Great Moments in Campaign Finance Disclosure

Undiscovered Data Entry Error

The PA Democratic Party discovers the previously undiscovered:

The Committee is in receipt of the Commission's Request for Further Information dated 3/6/2014 regarding the increase in debt.  It should be noted that the debt was entered into the committee's compliance software for inclusion in the report.  However, due to an undiscovered data entry error, the debt did not appear on the committee's report.  This error was discovered during the preparation of an amendment to the report on an unrelated issue and corrected immediately.

Look, It Was a LOT of Paper

The campaign committee of the late Bill Young wraps up with an adjustment of its cash on hand:

The March 30, 2014 expenditure of $6,576.52 on Line 21 reflects an adjustment for the cash on hand figure to correct a discrepancy between the cash on hand shown on the FEC report versus the campaign's actual cash on hand.  This results from an inability to determine which report or reports filed by this committee over the past 45 years caused the discepancy.

When in Doubt, Stonewall

From the San Diego Democratic Club:

Reference: FEC Letter February 25, 2014 
Re: C00428516 

I have received your February 25 2014 letter regarding our July-December 2013 report. I am not aware of your calculations nor calculations technique, so I don''t know how any variance is possible.

I am not aware of any errors of any kind. We operate on a cash accounting basis and recognize revenues when either autotransferred via a internet portal or when they are physically deposited. Federal reports are run per manadated schedule.

We utilize a automated accounting system called Compelte Campaigns. It is a closed system that carries a cycle to date and a year to date field. Therefore, any filing has an automatically corrected and updated year to date field. Therefore, there cannot be any reporting that moves from one cycle to another, requiring an amended report. 

I am not aware of any bank delays or technology issues that would cause revenues to wash from one reporting period to another. Therefore, I deny that any revenues or expenses are not correct in any period. They are correct per my knowlewdge and belief.

Therefore, I have no logical or legal basis to change any report since I have no reasonable basis to do so. 

Since every FEC report has a year to date column, I maintain that the year to date column will always be right and self correcting.   

Accordingly, I have no logical basis to make any amendments.

John A. Gordon
619 379-5561 (voice)
email: jgordon@pacificmanagementconsultinggroup.com

Didn’t Get Those Emails

Looks like The Investment Company Institute PAC was assuming everything was hunky-dory with its FEC filings:

Each of the issues in these RFAIs were caused by inadvertent errors in ICI PAC’s electronic filing system.  In addition, ICI PAC did not become aware of the 2012 RFAIs until recently due to technical issues with accessing the email account listed on ICI PAC’s Statement of Organization.

Debt? What Debt?

The Placer County Republican Central Committee has it all under control:

I became the Treasurer of the Republican Central Committee in January 2013. After reviewing our financial records and interviewing previous Treasurers I could not find any information or documents concerning a $10,000 debt that the committee owed to itself.  I deleted this debt to ourselves on the June 2013 reports as I could find nothing to validate the origin of the debt. 

Friends of Dennis Ross got confused about the year:

2012 Post General report was amended because the wrong election year was originally chosen 

The Akyumen Society seems to be lacking some, well, acumen for filing:

I have tried to file electronically for the independent expenditures, but the file keeps getting rejected based on errors that simply could not be corrected. 
 
After trying for almost 2 hours, I called the help line, but it was 10 minutes past their 5:30pm closing time.  I got an email today that we were given until midnight tonight (October 18th, 2013) to file without any penalties because of the government shut down, and I have been trying since to meet this deadline.  I do not know how to resolve the issues in time, and am hoping that I am given Monday to resolve it. 
 
Thanks.

Blame It on the Software

Newt Gingrich’s presidential campaign did a “software conversion” in June of 2012. Apparently that led to some problems:

Dear Ms. Sugarman:

This letter is in response to your request for additional information, dated August 28, 2013.

1. Your letter indicates that two donors appear to exceed the primary contribution limit.  Due to a software conversion in June of 2012, the aggregates of these donors were incorrect.  On 9/18/13, the Committee issued a refund in the amount of $250 to W. Michael Brown and a refund in the amount of $250 to Marc A. Hall.  These refunds will be disclosed on the next regularly schedule report filing.
2. Your letter indicates that the Committee was required to refund all contributions designated to the 2012 General Election within 60 days of May 2, 2012.  The Committee refunded all contributions designated for the General on June 14, 2012 and disclosed these refunds on the July 2012 Monthly filing.  This was well within the 60 day requirement.  As the Committee continues to review and update its systems, if any further contributions designated for the 2012 General Election are identified, they are immediately refunded.
3. All contributions included in the unitemized receipt totals on the detailed summary pages were from contributors who have not given more than $200 in the aggregate cycle to date.  Furthermore, these contributions were raised and designated for 2012 Primary Election debt retirement.
4. Due to a software conversion, several entries on Schedule D-P were incomplete.  The October Quarterly Report has been corrected and amended to accurately disclose debt owed to New Gingrich.   
5. The Committee verified the correct debt amount owed to Vision Screen Printing and Graphics.  The Schedule D-P shows a credit in order to accurately reflect this corrected amount.  This was not a credit given by the vendor, it was simply a correcting entry.
6. Due to a software conversion, several entries on Schedule B-P supporting Line 23 were incomplete.  The October Quarterly Report has been amended to accurately disclose these disbursements.
7. The Committee has reviewed all reimbursements to staff for travel and subsistence and has determined that no further itemizations are required based on FEC regulations in effect at that time.
8. Due to a software conversion, several entries on Schedule D-P were incomplete.  The October Quarterly Report has been amended to correctly disclose all debt.
9. All debt noted as IN DISPUTE on Schedule D-P indicates that the full amount of the debt disclosed is in dispute.  The Committee is working with these vendors (Crimson Hexagon, Moshe Technologies, Resilient Corporation and Mark Gembecki) to resolve these issues.  The Committee will continue to report all such debt as IN DISPUTE until these matters are resolved.

Stop Being Tricky, FEC!

John Pomeranz, the counsel to Florida Freedom PAC, seems a little miffed that the FEC deviated from its usual practice and mentioned issues with two different filings in the same RFAI. The horror!

The committee would also like to note for the record that requesting information about two separate reports in  the same letter (with a misleading caption that fails to mention the second report questioned) is an unorthodox approach by the Commission.

Gremlins

The Kentucky State Democratic Central Executive Committee had a problem with a recent filing:

The Committee is in receipt of the Commission's letter dated August 9, 2013 regarding the 2013 Amended February Monthly report filed on 7/25/2013.  A technical error occurred while filing the original report on Feb. 20, 2013. While preparing the data for the original filing, a paper version of the report was printed for internal review and all data was correct; yet, when it uploaded to the FEC, the file was created without any receipts or disbursements. The committee was unaware of the error until contacted by the FEC. The committee has been working with its software vendor to understand how the error occurred but we have not been able to recreate the error.