Preliminary Audit Report 

of the Audit Division on 

Jill Stein for President 

(October 11, 2011 - November 30, 2013) 

Why the Audit 

Was Done 

Federal law requires 

the Commissipn to 

audit every political 

committee established 

by a candidate who 

receives public funds 

for the primary 

campaign.' The audit 

determines whether the 

candidate was entitled 

to all of the matching 

funds received, 

whether the campaign 

used the matching 

funds in accordance 

with the law, whether 

the candidate is entitled 

to additional matching 

funds, and whether the 

campaign otherwise 

complied with the 

limitations, 

prohibitions, and 

disclosure requirements 

of the election law. 

Future Action 

The Commission may 

initiate an enforcement 

action, at a later time, 

with respect to any of 

the matters discussed in 

this report. 

About the Campaign (p. 2) 

Jill Stein for President is the principal campaign committee for Jill 

Stein, a candidate for the Green Party nomination for the office of 

President of the United States. The Committee is headquartered in 

Lexington, Massachusetts. For more information, see the chart on the 

Campaign Organization, p. 2. 

Financial Activity (p. 3) 

• Receipts 

o Contributions from Individuals 

o Matching Funds Received 

o Loans Received from the Candidate 

o Contributions from Political Parties 

o Offsets tp Operating Expenditures 

Total Receipts 

• Disbursements 

o Operating Expenditures 

o Fundraising Disbursements 

o Loan Repayments 

o Contribution Refunds 

Total Disbursements 

$ 817,317 

372,130 

64,000 

4,235 

1,902 

$ 1,259,584 

$ 1,069,758 

26,803 

20,000 

1 445 

$ 1,118!O06 

Findings and Recommendations (p. 4) 

• Net Outstanding Campaign Obligations (Finding 1) 

• Misstatement of Financial Activity (Finding 2) 

• Disclosure of Debts and Obligations (Finding 3) 

• Reporting of Receipts (Finding 4) 

• Reporting of Expenditures (Finding 5) 

• Itemization of Candidate Loans (Finding 6) 

26 U.S.C. §9038(a). 
Preliminary Audit Report 

of the Audit Division on 

Jill Stein for President 

(October 11, 2011 - November 30, 2013) 
Table of Contents 

Page 

Part I. Background 

Authority for Audit . 1 

Scope of Audit 1 

Inventory of Campaign Records 1 

Part II. Overview of Campaign 

Campaign Organization 2 

Overview of Financial Activity 3 

Part III. Summaries 

Findings and Recommendations 4 

Part IV. Findings and Recommendations 

Finding 1. Net Outstanding Campaign Obligations 6 

Finding 2. Misstatement of Financial Activity 9 

Findings. Disclosure of Debts and Obligations 11 

Finding 4. Reporting of Receipts 12 

Findings. Reporting of Expenditures 14 

Finding 6. Itemization of Candidate Loans 16 
Part I 

Background 

Authority for Audit 

This report is based on an audit of Jill Stein for President (JSFP), undertaken by the Audit 

Division of the Federal Election Commission (the Commission) as mandated by Section 

9038(a) of Title 26 of the United States Code. That section states, "After each matching 

payment period, the Commission shall conduct a thorough examination and audit of the 

qualified campaign expenses of every candidate and his authorized committees who 

received [matching] payments under section 9037." Also, Section 9039(b) of the United 

States Code and Section 9038.1(a)(2) of the Commission's Regulations state that the 

Commission may conduct other examinations and audits from time to time as it deems 

necessary. 

Scope of Audit 

This Audit examined: 

1. the campaign's compliance with limitations for contributions and loans; 

2. the campaign's compliance with the limitations for candidate contributions and loans; 

3. the campaign's compliance with the prohibition on accepting prohibited contributions; 

4. the disclosure of contributions and loans received; 

5. the disclosure of disbursements, debts and obligations; 

6. the consistency between reported figures and bank records; 

7. the accuracy of the Statement of Net Outstanding Campaign Obligations; 

8. the campaign's compliance with spending limits 

9. the completeness of records; and 

10. other campaign operations necessary to the review. 

