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Commonwealth of Pennsylvania

Consulting Services ITQ #4400007410

RFQ FOR CAMPAIGN FINANCE AUDITING

Solicitation Number: DOS RFQ 2017-3

May 1, 2017

To Whom It May Concern:

The attached Statement of Work (SOW) (Attachment A) is provided for you to develop your proposal for the referenced Consulting Project. The successful contractor will be selected based on Best Value. The Best Value Criteria specified below defines the criteria that will be used to determine the successful contractor to be issued a purchase order. It is imperative that you expound in writing on each of the best value criteria listed. You may complete your proposal on this form and return your quote by e-mail reply no later than 2:00 p.m. on May 22, 2017.

Best Value Criteria:

1. Cost: Complete the attached Cost Matrix (Attachment B) to submit the cost portion of your proposal. This contract cannot exceed the total extended cost that is being submitted on the Cost Matrix.

2. Contractor Prior Experience: On the included Contractor Prior Experience Submittal (Attachment C), detail three (3) projects your company performed that are similar in nature and scope to the requirements stated in the SOW. Include/reference the company name and address, contact person with phone number, e-mail address and best time to call, project name, project start and end dates and a brief description of the project.

3. Contractor Personnel and Qualifications: Provide resumes (Attachment D) with names of individuals that will be assigned and demonstrate the qualifications and skills required to successfully develop and implement the project as defined in the SOW. It is very important that the proposed individuals meet the minimum levels of experience and have all proper certifications, if requested. The proposed project manager must have demonstrated project management skills and technical background and experience to appropriately manage the project. Ensure resumes contain no personal information as these may become public documents.

4. Domestic Workforce Utilization: Complete and sign the attached Domestic Workforce Utilization Form (Attachment E).

5. Small Diverse Business Participation: To maximize Small Diverse Business participation in the project, the greatest consideration will be given to a Small Diverse Business quoting as a prime contractor. For all other prime contractors subcontracting to a Small Diverse Business, briefly explain what your company’s approach will be to maximize Small Diverse Business participation in the project if you are selected for award. This should include detail on which portions of the contract will be performed by the Small Diverse Business. Include specific percentage commitments to be paid to Small Diverse Business based upon the total contract value. The more definitive the commitment and the greater the percentage commitment, the greater consideration that your company will receive for this best value selection factor.

Any questions on this RFQ may be sent to Sara Roadcap at sarroadcap@, prior to May 8, 2017 at 2:00 p.m. Answers will be posted as an addendum by 2:00 p.m. on May 15, 2017.

Note: This Request for Quotations DOS RFQ 2017-3 is a restricted solicitation. Only those contractors qualified in the designated categories under Contract #4400007410, known as the Commonwealth of Pennsylvania’s Consulting Services Invitation to Qualify (ITQ), may submit a proposal in response to this RFQ.

• Auditing Services – Compliance Audits

• Auditing Services - General

For more information about the Consulting Services ITQ, please click the following link.



The following documents must be returned with your RFQ response:

Attachment B – Cost Matrix

Attachment C – Contractor Prior Experience Submittal

Attachment D – Resumes to be submitted by Bidders

Attachment E - Domestic Workforce Utilization Form

The following attachments that are part of this RFQ, but do not need to be returned with the RFQ response:

Attachment A – Statement of Work

Attachment F – Table 1: Election and Lottery Information; Lottery Outcome Sample

Attachment G – Pennsylvania Campaign Finance Reporting Law Audit Policies and Procedures

ATTACHMENT A

DOS RFQ 2017-3

CAMPAIGN FINANCE AUDITING SERVICES

STATEMENT OF WORK

SECTION 1. OBJECTIVES.

A. GENERAL. The Department of State’s Bureau of Commissions, Elections and Legislation (Bureau) requires the services of a Contractor to audit campaign finance statements and reports submitted by selected candidates for public office, and by those candidates’ authorized political committees and to prepare written audit reports in accordance with the requirements of the Section 1635 of the Pennsylvania Election Code, 25 P.S. § 3255.

B. SPECIFIC. This RFQ has three (3) specific objectives:

1. To obtain certified public accounting services;

2. To obtain audits of campaign finance statements and reports submitted by selected candidates and their affiliated political committees, including compliance audit; and

3. To obtain written reports detailing the audit findings, compliance findings, and the Contractor’s opinions.

SECTION 2. NATURE AND SCOPE OF CONTRACT.

A. Auditing Subjects. The purpose of this solicitation is to obtain professional audits of a selected number of campaign finance statements and reports which, pursuant to the Pennsylvania Election Code, candidates and political committees must file with the Secretary of the Commonwealth. The campaign finance statements and reports for this audit contract period reflect campaign finance activity between January 1, 2017 and December 31, 2018. Audit subjects will include both candidates and candidates’ authorized political committees.

