ASCAPAC Findings and Recommendations

Finding 1. Misstatement of Financial Activity

During audit fieldwork, a comparison of ASCAPAC’s reported activity with 

bank records revealed a misstatement of receipts for calendar year 2015. 

ASCAPAC understated its receipts by $16,834. The Audit staff recommends 

that ASCAPAC amend its disclosure reports to correct the misstatement. (For 

more detail, see p. 4.)

Response: Please see attached detailed reconciliation report (ASCAPAC 

Interim Finding 1 Reconciliation). Receipts listed in this finding were 

inadvertent deposits into the wrong bank account. The receipts were not PAC 

contributions or PAC related. The committee has accounted for these

inadvertent deposits as noted in Finding 1 and will file the appropriate 

amendments.

Finding 2. Receipt of Prohibited Contributions

During audit fieldwork, a review of contributions from individuals revealed that 

ASCAPAC received 102 contributions totaling $93,023 from apparent 

prohibited sources. The Audit staff recommends, absent evidence that these 

contributions were made with permissible funds, ASCAPAC refund these 

contributions to the contributors or disgorge the contributions to a government 

agency or eligible charitable organization. (For more detail, see p. 6.)

Response: After reviewing the 102 contributions totaling $93,023, ASCAPAC 

has conducted an ongoing, exhaustive effort to collect the tax status of all 

contributions in question. As of December 11, 2018, of the $93,023:

1. 46% was identified as eligible, totaling $43,121. (See attachment: 

ASCAPAC Interim Finding 2 Donor Responses Eligible)

a. $37,621 is allocated to eligible LLCs who have a corporate 

partner. As allowed by the law, the contribution is attributed to 

the partners of the LLC Partnership and not the corporation.

b. $5,500 is allocated to LLC Partnerships with no corporate 

partners.

2. 38% was identified as ineligible, totaling $35,271 (this total includes the 

$16,412 from corporations). ASCAPAC will refund these contributions 

or administer the funds to an eligible charity. (See attachment:

ASCAPAC Interim Finding 2 Donors Responses Ineligible)

3. 16% was nonresponsive, totaling $14,631. (See attachment: ASCAPAC 

Interim Finding 2 No Donor Responses)

a. ASCAPAC reached out to these contributors more than five 

times to obtain the requested information. 
The committee reasonably expects the ratio of eligible to ineligible 

contributions to hold true for the non-responsive contributors, which totals 

$8,047 (55% of $14,631). ASCAPAC will refund these contributions or

administer the funds to an eligible charity.

Finding 3. Recordkeeping for Receipts

During Audit fieldwork, the Audit staff reviewed records provided by 

ASCAPAC and determined that ASCAPAC did not maintain adequate 

documentation for receipts totaling $67,108. Of this amount, ASCAPAC did 

not maintain check copies for contributions totaling $6,378 and did not 

maintain the attribution information for each partner, for contributions totaling 

$60,730. The Audit staff recommends that ASCAPAC provide the missing 

records and submit any comments it deems necessary. (For more detail, see p.

9.)

Response: ASCAPAC has conducted an exhaustive effort to collect the information to the 

extent possible pursuant to this Finding and Finding 4 and will file corrections via 

amendments accordingly. In addition, the committee has updated its policies and

procedures to ensure proper record keeping in the future.

Finding 4. Disclosure of Receipts

During audit fieldwork, the Audit staff identified 154 contributions totaling 

$197,571 that were missing the required disclosure information. The Audit staff 

recommends that ASCAPAC amend its disclosure reports to correctly disclose 

these transactions on Schedule A (Itemized Receipts) and provide any other 

comments it deems necessary. (For more detail, see p. 11.)

Response: ASCAPAC has conducted an exhaustive effort to collect the information and 

has enclosed additional records that have been collected since the exit report.

1. Of the 78 contributions ‘disclosed with a name other than the one on the 

check/credit card’:

1. 25% (16 contributions) were credit card contributions found to be 

correctly reported by ASCAPAC. Upon an online submission of a 

contribution, the individual cardholder of a company credit card, must 

provide their name for the transaction. ASCAPAC has obtained written 

confirmation (enclosed as ASCAPAC Interim Finding 4 Donor 

Responses) that the reported name accurately reflects the correct 

contributor.

2. 14% (9 contributions) were contributions that ASCAPAC reported with 

different wording (i.e. Reported as Pinnacle III instead of Pinnacle III, 

LLC.) ASCAPAC will amend these contributions to reflect the exact name 

on the checks.
3. 20% (13 contributions) were identified by ASCAPAC as ineligible 

contributions that will be refunded or administered to an eligible charity.

The records reported for partnership attribution will be updated in filed amendments. In 

addition, the committee has updated its policies and procedures to ensure proper record 

keeping in the future.

Finding 5. Untimely Deposit of Receipts

During audit fieldwork, the Audit staff determined that ASCAPAC did not 

deposit 106 contributions totaling $84,333 within 10 days of receipt. The 

Audit staff recommends that ASCAPAC provide evidence demonstrating that 

the contributions in question were deposited timely or submit any additional 

comments it deems relevant to this matter. (For more detail, see p. 12.)

Response:

1. ASCAPAC’s policy is to deposit all checks within 10 days of 

receipts, normally on the day of receipt.

2. ASCAPAC has worked with its credit card processing vendor to 

improve the timeliness of the vendor’s transfer of funds to 

ASCAPAC’s account.

ASCAPAC has implemented a procedure that all PAC receipts are date 

stamped upon receipt.

Conclusion

ASCAPAC continues the effort to collect all missing information to correctly report 

contributions through amendments. At this time, we have submitted all the corrections 

outlined above to our compliance and reporting vendor and the process of filing 

amendments will begin immediately.