Inventory of Campaign Records 

The Audit staff routinely conducts an inventory of campaign records before it begins 

audit fieldwork. JSFP's records were materially complete and fieldwork commenced 

thereafter. 
Part II 

Overview of Campaign 

Campaign Organization 

Important Dates 

• Date of Registration November 14,2011 

• Eligibility Period^ August 22,2012 - September 6,2012 

• Audit Coverage^ October 11,2011 - November 30,2013 

Headquarters Lexington, Massachusetts 

Bank Information 

• Bank Depositories Two 

• Bank Accounts Three primaiy accounts and one general account. 

Treasurer 

• Treasurer When Audit Was Conducted James Moran 

. • Treasurer During Period Covered by Audit James Moran: October 23,2012 - current 

John Andrews: July 6,2012 - October 22,2012 

John Portelli: November 14,2011 - July 5.2012 

Management Information 

• Attended Commission Campaign Finance 

Seminar 

No 

• Who Handled Accounting and 

Recordkeeping Tasks 

Paid Staff 

On July 16,2012, the Candidate submitted a signed letter to the Commission seeking to become eligible to receive 

Presidential primaiy matching fiinds and agreeing that she and her authorized committee would comply with the 

conditions set forth in 11 CFR §9033.1(b). A threshold submission was submitted on July 16,2012, and the 

Commission certified the Candidate as eligible to receive matching liinds on August 22,2012. The period during 

which the Candidate was eligible for matching fonds ended on September 6,2012, the date of ineligibility. 

The Audit staff conducted limited reviews of receipts and expenditures after December 31,2012, to determine 

whether the Candidate was eligible to receive additional matching funds. 
Overview of Financial Activity 

(Audited Amounts) 

Cash-on-hand ® October 11,2011 SO 

Receipts 

o Contributions from Individuals* 817,317 

o Matching Funds Received^ 372,130 

o Loans Received from the Candidate 64,000 

o Contributions from Political Parties 4,235 

o Offsets to Operating Expenditures 1,902 

Total Receipts S 1,259,584 

Disbursements 

o Operating Expenditures 1,069,758 

o Fundraising Disbursements 26,803 

o Loan Repayments 20,000 

o Contribution Refunds 1,445 

Total Disbursements S 1,118,006 

Cash-on-hand @ December 31,2012 $ 141,578 

* JSFP received approximately 8,400 contributions from 6,000 individuals. 

^ As of the Candidate's date of ineligibility, September 6,2012, JSFP had received matching funds totaling 

S100,000. JSFP received an additional $272,130 by December 3,2012, for a total of $372,130. 
Part III 

Summaries 

Findings and Recommendations 

Finding 1. Net Outstanding Campaign Obligations 

The Audit staffs review of JSFP's financial activity through November 30,2013, and 

estimated winding down costs indicated that the Candidate did not receive matching fund 

payments in excess of her entitlement. (For more detail, see p. 6.) 

Finding 2. Misstatement of Financial Activity 

During audit fieldwork, a comparison of JSFP's reported financial activity with its bank 

records revealed that, for 2012, JFSP understated its reported receipts and ending cashon-hand by $211,949, and $106,128, respectively; and overstated disbursements by 

$13,850. Subsequent to the audit notification letter JSFP filed amendments; however, 

receipts, disbursements and ending cash-on-hand remain understated! Additional 

amended reports filed subsequent to the end of fieldwork exit conference materially 

corrected the misstatement errors. The Audit staff recommends that JSFP provide any 

additional information or written comments that it considers relevant to this matter. 

(For more detail, see p. 9.) 

Finding 3. Disclosure of Debts and Obligations 

During audit fieldwork, the Audit staff identified debts totaling $78,043 that were not 

disclosed on Schedule D-P (Debts and Obligations) as required. Amendments filed 

subsequent to the audit notification letter disclosed some of these debts. The Audit staff 

recommends that JSFP amend its disclosure reports to properly disclose the remaining 

$4,501 in debts. (For more detail, see p. 11.) 

Finding 4. Reporting of Receipts 

During audit fieldwork, the Audit staffs review identified contributions from individuals 

totaling $23,071 that JSFP failed to itemize. In addition, receipts totaling $57,622 were not 

adequately disclosed. For most of these contributions, the election cycle-to-date total 

disclosed on Schedules A-P was incorrect. Amended reports filed subsequent to the audit 

notification letter materially corrected both the itemization and disclosure errors. The 

Audit staff recommends JSFP provide any additional information or written comments that 

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

Finding 5. Reporting of Expenditures 

During audit fieldwork, the Audit staffs review identified expenditures totaling $49,797 

that JSFP failed to itemize. In addition, expenditures totaling $314,673 were not 

adequately disclosed. For most of these expenditures, the purpose was not disclosed or 

inadequately disclosed. Amended reports filed subsequent to the audit notification letter 

materially corrected both the itemization and disclosure errors. The Audit staff 
recommends JSFP provide any additional information or written comments that it 

considers relevant to this matter. (For ihore detail, see p. 14.) 