A campaign finance statement is an affidavit representing that the receipts and disbursements of the candidate or the candidate’s political committee did not exceed $250.00 during the reporting period. The Secretary has promulgated a statement form that all filers are required to use. The form, which is distributed by the Bureau is titled “Campaign Finance Statement” and is numerically designated DSEB 503. A copy of the DSEB 503 Form is available on the Bureau’s website at:



A campaign finance report is filed when the receipts and disbursements of a candidate or political committee exceed $250.00 during the reporting period. The report constitutes a complete accounting of financial activity with supporting schedules. The Secretary has promulgated a report form that all filers are required by the Law to use. The form that is distributed by the Bureau is titled “Campaign Finance Report” and is numerically designated DSEB 502. A copy of the DSEB 502 Form is available on the Bureau’s website at:



B. Audit Lottery. The selection of candidates and political committees to be audited is made through public lotteries conducted by the Secretary, in accordance with the Pennsylvania Election Code. Forty (40) days following each primary election and general or municipal election (in even-numbered years, the November election is called a general election, in odd-numbered years, the November election is called a municipal election), the names of the public offices voted on at the primary and general or municipal election, along with the names of any public offices filled at any special election during the audit period, are placed in a tumbling device. Each statewide office, legislative district and judicial district is considered a public office for the purposes of the lottery. Three percent (3%) of the total number of public offices is selected at random for audit. The Contractor shall audit and report on the campaign finance statements or reports filed by each candidate seeking the selected public office(s), as well as the statements or reports filed by the political committees authorized by such candidate.

The Contractor shall audit only those pre- and post-primary/election statements and reports filed with respect to the primary or election for which the lottery is conducted. Campaign finance statements or reports filed by a candidate or committee during preceding election cycles are not subject to audit, nor is the Contractor required to audit a candidate’s or political committee’s annual campaign finance statements and reports.

C. Compensation. Because the total amount of services to be delivered under the contract depends upon the outcome of future lotteries, it is impossible to determine exactly how much work the Contractor will be required to perform over the term of the contract. The law requires that there be an audit of three percent (3%) of all the public offices voted on at the primary and general or municipal elections. The number of public offices selected in each lottery varies, depending on the number of offices voted on during the primary and general or municipal elections. It is possible that a single public office voted on at the primary and general or municipal election may meet or exceed the three percent (3%) standard or more than one (1) public office may need to be drawn in a lottery to meet the three percent (3%) requirement. Past experience has been that, in a general election year, seven (7) public office districts are selected for each election; in a municipal election year, one (1) public office district generally meets the three percent (3%) requirement for the primary and municipal election lotteries.

It is also impossible to predict how many candidates will stand for nomination or election to each public office selected in the lottery. It is not uncommon that one (1) candidate may be unopposed for election in one (1) public office. In much less frequent instances, candidates for one (1) public office could reach or exceed ten (10).

As an aid to the Contractors who submit a bid, the Issuing Office has prepared Attachment F, which contains information about the following:

1. The actual dates of the primaries, general or municipal elections, and audit selection lotteries that will occur for the contract term; and

2. The number of offices audited since 2013.

A Contractor should use the information in Attachment F to estimate the amount of services she or he will be required to provide under the contract and the probability of being required to audit a public office for which there are multiple candidates.  Contractors should carefully evaluate the information presented in Attachment F when estimating the amount of hours required and preparing cost proposals.  The Contractor will be paid based on the hourly rate with a not-to-exceed compensation cap for all required work during the contract period.  

The Commonwealth’s current audit contractor is Wessel and Company, PC. Pursuant to Law, no certified public accountant or certified public accounting firm is eligible to obtain the audit contract for two (2) successive contract periods. The bid submitted by Wessel and Company, PC for the 2015 and 2016 audit period was based on an estimate that all required services over the life of the Contract would be completed in approximately 720 hours at a total cost of $48,470.00, reflecting the Contractor’s composite hourly rate of $65.50.

The Contractor shall be responsible for furnishing all professional services, labor, materials, supplies, shipping, mailing, facilities, data processing services, and security required to perform the audit services.

SECTION 3. CONTRACTOR QUALIFICATIONS

A. Professional Qualification and Standards. The Department requires that campaign finance audits be conducted by Certified Public Accountants with a minimum of five (5) years experience with audits related to statutorily required financial reporting.

The Contractor shall perform a detailed professional audit of each candidate and committee statement or report subject to audit consistent with sound auditing principles and in compliance with the auditing standards of the American Institute of Certified Public Accountants. Although the Bureau may make some allowance for the Contractor’s standard audit approach, the Bureau has developed audit policies and procedures for campaign finance statements and reports. (See Attachment “G”, Pennsylvania Campaign Finance Reporting Law Audit Policies and Procedures). At the beginning of the contract term, the Bureau will review its current audit policies and procedures with the selected Contractor to maximize the benefit of experience with prior auditing contractors, to minimize start-up costs, and to ensure the continuity of the audit program.

The Contractor shall conduct the audit in a courteous manner and ensure that candidates have adequate time to respond to requests for information.

