discloseo. Accordingly, it is su~gested that the

Committee devise ana implement procedures for contribution record

maintenance which will result in the proper accounting and

disclosure of contributions.

It was recommended in the interim audit report that the

Committee file amenaments itemizing the re~aining 12 , co~tributions .

..' .... On April 27, 1983, the Committee -filed a~endments to

its disclosure reports itemizing the cont=ibutions as required.

Recommencation

Basec upon the action of the Committee, the Audit staff recomme~cs no further action on this matter.

B. Contributions To/From Other Polit1cal Co~~ittees

. Sections ~34 (b) (3) (D) ana (6) (E) (i) '·of Title 2 of the D~itec States Cooe require the cisclosure of th~ icentification

of each affiliated committee which makes a transfe~ to the

reporting co~~ittee'curing the reportin~ p:rioo, a~a the name and

aocress of each political committee whict has receivec a

contribution from the reporting committee together with the date a~d amount of any such contribution.

During the pre-audit review, it ~as notec that the Cc~~ittee did not ite~ize two contributic~s to political co~mittees totaling $525.00 ana one cont!ibutic~ apparently

receivec fro~ an affiliated com~itte€. tc~alin9 $3,000.00. A r€vie~ c! the Co~~ittee's cancelled checks durins the audit fielc~ork confirweo that t~o contributic~sr totaling $525.00 were ~~oe. However, the Audit staff ~as unab:~ tc'~erify the Cc~~itt€e's receipt of the $3,000.00 cont:ibution since the Co~mitt€e cid not ~a:ntain certain contributor records.
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. .On April 4 and 27, 1983, the cc~~ittee filed amendments

disclosing the above transactions.

Recommendation

Based on the above we recommend no fu:ther action.

c. Matter Referred to the Office c: General Counsel

A certain matter noted during th~ audit was referred to

the Commission's Office of General Counsel on June 16, 1983.

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