Finding 6. Itemization of Candidate Loans 

The Audit staffs bank reconciliation for 2012 (See Finding 2) identified loans from the 

Candidate totaling $40,000 that had not been disclosed by JSFP. Amended reports filed 

subsequent to the audit notification letter materially corrected both the. itemization and 

disclosure errors. The Audit staff recommends JSFP provide any additional information 

or written comments that it considers relevant to this matter. (For more detail, see p. 16.) 
6 

Part IV 

Findings and Recommendations 

Finding 1. Net Outstanding Campaign Obligations 

Summary 

The Audit staffs review of JSFP's financial activity through November 30,2013, and 

estimated winding down costs indicated that the Candidate did not receive matching fund 

payments in excess of her entitlement. 

Legal Standard 

A. Net Outstanding Campaign Obligations (NOCO). Within IS days after the 

candidate's date of ineligibility (see definition below), the candidate must submit a 

statement of "net outstanding campaign obligations." This statement must contain, 

among other things: 

• The total of all committee assets including cash-on-hand, amounts owed to the 

committee and capital assets listed at their fair market value; 

• The total of all outstanding obligations for qualified campaign expenses; and 

• An estimate of necessary winding-down costs. 11 CFR §9034.S(a). 

B. Date of Ineligibility. The date of ineligibility is whichever of the following dates 

pccurs first: 

• The day on which the candidate ceases to be active in more than one state; 

• The 30th day following the second consecutive primary in which the candidate 

receives less than 10 percent of the popular vote; 

• The end of the matching payment period, which is generally the day when the 

party nominates its candidate for the general election; or 

• In the case of a candidate whose party does not make its selection at a national 

convention, the last day of the last national convention held by a major party in 

the calendar year. 11 CFR §§9032.6 and 9033.S. 

C. Qualified Campaign Expense. Each of the following expenses is a qualified 

campaign expense. 

• An expense that is: 

o Incurred by or on behalf of the candidate (or his or her campaign) during the 

period beginning on the day the individual becomes a candidate and 

continuing through the last day of the candidate's eligibility under 11 CFR 

§9033.5; 

o Made in connection with the candidate's campaign for nomination; and 

o Not incurred or paid in violation of any federal law or the law of the state 

where the expense was incurred or paid. 11 CFR §9032.9. 

• An expense incurred for the purpose of determining whether an individual should 

become a candidate, if that individual subsequently becomes a candidate, 

regardless of when that expense is paid. 11 CFR §9034.4. 
• An expense associated with winding down the campaign and terminating political 

activity. 11 CFR §9034.4(a)(3). 

D. Entitlement to Matching Payments after Date of Ineligibility. If, on the date of 

ineligibility (see above), a candidate has net outstanding campaign obligations as defined 

under 11 CFR §9034.5, that candidate may continue to receive matching payments 

provided that he or she still has net outstanding campaign debts on the day when the 

matching payments are made. 11 CFR §9034.1 (b). 

E. Winding Down Costs. A primary election candidate who does not run in the general 

election may receive and use matching funds after notifying the Commission in writing 

of the candidate's withdrawal from the campaign for nomination or after the date of the 

party's nominating convention, if the candidate has not withdrawn before the convention. 

A primary election candidate who runs in the general election must wait until 31 days 

after the general election before using any matching funds for winding down costs, 

regardless of whether the candidate receives matching funds for the general election. 