B. Familiarity with the Law; Continuity of Assignment. The Department requires that the selected auditor have detailed knowledge of Sections 1621 through 1642 of the Pennsylvania Election Code, 25 P.S. §§ 3241-3260b, relating to requirements for campaign finance reporting, see 25 P.S. Sections 3241-3260b. In addition, the Contractor and assigned personnel will require a basic knowledge of the Pennsylvania election process. Due to the unique nature of these audits, the Bureau strongly recommends year-to-year continuity of the principal staff assigned by the Contractor to perform services under the contract.

SECTION 4. REQUIRED TASKS.

Required tasks include, but are not limited to the following:

A. Meet with Bureau Representatives. The Contractor must complete several preliminary tasks before initiating its first audits. The Contractor shall meet with Bureau representatives at the beginning of the contract term to review the bureau’s audit policies and procedures, review the format of the audit reports, obtain initial audit assignments, and prepare for the commencement of audits. The Contractor and Contractor’s assigned principal staff shall subsequently meet with Bureau representatives as necessary.

B. Prepare for Pre-Audit Conferences with Candidates and Committee Treasurers. The Bureau will provide the Contractor with paper or electronic copies of all necessary reports, statements, and registration and authorization forms for each candidate and political committee to be audited. The Contractor shall review the documents in accordance with the Bureau’s audit policies and procedures and prepare for a pre-audit conference with each candidate and committee treasurer.

C. Conduct Pre-Audit Conferences with Candidates and Committee Treasurers. The Contractor shall schedule and begin conducting pre-audit conferences within three (3) weeks after the Contractor receives the copies of the reports to be audited from the Bureau. Bureau representatives shall be permitted to attend any conference. A pre-audit conference is to be held in the location that is most suitable to the candidate and the committee treasurer(s). The Contractor may also complete the pre-audit conferences by telephone, e-mail, or written correspondence.

The purpose of the pre-audit conference is to obtain all supporting documentation from the candidate and committee treasurer and to obtain an understanding of the candidate’s and committee’s financial organization and internal controls. Pursuant to law, all audited candidates and committees must furnish any records to the Contractor that the Contractor deems necessary for the completion of his/her work.

D. Conduct Audit. All audits shall be conducted in accordance with the requirements of Section 3(A), above. An audit shall include findings of any possible violations of the campaign finance reporting law with respect to campaign contributions and expenses. The required work includes, but is not limited to, validation and compliance testing, transaction reviews, transaction confirmations, bank confirmations, and proof of cash. The work shall be performed in the Contractor’s offices.

E. Formulate Opinions. The Contractor shall formulate an opinion, based on each audit conducted. The opinion shall address the statements and reports submitted by the audited candidate or committee, and compliance with the law and Bureau regulations with respect to campaign contributions and expenses. The regulations are published at 4 Pa. Code, Chapters 172, and 176-181.

F. Issue Audit Reports. Audit reports shall list all findings and cite the specific section of the law or regulations relied upon. The Contractor shall issue an electronic copy (either on CD or in .pdf via email) of written audit reports to the Bureau. Audit reports for primary elections shall be due on December 31 in the year of the primary. Audit reports for the general or municipal elections shall be due June 30 of the following year. The Bureau may agree to adjust the due dates if necessary. Upon issuance of the final audit report, the Contractor shall also furnish one (1) copy of each audit report to the Attorney General of the Commonwealth of Pennsylvania; one (1) copy to the candidate whose statements or reports were audited; and one (1) copy to the treasurer of any candidate committee whose statements or reports were audited.

As soon as possible after the audit is completed, and at least ten (10) business days prior to the audit report due date specified by the Bureau, the Contractor shall present a draft report on each audit to the Bureau for review and comment. Electronic transmission of the draft report to the Bureau is required. The Contractor shall also present the draft to the candidate or their political committee, who shall be invited to respond to the findings and submit any written response or comments they may have regarding the audit and report. Candidate or committee written responses or comments regarding the Contractor’s draft report shall be attached to the final audit report. In preparing a final audit report, the Contractor shall give due consideration to any response submitted by the audited candidate or committee and any comment provided to the Contractor by the Bureau. Unless otherwise directed by the Bureau, the Contractor shall issue a final audit report ten (10) business days after issuing its draft report.

SECTION 5. REPORTS

A. Progress Reports. The Contractor shall submit a quarterly progress report to the Bureau within seven (7) days following the end of each calendar quarter of the contract term. The report shall include:

1. A list of the dates of the pre-audit conferences held by the Contractor during the quarter (The Bureau requires the Contractor to submit the Report in the format set forth in Appendix G);

2. A list of the audits conducted during the quarter and the status of those audits;

3. A list of draft audit reports submitted for approval during the quarter;

4. A list of final audit reports submitted and

5. Any other information that the Contractor considers important for the Bureau to know in order to assess the Contractor’s progress in completing tasks required by the contract.

B. Problem Identification. The Contractor shall notify the Bureau as soon as possible of any material problems experienced by the Contractor in completing the tasks required by the contract. The initial notification may be verbal, but shall be promptly followed by a written problem identification report. E-mail correspondence is acceptable. On its own initiative, the Bureau may require the Contractor to submit a Problem Identification Report concerning any subject of concern to the Bureau related to the performance of the contract.

