Final Audit Report of the 

Commission on the Caesars 

Entertainment Corporation 

Political Action Committee 

(January 1, 2011 - December 31, 2012) 

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 

(die Act). The 

Commission generally 

conducts such audits 

when a committee 

appears not to have met 

the threshold 

requirements for 

substantial compliance 

with the Act.' TTie audit 

determines whether the 

committee complied with 

the limitations, 

prohibitions and 

disclosure requirements 

of the Act. 

About the Committee (p. 2) 

The Caesars Entertainment Corporation Political Action 

Committee is a non-party separate segregated fund of Caesars 

Entertainment Corporation headquartered in Las Vegas, Nevada. 

For more information, see the chart on the Committee 

Organization, p. 2. 

Financial Activity (p. 2) 

• Receipts 

o Contributions from Individuals 

Total Receipts 

Disbursements 

o Contributions to Federal 

Candidates/Other Committees 

o Operating Expenditures 

o Other Disbursements 

Total Disbursements 

Commission Finding (p. 3) 

Misstatement of Financial Activity 

$ 328,196 

$ 328,196 

$ 308,430 

18,909 

20,126 

$ 347,465 

Future Action 

The Commission may 

initiate an enforcement 

action, at a later time, 

with respect to the matter 

discussed in this report. 

2 U.S.C. §438(b). 
Audit Report of the 

Commission on 

the Caesars Entertainment 

Corporation Political Action 

Committee 

(January 1, 2011 - December 31, 2012) 
Table of Contents 

Page 

Part I. Background 

Authority for Audit 1 

Scope of Audit 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 

Misstatement of Financial Activity 4 
Part I 

Background 

Authority for Audit 

This report is based on an audit of the Caesars Entertainment Corporation Political 

Action Conunittee (CECPAC)^, undertaken by the Audit Division of the Federal Election 

Commission (the Coinmission) 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 Conunission 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 Conunission must perform an intemal 

review of reports filed by selected committees to determine whether 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: 

1. the consistency between reported figures and bank records; 

2. the disclosure of individual contributors' occupation and name of employer; and 

3. other committee operations necessary to the review. 

Audit Hearing 

CECPAC declined the opportunity for a hearing before the Conunission on the matter 

presented in this report. 

^ The committee's name during the audit period was Caesars Entertainment Political Action Committee. It 

was changed on June 4,2013. 
Part II 

Overview of Committee 

Committee Organization 

Important Dates 

• Date of Registration December 11,1989 

• Audit Coverage January 1,2011 - December 31,2012 

Headquarters Las Vegas, Nevada 

Bank Information 

• Bank Depositories One 

• Bank Accounts One Federal 

Treasurer 

• Treasurer When Audit Was Conducted Meredith Hartstem 

• Treasurer During Period Covered by Audit Meredith Hartstem 

Management Information 

• Attended Commission Campaign Finance 

Seminar 

Yes 

• Who Handled Accounting and 

Recordkeeping Tasks 

Paid Staff 

Overview of Financial Activity 

(Audited Amounts) 

Cash-on-hand @ January 1,2011 $ 132,248 

Receipts 

o Contributions from Individuals 328,196 

Total Receipts $ 328,196 

Disbursements 

o Contributions to Federal Candidates/Other 

Coinmittees 

308,430 

o Operating Expenditures 18,909 

o Other Disbursements 20,126 

Total Disbursements $ 347,465 

Cash-on-hand December 31,2012 $ 112,979 
Part III 

Summary 

Commission Finding 

Misstatement of Financial Activity 

A comparison of CECPAC's bank activity with its most recent amended reports prior 

to the audit revealed material misstatements in both 2011 and 2012. In addition, a 

comparison of CECPAC's bank activity with its original reports for 2011 and 2012 

also revealed material misstatements. 

Following the audit exit conference, CECPAC amended its reports to materially 

correct the misstated financial activity. In response to the Interim Audit Report 

recommendations, CECPAC stated that it would not submit an additional response 

since it had already filed amended reports that materially corrected the misstatements 

in response to the audit. 

The Commission approved a finding tiiat CECPAC misstated its financial activity for 

calendar years 2011 and 2012 and that CECPAC materially misstated its original 

reports. (For more detail, see p. 4.) 
Part IV 

Commission Finding 

Misstatement of Financial Activity 

Summary 

A comparison of CECPAC's bank activity with its most recent amended reports prior 

to the audit revealed material misstatements in both 2011 and 2012. In addition, a 

comparison of CECPAC's bank activity with its original reports for 2011 and 2012 

also revealed material misstatements. 

Following the audit exit conference, CECPAC amended its reports to materially 

correct the misstated financial activity. In response to the Interim Audit Report 

recommendations, CECPAC stated that it would not submit an additional response 

since it had already filed amended reports that materially corrected the misstatements 

in response to the audit. 

The Commission approved a finding that CECPAC misstated its financial activity for 

calendar years 2011 and 2012 and that CECPAC materially misstated its original 

reports. 

Legal Standard 

Contents of Reports. Each report must disclose: 

• the amount of cash-on-hand at the begiiming and end of the reporting period; 

• the total amount of receipts for the reporting period and for the calendar year; 

• the total amount of disbursements for the reporting period and for the calendar 

year; and 

• certain transactions that require itemization on Schedule A (Itemized 

Receipts) or Schedule B (Itemized Disbursements). 2 U.S.C. §434(b) (1), (2), 

(3), (4) and (5). 