11 CFR §9034.11(d). 

Facts and Anal3rsis 

A. Facts 

The Candidate's date of ineligibility (DOI) was September 6,2012. The Audit staff 

reviewed JSFP's financial activity through November 30,2013, analyzed estimated 

winding down costs and prepared the Statement of Net Outstanding Campaign 

Obligations that appears on the next page. 
Jill Stein for President 

Statement of Net Outstanding Campaign Obligations 

As of September 6,2012 

Prepared November 30,2013 

Assets 

Cash in Bank $ 57,302 

Accounts Receivable 31.443 

Total Assets $ 88,745 

Liabilities 

Accounts Payable for Qualified Campaign Expenses at 9/6/12 $ 307,500 

Loans Payable to Candidate 44,000^ [a] 

Winding Down Costs: 

Actual Winding Down Expenses Paid (12/7/12 - 11/30/13) 85,487 [b] 

Estimated Winding Down Costs (12/1/13 - 6/30/14) 104.650 M 

Total Liabilities 541.637 

Net Outstanding Campaign Obligations (Deficit) as of September 6,2012 S (452.8921 

[a] Loans payable at DOI. 

[b] The Genera! election was November 6,2012. The winding down period begins 31 days after the 

General election on December 7,2012. 

[c] Estimated winding down costs will be compared to actual winding down costs and adjusted 

accordingly. 

Shown below are adjustments for funds received after the Candidate's DOI on September 

6,2012 through December 3,2012, the date JSFP received its last matching fund 

payment. 

Net Outstanding Campaign Obligations (Deficit) as of 

September 6,2012 

($452,892) 

Less: Contributions Received (September 7,2012 to 

December 3,2012) 

98,753 

Less: Matching Funds Received September 7,2012 thru 

December 3, 2012 

272,130 

Remaining Net Outstanding Campaign Obligations (Deficit) 

as of December 3,2012 

$ (82,009) 

As presented above, JSFP has not received matching fund payments in excess of its 

entitlement. 

' This total represents all loans payable at DOI. Loan repayments of $20,000 each were paid on 

September 7,2012, and March 20,2013, totaling $40,000. The outstanding balance due on the loan 

is $4,000. 
The Audit staff presented a preliminary NOCO statement and related work papers to the 

JSFP representatives at the exit conference. After the exit conference, the representatives 

provided additional documentation as requested to update the NOCO statement. 

B. Preliminary Audit Report Recommendation 

The Audit staff recommends that, within 60 calendar days of service of this report, JSFP 

demonstrate any adjustments it believes are required in connection with any part of the 

NOCO statement or provide any other additional comments. 

Finding 2. Misstatement of Financial Activity 

Summary 

During audit fieldwork, a comparison of JSFP's reported financial activity with its bank 

records revealed that, for 2012, JFSP understated its reported receipts and ending cashon-hand by $211,949, and $106,128, respectively; and overstated disbursements by 

$13,850. Subsequent to the audit notification letter JSFP'filed amendments; however, 

receipts, disbursements and ending cash-on-hand remain understated. Additional 

amended reports filed subsequent to the end of fieldwork exit conference materially 

corrected the misstatement errors. The Audit staff recommends that JSFP provide any 

additional information or written comments that it considers relevant to this matter. 

Legal Standard 

Contents of Reports. Each report must disclose: 

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

• the total amount of receipts for the reporting period and for the election cycle; 

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

cycle; and 

• certain transactions that require itemization on Schedule A-P (Itemized Receipts) 

or Schedule B-P (Itemized Disbureements). 2 U.S.C. §434(b)(l), (2), (3), (4) and 

(5) 

Facts and Analysis 

A. Facts 

The Audit staff reconciled JSFP's reported financial activity with its bank records and 

determined that there was a misstatement of beginning and ending cash-on-hand and 

receipts. The following chart outlines the discrepancies and succeeding paragraphs 

explain, to the extent possible, the reasons for the misstatements. 
10 

2012 Activity 

.Reported Bank Records Discrepancy 

Beginning Cash-on-hand 

Balance @ January 1,2012 

$19,000 $19,328 $328 

Understated 

Receipts $1,018,273 $1,230,222 $211,949 

Understated 

Disbursements $1,121,822 $1,107,972 $13,850 

Overstated 

Ending Cash-on-hand Balance 

^December 31,2012 

$35,450' $141,578 $106,128 

Understated 

The beginning cash-on-hand was overstated by $328 likely due to prior period 

discrepancies. 

The understatement of receipts resulted from the following: 

• Matching Funds not reported 

• Contributions from Individuals not reported 

• In-kind contributions not reported 

• Loans from Candidate not reported (See Finding 6.) 