A Problem Identification Report shall include, but not be limited to, the following:

1. A complete description of the problem;

2. The Contractor’s assessment of the impact of the problem on the completion of tasks required by the contract;

3. Possible responses to, or a course of action required by, the problem; and

4. The Contractor’s recommendations for resolving the problem, including the respective advantages and disadvantages of alternative recommendations.

SECTION 6. INVOICING.

The Contractor shall be paid upon the completion of each audit. After a final audit report is issued, the Contractor shall submit an invoice detailing the specific tasks completed, the time spent on each task, and the cost by each candidate or candidate’s political committee audited. Examples of tasks would include pre-audit conferences, actual audit time and report preparation. The project manager for the Department will review all invoices for accuracy and completeness before the invoice will be forwarded for payment. This is a fixed price contract. The Contractor will not be compensated for any costs that exceed the amount bid on the cost matrix.

ATTACHMENT B

DOS RFQ 2017-3

CAMPAIGN FINANCE AUDITING SERVICES

COST MATRIX

|YEAR |NUMBER OF HOURS |HOURLY RATE |EXTENDED |

|FY17 | |$ |$ |

|FY18 | |$ |$ |

|TOTAL | |N/A |$ |

NOTE: This contract cannot exceed the total extended cost that is being submitted in this Cost Matrix.

Vendor Name:

Address:

City, State, Zip Code

Authorized Signatory

Printed Name

Date

ATTACHMENT C

DOS RFQ 2017-3

CAMPAIGN FINANCE AUDITING SERVICES

Contractor Prior Experience Submittal

| |Company Name and Address |Contact Information |Project Name |Project Start and |Brief Description of the Project |

| | | | |End Dates | |

|1 | | | | | |

|2 | | | | | |

|3 | | | | | |

ATTACHMENT D

DOS RFQ 2017-3

CAMPAIGN FINANCE AUDITING SERVICES

RESUMES TO BE SUBMITTED BY BIDDER

ATTACHMENT E

DOS RFQ 2017-3

DOMESTIC WORKFORCE UTILIZATION CERTIFICATION

To the extent permitted by the laws and treaties of the United States, each proposal will be scored for its commitment to use the domestic workforce in the fulfillment of the contract. Maximum consideration will be given to those Contractors who will perform the contracted direct labor exclusively within the geographical boundaries of the United States or within the geographical boundaries of a country that is a party to the World Trade Organization Government Procurement Agreement. Those who propose to perform a portion of the direct labor outside of the United States and not within the geographical boundaries of a party to the World Trade Organization Government Procurement Agreement will receive a correspondingly smaller score for this criterion. In order to be eligible for any consideration for this criterion, Contractors must complete and sign the following certification. This certification will be included as a contractual obligation when the contract is executed. Failure to complete and sign this certification will result in no consideration being given to the Contractor for this criterion.

I, ______________________[title] of ____________________________________[name of Contractor] a _______________ [place of incorporation] corporation or other legal entity, (“Contractor”) located at __________________________________________________________

[address], having a Social Security or Federal Identification Number of ________________________, do hereby certify and represent to the Commonwealth of Pennsylvania ("Commonwealth") (Check one of the boxes below):

 All of the direct labor performed within the scope of services under the contract will be performed exclusively within the geographical boundaries of the United States or one of the following countries that is a party to the World Trade Organization Government Procurement Agreement: Aruba, Austria, Belgium, Bulgaria, Canada, Chinese Taipei, Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hong Kong, Hungary, Iceland, Ireland, Israel, Italy, Japan, Korea, Latvia, Liechtenstein, Lithuania, Luxemburg, Malta, the Netherlands, Norway, Poland, Portugal, Romania, Singapore, Slovak Republic, Slovenia, Spain, Sweden, Switzerland, and the United Kingdom

OR

 ________________ percent (_____%) [Contractor must specify the percentage] of the direct labor performed within the scope of services under the contract will be performed within the geographical boundaries of the United States or within the geographical boundaries of one of the countries listed above that is a party to the World Trade Organization Government Procurement Agreement. Please identify the direct labor performed under the contract that will be performed outside the United States and not within the geographical boundaries of a party to the World Trade Organization Government Procurement Agreement and identify the country where the direct labor will be performed: ______________________________________________________________________________________

______________________________________________________________________________________

[Use additional sheets if necessary]

The Department of General Services [or other purchasing agency] shall treat any misstatement as fraudulent concealment of the true facts punishable under Section 4904 of the Pennsylvania Crimes Code, Title 18, of Pa. Consolidated Statutes.