Facts and Analysis 

A. Misstatement of Financial Activity - Most Recent Reports Filed Prior to the 

Audit 

1. Facts 

The Audit staff reconciled CECPAC's reported financial activity with its bank 

records for calendar years 2011 and 2012. The follov^ng charts outline the 

discrepancies between CECPAC's disclosure reports and its bank records. 

Succeeding paragraphs explain why the discrepancies occurred. 
2011 Committee Activity 

Reported Bank Records Discrepancy 

Beginning Cash Balance @ 

January 1,2011 

$93,767 $132,248 $38,481 

Understated 

Receipts $155,900 $162,601 $6,701 

Understated 

Disbursements $181,258 $181,443 $185 

Understated 

Ending Cash Balance 

(® December 31,2011 

$68,409 $113,406 $44,997 

Understated 

The beginning cash balance was understated by $38,481 and the discrepancy is 

unexplained, but it likely resulted from prior period discrepancies. 

The $6,701 understatement of receipts was a result of contributions from 

individuals, totaling $6,681, that were not reported and an unexplained difference 

of $20. 

The $44,997 understatement ofthe ending cash balance was a result of the 

reporting discrepancies described above as well as the $185 understatement of 

disbursements. 

2012 Committee Activity 

Reported Bank Records Discrepancy 

Begiiming Cash Balance @ 

January 1,2012 

$68,409 $113,406 $44,997 

Understated 

Receipts $155,600 $165,595 $9,995 

Understated 

Disbursements $143,757 $166,022 $22,265 

Understated 

Ending Cash Balance 

@ December 31,2012 

$80,252 $112,979 $32,727 

Understated 

The understatement of receipts was the result of contributions from individuals, 

totaling $9,995, that were not reported. 

The $22,265 net understatement of disbursements was a result of contributions to 

federal candidates/other committees, totaling $22,500, that were not reported, and 

an unexplained difference of ($235). 

The $32,727 understatement of die ending cash balance was a result of the 

reporting discrepancies noted above. 

CECPAC filed amended repbrts on February 20 and 21,2013, subsequent to the 

Audit Notification Letter dated December 4,2012. These reports disclosed 

previously unreported contributions from individuals.totaling $9,995. However, 
die amended reports disclosed only $5,000 of the previously unreported 

contributions to federal candidates/other committees totaling $22,500. Thus, the 

disbursements remained materially misstated for calendar year 2012. 

2. Interim Audit Report and Audit Division Recommendation 

The Audit staff discussed die misstatements for 2011 and 2012 widi CECPAC's 

representative during the exit conference and provided copies of relevant work 

papers detailing the misstatements. In response, CECPAC filed amended reports 

that materially corrected the misstatements. 

The Interim Audit Report recommended that CECPAC provide any additional 

comments it considered necessary with respect to this matter. 

3. Committee Response to Interim Audit Report 

In response to the Interim Audit Report reconunendation, CECPAC stated that it 

would not submit an additional response since it had already filed amended 

reports that materially corrected the misstatements. 

4. Draft Final Audit Report 

The Draft Final Audit Report acknowledged diat CECPAC amended its reports 

which materially corrected the misstatements. 

5. Committee Response to the Draft Final Audit Report 

CECPAC offered no additional coinments in its response to the Draft Final Audit 

Report. 

B. Misstatement of Financial Activity - Original Reports Filed 

1. Facts 

In addition to examining CECPAC's most recent reports filed prior to the audit 

notification, the Audit staff compared CECPAC's originally filed reports with its 

bank records. The purpose of this additional reconciliation was to identify the 

degree to which CECPAC had misstated its original filings. 

The Audit staff calculated that CECPAC understated the sum of the reported 

receipts on the original reports filed by $151,950 and the sum of the reported 

disbursements on the original reports filed by $91,495 over the two-year period 

(2011 and 2012). These figures include the $6,701 understatement of receipts 

from 2011 and die $9,995 and $22,265 understatement ofreceipts and 

disbursements, respectively, from 2012 discussed in Section A above 

(Misstatement of Financial Activity - Most Recent Reports Filed Prior to the 

Audit)^ 

3 The amended reports did not correct all the misstated activity identified by the Audit staff in its 

review of CECPAC's originally filed reports. However, in response to this audit, CECPAC filed 

amendments to materially correct the misstated activity identified by the Audit staff. 
2. Interim Audit Report and Audit Division Recommendation 

The Audit staff discussed the understatement of receipts and disbursements on its 

original reports filed with the CECPAC representative during the exit conference 

and provided copies of relevant work papers detailing the receipts and 

disbursements not reported. In response, the CECPAC representative stated that 

the management was not aware that the original reports contained only partially 

reported receipts and/or disbursements. As a result, CECPAC management 

indicated it would implement more rigorous intemal reviews as well as periodic 

financial reconciliations. 

The Interim Audit Report recommended that CECPAC provide any additional 

comments it considered necessary with respect to the misstatement of activity on 

its original reports. 

3. Committee Response to Interim Audit Report 

In response to the Interim Audit Report reconunendation, CECPAC stated that it 

would not submit an additional response with respect to the misstatements 

identified on its original reports. 

4. Draft Final Audit Report 

The Draft Final Audit Report acknowledged that CECPAC amended its reports, 

which materially corrected the misstatements. 

5. Committee Response to the Draft Final Audit Report 

CECPAC offered no additional comments in its response to the Draft Final Audit 

Report. 

Commission Conclusion 

On December 5,2013, the Coinmission considered the Audit Division 

Reconunendation Memorandum in which the Audit staff recommended that the 

Commission adopt a finding that CECPAC misstated its financial activity for 

calendar years 2011 and 2012 and that CECPAC misstated its original reports. 

The Commission approved the Audit staffs recommendation.