• Offsets not reported 

• Receipts from political action committees not reported 

• Reported receipts not supported by a deposit/credit 

• Unidentified difference 

Net Understatement of Receipts 

The overstatement of disbursements resulted from the following: 

• Inter-account transfers reported as disbursements 

• Reported voided checks 

• Over-reported payroll disbursements 

• Double reporting of Candidate loan repayment 

• Disbursements reported not supported by a check/debit 

• Operating expenditures reported twice 

• Bank reversing entries reported as disbursements 

• Operating expenditures not reported 

• In-kinds not reported 

• Refund not reported and other reporting errors 

• Unidentified Difference 

Net Overstatement of Disbursements 

$ 100,000 

89,647 

2,539 

40,000 

1,509 

4,235 

(23,772) 

(2.209) 

$211.949 

$ (17,000) 

(3.765) 

(2,585) 

(20,000) 

(9,399) 

(23,108) 

(285) 

61,082 

2,539 

825 

(2,154) 

a 13.850) 

^ JSFP's reported ending .cash-on-hand balance does not calculate correctly due to a failure to cany 

forward the ending casli-on-hand balance of (S7S,680) fixiin its 2012 September Monthly report as the 

beginning cash-on-hand on its 2012 October Monthly report. Absent this error, the correct ending cash 

balance as of December 31,2012 should have been (S84,SS0). 
11 

The understatement of ending cash-on-hand in the amount of $106,128 resulted from the 

misstatements described above. 

B. Preliminary Audit Report Recommendation 

At the exit conference, the Audit staff explained the misstatements and subsequently 

provided JSFP representatives with schedules detailing these discrepancies. In response, 

the representatives agreed to amend JSFP's reports. The representatives offered no 

additional comments during the exit conference. Subsequent to the audit notification 

letter JSFP filed amendments; however, receipts, disbursements and ending cash-on-hand 

reniain understated. Additional amended reports filed subsequent to the end of fieldwork 

exit conference materially corrected the misstatement errors. 

The Audit staff recommends that, within 60 calendar days of service of this report, JSFP 

provide any additional information or written comments that it considers relevant to this 

matter. 

I Finding 3. Disclosure of Debts and Obligations 

Summary 

During audit fieldwork, the Audit staff identified debts totaling $78,043 that were not 

disclosed on Schedule D-P (Debts and Obligations) as required. Amendments filed 

subsequent to the audit notification letter disclosed some of these debts. The Audit staff 

recommends that JSFP amend its disclosure reports to properly disclose the remaining 

$4,S01 in debts. 

Legal Standard 

A. Continuous Reporting Required. An authorized committee must disclose the 

amount and nature of outstanding debts and obligations until those debts are 

extinguished. 2 U.S.C. §43.4(b)(8) and 11 CFR §§ 104.3(d) and 104.11(a). 

B. Separate Schedules. An authorized committee must file separate schedules for debts 

owed by and to the committee with a statement explaining the circumstances and 

conditions under which each debt and obligation was incurred or extinguished. 

11 CFR §104.11(a). 

C. Itemizing Debts and Obligations. 

• Once it has been outstanding 60 days from the date incurred, a debt of $500 or 

less must be reported on the next regularly scheduled report. 

• A debt exceeding $500 must be disclosed in the report that covers the date on 

which the debt was incurred, except reoccurring administrative expenses (such as 

rent) shall not be reported as a debt before the payment due date. 

11 CFR §104.11(b). 
12 

Facts and Analsrsis 

A. Facts 

During audit fieldwork, the Audit staff used available disbursement records to reconcile 

the accounts of JSFP's largest vendors. These vendors provided JSFP mainly with 

services such as ballot access petitioning, legal services, printing, television advertising, 

and national party convention services. The Audit staff identified debts owed to these 

vendors totaling $78,043^ that were not disclosed on Schedule D-P as required. 

B. Preliminary Audit Report Recommendation 

The Audit staff presented this matter to JSFP representatives at the exit conference and 

provided schedules detailing the unreported debts for each reporting period. The 

representatives agreed to file amendments, but offered no additional comments during the 

exit conference. The Audit staff reviewed amended reports filed after the audit 

notification letter and concluded that debts totaling $4,501 have not yet been disclosed. 

The Audit staff recommends that, within 60 calendar days of service of this report, JSFP 

provide documentation demonstrating that the remaining $4,501 in expenditures did not 

require reporting on Schedule D-P. Absent such documentation, the Audit staff 

recommends that JSFP amend its reports to disclose the remaining outstanding debts. 