Attest or Witness: ______________________________

Corporate or Legal Entity's Name

_____________________________ ______________________________

Signature/Date Signature/Date

_____________________________ ______________________________

Printed Name/Title Printed Name/Title

ATTACHMENT F

DOS RFQ NO. 2017-3

CAMPAIGN FINANCE AUDITING SERVICES

Election and Lottery Information; Lottery Outcome Sample

Election Year 1:  (2017)

Election and Lottery Dates:

Primary Election Date – May 16, 2017

Primary Lottery Date – June 26, 2017

Municipal Election Date – November 7, 2017

Municipal Lottery Date – December 18, 2017

Offices Included in Lottery                                                                                                                      Number of Districts*

               Judge of the Supreme Court ……………………………………………………………………………………………. 1

Judge of the Superior Court……………………………………………………………………………………………… 1

                Judge of the Commonwealth Court…………………………………………………………………………………. 1

                Judge of the Court of Common Pleas……………………………………………………………………………….. 21

                Judge of the Municipal Court………………………………………………………………………………………….. 1

                Special Election House of Representative in the General Assembly……………………………………. 2

                Special Election House of Representative in the General Assembly……………………………………. 2

Total Offices (Districts) Appearing on the Ballot…………………………………………………………………………… 27

Offices to be Selected for Audit (3% of TOTAL)…………………………………………………………………………….. 1

*The figures in this column include judicial retention elections for which there are no primary elections.  The number of judicial retention elections will not affect the number of offices selected for audit. 

Election Year 2:  (2018)

Election and Lottery Dates:

Primary Election Date – May 15, 2018

Primary Lottery Date – June 25, 2018

General Election Date November 6, 2018

General Lottery Date – December 17, 2018

Offices Included in Lottery                                                                                                                     Number of Districts*

                Governor……….………………………………………………………………………………………………………………. 1

                Lieutenant Governor……………………………………………………………………………………….……………… 1

                Senator in the General Assembly…………………………………………………………………………………..… 25

                Representative in the General Assembly………………………………………………………………………….. 203

Total Offices (Districts) Appearing on the Ballot ……………………………………………………………………...…… 230

Offices to be Selected for Audit (3% of Total)………………………………………… ……………………………………. 7

NOTE:  All dates subject to change due to amendatory legislation. 

2013 Primary Election Lottery (1 district selected for audit)

2013 Municipal Election Lottery (1 district selected for audit)

2014 Primary Election Lottery (7 districts were selected for audit)

2014 General Election Lottery (7 districts were selected for audit)

2015 Primary Election Lottery (1 district selected for audit)

2015 Municipal Election Lottery (1 district selected for audit)

2016 Primary Election Lottery (7 districts were selected for audit)

2016 General Election Lottery (7 districts were selected for audit)

ATTACHMENT G

DOS RFQ NO. 2017-3

PENNSYLVANIA CAMPAIGN FINANCE REPORTING LAW

AUDIT POLICIES AND PROCEDURES

FORM # DSEB-503 – CAMPAIGN FINANCE STATEMENT ($250 or LESS)

I. Audit Administration

A. Obtain from the State Bureau of Commissions, Elections and Legislation (the State) copies of all campaign finance statements ($250 or less) filed by the candidate/committee treasurer relating to the Election.

B. Make a copy of the campaign finance statements received from the State to be included in the audit work papers. Retain the original copies (unmarked) for issuance with the final audit report.

C. Obtain copies of correspondence (if any) between the state and the candidate/committee treasurer.

D. Determine if the candidate/committee treasurer has provided all records (if any) deemed necessary to complete the required audit procedures.

E. Obtain a management representation letter signed by the candidate/committee treasurer. Use standard management representation letter language designed for candidates filing Form #DSEB-503 for this engagement.

F. Draft audit report in good form, including title page, Auditor’s Report (opinion) and transmittal (instruction) letter. Use standard report format designed for reporting on campaign finance statements (Form #DSEB-503) approved for this engagement.

G. Document all exceptions noted and discuss exceptions with audit supervisor for review and approval that audit documentation is adequate. Note: Any apparent violations of the Act should be recorded (noted) and discussed promptly with the audit supervisor and manager in order that the appropriate Department of State officials may be notified of the details relating to the exception.

H. Review draft of audit report including exception(s) noted (if any) with the State.

I. Review draft of audit report including exception(s) noted (if any) with candidate/committee treasurer.

J. Mail final audit report and compliance report to the Secretary of the Commonwealth (c/o the Bureau of Commissions, Elections and Legislation); and directly to the Attorney General, and the candidate or committee treasurer who was subject of the audit.

K. Return all supporting documentation to candidate/committee treasurer.

Compliance Testing

2 Pennsylvania Campaign Finance Reporting Law

Read Act 171 of 1978, Campaign Finance Reporting Law, as amended (the Act), to become familiar with the requirements of the Act (a manual provided by the State contains the entire Act, which is also found on the Campaign Finance page at the Department of State web site, dos.state.pa.us).

Form #DSEB-501 – Authorization of Political Committee

If a political committee was operating on behalf of a candidate, verify that Form #DSEB-501, Authorization for a Political Committee to Receive Funds on Behalf of a Candidate was filed with the State for each committee in existence.

Verify the following:

a. The committee was authorized by the candidate

b. The candidate signed and dated Form #DSEB-501

If there is more than one committee operating on behalf of a candidate, verify that each committee was authorized to receive funds on behalf of the candidate

By examining the dates of the various transactions submitted by the committee in the supporting documentation, and as reported on the campaign finance reports, verify that no transactions were made prior to the date Form #DSEB-501 was signed by the candidate.

