PAC Outsourcing was engaged by an international labor union to provide federal and state campaign law compliance and related administrative support. The client had relied on a law firm for such services for ten years.
Upon receipt of the records, we discovered that the reported receipt totals were more than a million dollars less than actual cash on hand. The union’s general counsel was immediately apprised and following a discussion of our initial findings, the client accepted our recommendation to employ the FEC’s self-reporting of a violation procedure (Sua Sponte Submission) with the objective of determining the cause of the material difference in the reported and actual receipts.
PAC Outsourcing was instructed to initiate an audit of the federal PAC’s activity including state and local activity. The audit process took more than four months to complete and entailed looking back ten years in some circumstances in order to adjust the reporting. A number of state (and some local) campaign law filings had to be amended.
As part of the Sua Sponte proceeding, we were able to negotiate a one-time adjustment to the client’s federal PAC filings to reflect the revised receipts total, thus eliminating the need to amend years’ worth of FEC filings.
The union has now been a client for more than six years. The federal and state PAC accounts have been properly maintained throughout this period and there have been no inquiries or questions concerning the client’s PAC activities.
Politics has become so expensive it takes a lot of money even to be defeated.