I Finding 4. Reporting of Receipts 

Summary 

During audit fieldwork, the Audit staffs review identified contributions from individuals 

totaling $23,071 that JSFP failed to itemize. In addition, receipts totaling $57,622 were 

not^equately disclosed. For most of these contributions, the election cycle-to-date total 

disclosed on Schedules A-P was incorrect. Amended reports filed subsequent to the audit 

notification letter materially corrected both the itemization and disclosure errors. The 

Audit staff recommends JSFP provide any additional information or written comments 

that it considers relevant to this matter. 

Legal Standard 

A. Itemization Required for Contributions from Individuals. An authorized 

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. If 

contributions and expenditures are designated for another election cycle, then the 

Each debt amount was counted once, even if it required disclosure over multiple reporting periods. 
13 

election cycle begins when the first contribution is received or expenditure is made. 

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 mailing address; 

• 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). 

Facts and Analysis 

A. Facts 

During audit fieldwork, the Audit staff reviewed all contributions from individuals whose 

contributions aggregated in excess of $200 and those contributions whose election 

designation was incorrectly coded. These reviews identified the following: 

1. Contributions Not Itemized - There were 268 contributions from individuals 

totaling $23,071^ that JSFP failed to itemize on Schedule A-P (Itemized 

Receipts). 

2. Contributions Not Adequately Disclosed-Vasxt were 250 contributions from 

individuals totaling $57,622, mostly for which the election cycle-to-date 

amounts and/or contributor names were either incorrectly disclosed or 

missing. 

These itemization and disclosure errors resulted mainly from: 

• Multiple contributor id's created for the sanie individual mainly resulting from 

incorrect data entry of contributor information. For example, the first and/or last 

name had been entered incorrectly for contributions that are apparently from the 

same individual; 

• The Audit staffs reconciliation of the receipts database provided by JSFP resulted 

in the addition of.approximately 1,780'° receipts that had not been included in the 

database. JSFP representatives could not explain why these had been omitted. 

Although most of these that were added to the receipts database were not required 

to be itemized, it resulted in the disclosure of the aggregate election to date 

amounts on Schedules A-P for other contributions from the same individuals to be 

incorrectly disclosed.; and 

' Of this amount, $6,272 is included in Finding 2, Misstatement of Financial Activity, as part of the 

receipts adjustment of $89,64? for contributions from individuals not reported. 

These items are included in the adjustments for receipts presented at Finding 2, Misstatement of 

Financial Activity. 
14 

B. Preliminary Audit Report Recommendation 

At the exit conference, the Audit staff explained the errors and subsequently provided 

JSFP representatives with schedules detailing these discrepancies. In response, the 

representatives agreed to amend JSFP's reports. The representatives offered no 

additional comments during the exit conference. 

Subsequent to the exit conference, the Audit staff reviewed amended reports filed after 

the audit notification letter and concluded that the amendments materially corrected both 

the itemization and disclosure errors. 

The Audit staff recommends that, within 60 calendar days of service of this report, JSFP 

provide any additional information or written comments that it considers relevant to this 

matter. 

I Finding 5. Reporting of Expenditures 

Summary 

During audit fieldwork, the Audit staffs review identified expenditures totaling $49,797 

that JSFP failed to itemize. In addition, expenditures totaling $314,673 were not 

adequately disclosed. For most of these expenditures, the purpose was not disclosed or 

inadequately disclosed. Amended reports filed subsequent to the audit notification letter 

materially corrected both the itemization and disclosure errors. The Audit staff 

recommends JSFP provide any additional information or written comments that it 

considers relevant to this matter. 

Legal Standard 

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

person exceed $200 in an election cycle, the committee must report the: 

• Amount; 

• Date when the expenditures were made; 

• 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)(A) and 11 CFR §l04.3(b)(4)(i). 

B. Examples of Purpose. 

• 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). 
15 

C. 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. If 

contributions and expenditures are designated for another election cycle, then the 

election cycle begins when the first contribution is received or expenditure is made. 

11 CFR§ 100.3(b). 

Facts and Analysis 

A. Facts 

During audit fieldwork, the Audit staffs review of all operating expenditures required to 

be itemized identified the following. 

1. Ooeratine Expenditures Not Itemized - There were 67 such expenditures 

totaling $49,797'' that JSFP failed to itemize on Schedule B-P (Itemized 

Disbursements). 