Verify that Form #DSEB-501 was filed with the State prior to the committee receiving any money on behalf of the candidate.

Ascertain that no transactions occurred if there was a vacancy in the office of committee chairperson or treasurer.

Form #DSEB-500 – Political Committee Registration Statement

If the political committee has received contributions in an aggregate amount of $250 or more as reported on the campaign finance reports (and as listed in the cash receipt records supplied by committee treasurer), verify that Form #DSEB-500 - Political Committee Registration Statement was filed with the State prior to or within 20 days after the date on which it received such amount.

Note: Form #DSEB-500 – Political Committee Registration Statements are filed by political committees only; individual candidates do not file a Registration Statement.

a. The following information should be included on the registration statement:

✓ Name, address and phone number of political committee

✓ Name, address and phone number of the committee’s treasurer and the committee’s chairman

✓ Names, addresses and relationships of other affiliated or connected organizations, if any

✓ Name and address of candidate

✓ Names and addresses of any banks, safety deposit boxes or other depositories used by the committee

✓ Proposed period of operation of the committee

b. Note that any changes to the information in (a.) were reported to the State within 30 days of such changes based on information filed by the candidate/committee.

c. If the candidate has authorized more than one committee to receive money on their behalf, verify that each committee has the same treasurer.

d. Verify that the committee chairperson and the committee treasurer are not the same individual

Review the Campaign Finance Statement(s) received from the State.

1. Verify that all required reports have been filed by the filing deadline, on the appropriate report form, covering the correct reporting period.

a. First report period (Cycle 1 or Cycle 4) (6th Tues. pre-primary/election report), for statewide candidates (i.e. Governor, Lieutenant Governor, Attorney General, Auditor General, State Treasurer, Supreme, Superior and Commonwealth Court Judges).

b. Second reporting period (Cycle 2 or Cycle 5) (2nd Fri. pre-primary/election report), for all candidates subject to the lottery.

c. Third reporting period (Cycle 3 or Cycle 6) (30 day post-primary/election report), for all candidates subject to the lottery.

d. Verify that the proper type of report is indicated on the statement.

e. Compare the date of the report filing (date stamped received by the State) to the filing deadline date and ascertain whether late fees were assessed in accordance with Sec. 1632(a) of the Campaign Finance Reporting Law if the reports were filed after the filing deadline. Such late fees may not be paid from contributions or considered legitimate campaign expenditures. If the envelope transmitting the report or statement is postmarked by the day preceding the filing deadline, the report will be considered timely regardless of the receipt date.

2. Determine that the Political Committee Registration Statement (DSEB-500), the Authorization for a Political Committee to Receive Funds on Behalf of a Candidate (DSEB-501), and the reports or statements were filed with the County Board of Elections in the county where the candidate resides. A list of the county contact persons is posted to the Department of State web page at dos.state.pa.us. Due dates for filing the statements with the county boards are the same as due dates for filing with State.

3. Verify that the candidate signed each campaign finance statement and that the signature has been notarized.

Examine all correspondence (if any) between the State and the candidate during the report period being audited to determine if any actions as a result of the correspondence would affect the audit report.

FORM # DSEB-502 – CAMPAIGN FINANCE REPORTS

I. Audit Administration

A. Obtain from the State Bureau of Commissions, Elections and Legislation (the State) copies of all campaign finance reports (Form #DSEB – 502) filed by the candidate and all committees authorized by the candidate for the audit period.

B. Make a copy of the campaign finance report(s) received from the State to be included in the audit work papers. Retain the original copies (unmarked) for issuance with the final audit report.

C. Obtain copies of correspondence (if any) between State and the candidate/committee.

D. If the campaign finance reports were filed by a candidate’s authorized political committee, obtain from the State a copy of Form #DSEB-501, Authorization for a Political Committee to Receive Funds on Behalf of a Candidate, and Form #DSEB-500 - Political Committee Registration Statement, including any amendments to these documents.

E. Review the campaign finance reports received from the State to identify non-cash transactions or potential problem areas which may warrant further review and prepare specific questions regarding these areas to be used in the audit checklist and exhibits to be mailed to the candidate/committee treasurer.

F. Mail notification letter and audit checklist with exhibits, designed for candidate/committees required to file a campaign finance report, to the candidate/committee treasurer to request supporting documentation.

G. When audit checklist with exhibits and supporting documentation is received, provide candidate/committee treasurer with receipt for documents received.

H. Determine that the candidate/committee has provided all supporting documentation deemed necessary to complete the required audit procedures.

I. Obtain a management representation letter signed by the candidate and/or committee treasurer. Use standard management representation letter designed for candidates/or committees filing a campaign finance report for this engagement.

J. Draft audit report in good form, including title page, Auditor’s Report (opinion) and transmittal (instruction) letter. Use standard report format designed for reporting on campaign finance reports for this engagement.

