tailieunhanh - AGENDA DOCUMENT NO. 11-41 FEDERAL ELECTION COMMISSION

Given the strong leadership evidenced by the current Governors of New York and New Jersey, and their appropriate and intense focus on responsible government, increased transparency, organizational efficiency and fiscal responsibility, the Port Authority now has a window of opportunity to drive the transformational changes fundamental to addressing the challenges of the organization. With the relatively recent appointments of a new Chairman, Vice‐Chairman, several Commissioners, Executive Director and Deputy Executive Director, the Port Authority has a reinvigorated focus. The organization’s new leadership appears intent on driving the change necessary to best position the Port Authority to meet the challenges of the 21st Century and to progress from its “business as usual” approach. A major theme in this endeavor is increased transparency and accountability throughout the organization. . | AGENDA DOCUMENT NO. 11-41 FEDERAL ELECTION COMMISSION WASHINGTON . 20463 June 23 2011 MEMORANDUM AGENDA ITEM To The Commission Through Alec Palmer Acting Staff Director For Meeting of II From Chief Compliance Officer Joseph F. Stoltz Assistant Staff D Audit Division By Thomas J. Nurthen Audit Manager Mary Moss Lead Auditor Subject Audit Division Recommendation Memorandum on John Edwards for President JEFP Discussed below is JEFP s response to the attached Draft Final Audit Report DFAR as well as the Audit Division s comments and recommendations. The Office of General Counsel reviewed this memorandum concurs with the recommendations and provided the attached comments. JEFP declined the opportunity for an audit hearing and did not respond to Findings 2 3 or 4. Finding 1. Matching Funds Received in Excess of Entitlement In response to the Draft Final Audit Report Counsel for JEFP Counsel has restated many of the same arguments made previously with respect to the February 7 2008 payroll and to JEFP s overall objection to the repayment of matching funds. In addition to those arguments Counsel stated that the portion of the February 7 2008 2 payroll in question 528 454 should be treated as a pre-DOI date of ineligibility qualified campaign expense for the following reasons 1 To compensate staff for overtime and extra hours worked during January 2008. To compensate staff for remaining with the campaign after DOI to perform functions relating to closing out campaign offices. To compensate staff for extra expenses they may have incurred including assisting in the close-out of the campaign. Counsel continued that the final payroll was to compensate staff for their work prior to DOI and to deal with obligations leased office space rental cars leased equipment etc. that were undertaken by the campaign prior to DOI. As such according to Counsel the final payroll amount that the Audit Division is challenging is a qualified campaign expense because the expenditure 1 occurred .