2. Ooeratine Expenditures Not Adequately Disclosed - JSFP did not disclose or 

inadequately disclosed 166 such expenditures totaling $314,673 on Schedule 

B-P. The majority of the disclosure errors were caused by JSFP not disclosing 

the purpose or disclosing inadequate purposes, such as "consulting", "contract 

labor" and "professional fees", for operating expenditures. Other errors 

included incorrectly reporting payroll expenditures, along with the failure to 

disclose memo entries relating to expenditures for reimbursements to 

individuals. 

B. Preliminary Audit Report Recommendation 

At the exit conference, the Audit staff explained the expenditure reporting errors and 

subsequently provided JSFP representatives with schedules detailing these discrepancies. 

In response, the JSFP representatives agreed to amend JSFP's reports. The 

representatives offered no additional comments during the exit conference. 

Subsequent to the exit conference, the Audit staff reviewed amended reports filed after 

the audit notification letter and concluded that the amendments materially corrected both 

the itemizatipn and disclosure errors. 

The Audit staff recommends, that within 60 calendar days of service of this report, JSFP 

provide any additional information or written comments that it considers relevant to this 

matter. 

'' Of this amount, $45,200 is included in Finding 2, Misstatement of Financial Activity, as part of the 

adjustments for disbursements not reported. 
16 

Finding 6. Itemization of Candidate Loans 

Summary 

The Audit staffs bank reconciliation for 2012 (See Finding 2) identified loans from the 

Candidate totaling $40,000 that had not been disclosed by JSFP. Amended reports filed 

subsequent to the audit notification letter materially corrected both the itemization aiid 

disclosure errors. The Audit staff recommends JSFP provide any additional information 

or written comments that it considers relevant to this matter. 

Legal Standard 

A. Reporting Loans. All loans received by a committee must be itemized on Schedule 

A-P (Itemized Receipts) and continuously reported until repaid. All repayments 

made on a loan must also be itemized. 11 CFR §§104.3(a)(4)(iv), (b)(4)(iii) and 

§104.11. 

B. Schedule C. Bpth the original loan and payments to reduce principal must be 

reported each reporting period until the loan is repaid. The committee must report the 

following: 

• The source of the loan; and 

• The type of loan the candidate received (i.e. bank loan, brokerage account, credit 

card, or home equity line of credit) either in the first box for endorsers and 

guarantors with a notation for loan type or in the box for "Loan Source" after the 

candidate's name. 11 CFR § 104.3(d) and § 104.11. 

C. Schedule C-1. When a candidate obtains a loan from an advance on the candidate's 

brokerage account, credit card, home equity line of credit or other line of credit for 

use in connection with the candidate's campaign, the candidate's principal campaign 

committee must disclose in the report, covering the period when the loan was 

obtained, the following information on Schedule C-1 or C-P-1: 

• The date, amount, and interest rate of the loan, advance, or line of credit; 

• The name and address of the lending institution; and 

• The type and value of collateral or other sources of repayment that secure the 

loan, advance, or line of credit, if any. 11 CFR § 104.3(d)(4). 

Facts and Anal3rsis 

A. Facts 

The Audit staffs bank reconciliation for 2012 (See Finding 2) identified loans from the 

Candidate, totaling $40,000, which had not been reported by JSFP. On June 22,2012, 

JSPFP received loans of $14,000 and $6,000. Although disclosed on Schedule C-P, the 

loans were nqt disclosed on Schedule A-P. JSFP also received a loan of $20,000 on 

September 11,2012, which was not disclosed on either Schedule A-P or C-P. During 

fieldwork. Audit staff discussed the itemizing of loans from the Candidate on the 

appropriate schedules with JSFP representatives. 
17 

B. Preliminary Audit Report Recommendation 

At the exit conference, the Audit staff provided JSF? representatives with schedules 

detailing these discrepancies. In response, the representatives agreed to amend JSFP's 

reports. The representatives offered no additional comments during the exit conference. 

Subsequent to the exit conference, the Audit staff reviewed amended reports filed after 

the audit notification letter and concluded that these amendments properly itemized the 

Candidate's loans on Schedules A-P and C-P. 

The Audit staff recommends, that within 60 calendar days of service of this report, JSFP 

provide any additional informiation or written comments that it considers relevant to this 

matter.