K. Document all exceptions noted and discuss exceptions with audit supervisor for review and approval that audit documentation is adequate. Note: Any apparent violations of the Act should be noted and discussed promptly with the audit supervisor and manager in order that the appropriate Department of State officials may be notified of the details relating to the exception.

L. Review draft of audit report including exception(s) noted (if any) with the State.

M. Mail a draft of audit report including exception(s) noted (if any) to the candidate and/or committee treasurer for their review.

N. Mail final audit report and compliance report to the Secretary of the Commonwealth (c/o the Bureau of Elections), the Attorney General, and the candidate or committee treasurer who was subject of the audit.

O. Return supporting documentation to candidate/committee treasurer.

II. Compliance Testing

Pennsylvania Campaign Finance Reporting Law

Read Act 171 of 1978, Campaign Finance Reporting Law, as amended (the Act), to familiarize yourself with the requirements of the law. The entire text is available on the Department’s website at Form #DSEB-501 – Authorization of Political Committee

If a political committee(s) was (were) operating on behalf of the candidate, verify that Form #DSEB-501, Authorization for a Political Committee to Receive Funds on Behalf of a Candidate was filed with the State for each committee in existence.

Verify the following:

a. The committee was authorized by the candidate

b. The candidate signed and dated Form #DSEB-501

If there is more than one committee operating on behalf of a candidate, verify that each committee was authorized to receive funds on behalf of the candidate.

By examining the dates of the various transactions submitted by the committee in the supporting documentation, and as reported on the campaign finance reports, verify that no transactions were made prior to the date Form #DSEB-501 was signed by the candidate.

Verify that Form #DSEB-501 was filed with the Secretary of the Commonwealth prior to the committee receiving any money on behalf of the candidate.

Ascertain that no transactions occurred if there was a vacancy in the office of committee chairperson or treasurer.

Form #DSEB-500 – Political Committee Registration Statement

If the political committee has received contributions in an aggregate amount of $250 or more as reported on the campaign finance reports (and as listed in the cash receipt records supplied by committee treasurer), verify that Form #DSEB-500 - Political Committee Registration Statement was filed with the State prior to or within 20 days after the date on which it received such amount.

Note: Registration statements (Form #DSEB-500) are filed by political committees only; individual candidates do not file Registration Statements. The following information should be included on the registration statement:

✓ Name, address and phone number of political committee

✓ Name, address and phone number of the committee’s treasurer and the committee’s chairman

✓ Names, addresses and relationships of other affiliated or connected organizations, if any

✓ Name and address of candidate

✓ Name and addresses of any banks, safety deposit boxes or other depositories and their addresses used by the committee

✓ Proposed period of operation of the committee

a. Note that any changes to the information contained in the registration statement were reported to the State within 30 days of such changes based on information filed by the candidate/committee.

b. If the candidate has authorized more than one committee to receive money on their behalf, verify that each committee has the same treasurer.

c. Verify that the Committee Chairperson and the Committee Treasurer are not the same individual

Form DSEB-502 – Campaign Finance Report

Review the campaign finance report(s) received from the State.

a. Verify that all required reports have been filed by the filing deadline on the appropriate report form, covering the correct reporting period.

Note: If the candidate/committee met the requirement to file Form #DSEB-503 – Campaign Finance Statement ($250 or less) but instead filed Form #DSEB-502 – Campaign Finance Report with applicable details, this is not an exception to be cited. The candidate/committee simply went beyond the minimum reporting requirements.

i. First report period (Cycle 1 or Cycle 4 - 6th Tues. pre-primary/election report), for statewide candidates (i.e. Governor, Lieutenant Governor, Attorney General, Auditor General, State Treasurer, Supreme, Superior and Commonwealth Court Judges).

a. Candidates for offices to be voted for by the electors of the State at large must file a 6th Tuesday pre-primary/election report.

b. A committee that expends money for the purpose of influencing the election of a statewide candidate must file a 6th Tuesday pre-primary/election report if expenditure is made on or prior to the cut-off date and exceeds $250.

ii. Second reporting period (Cycle 2 or Cycle 5 - 2nd Friday pre-primary/election report), for all candidates subject to the lottery.

iii. Third reporting period (Cycle 3 or Cycle 6 - 30 day post-primary/election report), for all candidates subject to the lottery.

b. Verify that the proper type of report is indicated on the cover page of the report.

c. Compare the date of the report filing (date stamped received by the State) to the filing deadline and ascertain whether late fees were assessed in accordance with Sec. 1632(a) of the Campaign Finance Reporting Law if the reports were filed after the filing deadline. Such late fees may not be paid from contributions to the candidate or political committee or considered legitimate campaign expenditures. (Note: A report is deemed to have been filed within the prescribed time if it was transmitted by first class mail and was postmarked by the U.S. Postal Service on the day prior to the filing deadline.

2. Determine that the Political Committee Registration Statement, the Authorization for a Political Committee to Receive Funds on Behalf of a Candidate, and the campaign finance reports or statements were filed with the County Board of Elections in the county where the candidate resides. A list of the county contact persons is posted to the Department of State web page at dos.state.pa.us. Due dates for filing the campaign forms with the county boards are the same as due dates for filing with State.

3. Verify that the candidate and committee treasurer have signed the campaign finance reports and the signatures are properly notarized.

Examine all correspondence (if any) between the State and the candidate during the report period being audited to determine if any actions as a result of the correspondence would affect the audit report.

Audit Procedures for Cash Receipts and Disbursements

A. General

1. Verify the mathematical accuracy of each campaign expense report filed with the State. (Note: The State prefers that only those detailed schedules and sections applicable for each candidate/committee be included and filed as part of the campaign finance report; however, no exception is to be noted if all schedules and sections are attached with ones not applicable being marked as such.)

a. Trace beginning cash balance carried forward from previous report to ending cash balance carried forward on that previous report. (Note: must obtain copy of cover sheet of the last campaign finance report filed by the candidate/committee with the State prior to those being audited – this can be obtained from the State, if not already provided).

b. Trace ending cash balance to the beginning cash balance on the subsequent report, if subsequent report is within scope of audit.

c. Verify the footing of the Summary of Receipts and Expenditures on Page 1 (Cover Sheet) of the campaign finance report.

d. Trace the total reported on Lines B, D, F, and G of the Cover Sheet to the appropriate supporting schedules filed with the report.

e. Verify the footing of Page 2 Schedule I – Summary of Contributions and Receipts of the report.

f. Trace the totals reported on Schedule I to the supporting detailed sections filed with the report.

g. Foot the detailed sections (Part A, B, C, D and E) in support of Schedule I receipts.

h. Verify the footing of Schedule II – In-Kind Contributions and Valuable Things Received.

i. Verify the footing of Schedule III – Statement of Expenditures.

j. Verify the footing of Schedule IV – Statement of Unpaid Debts.

Note: Errors noted (if any) while performing previous audit steps a. through j. that result in an improper statement of the ending cash balance should be cited as an exception in the audit report. All other errors should be listed and given to the State for its own internal follow up.

2. Obtain the candidate/committee bank statements, cash receipts journal (deposit slips) and cash disbursements journal (cancelled checks or equivalent) for the audited reporting period.

3. Compare the bank records maintained by the candidate/committee to those listed on the Registration Statement (Form DSEB-500).

4. Note the names of all authorized check signers for all disbursement accounts. The treasurer or assistant treasurer should control political committee disbursements. Verify that the committee treasurer has appointed assistant treasurers, in writing.

5. Complete a proof of cash for the entire reporting period being audited (pre-election and post-election reporting periods are combined and treated as one reporting period).

Note: Any small (not material) differences between the campaign finance report and the bank that exists at both the beginning and end of the reporting period – probably due to O/S checks that never cleared – should not be cited on the audit report; however, the details of such differences should be given to the State for its internal use and subsequent follow up.

B. Contributions and Cash Receipts

1. Confirm directly with the donors the number, amount and dates of all contributions made during the reporting period. Also verify the donor’s occupation and employer if amount contributed by that donor exceeded $250. Confirmation selection should be based on the following criteria:

a. Since we are primarily testing compliance in reporting contributions, the selection should include a representative cross section of all contribution amounts.

i. Select several contributors of over $50 and send standard negative confirmations that have been developed for this engagement.

ii. After the candidates have submitted their documentation, select several contributors of $50 or less and send standard negative confirmations developed for this engagement.

b. If no exceptions are returned (i.e., for incorrect date, unknown addresses), conclude confirmation procedures.

c. If exceptions are received, discuss with supervisor to determine if additional confirms should be sent. If additional exceptions occur from this sample, consult with supervisor and manager for further confirmation procedures.

d. A confirmation should be sent to the contributor for any transactions that were improperly reported, or for which differences between supporting cash records, campaign finance reports and bank records were noted during testing.

2. Perform additional compliance test with regard to cash receipts.

a. Examine the cash receipts records to determine that no contributions were accepted from national or state banks, corporations or unincorporated associations, except corporations formed primarily for political purposes or as political committee. (Contributions from partnerships are permitted.)

i. If any contributions appear to be from corporations, review with Dept. of State Corporation Bureau to determine whether the organization is registered as a corporate entity.

ii. If any contributions appear to be from professional corporations (i.e., several attorney names listed together), review with Corporation Bureau to determine whether the organization is registered as a professional corporate entity.

iii. If Corporation Bureau is unable to verify that a contributor is not a corporation or a professional corporation, mail a standard positive contribution confirmation to the contributor to confirm the amount and date of the contribution and a description of the contributor (i.e., individual, bank, corporation, etc.).

iv. If any exceptions are noted as a result of the above, a confirmation should be sent to the candidate/committee to verify that the information in the cash records and reports is correct. In addition, the staff should confirm with the contributor any possible exception noted above.

b. Examine cash receipts records to determine if any contributions were accepted from anonymous sources or from any person who represented that he was acting as an agent for another person. Verify with the candidate or committee treasurer if any such funds were received and if the anonymous contributions were forwarded to the State Treasurer within 20 days. If such funds were received, examine correspondence to the State Treasurer noting that date of correspondence was within 20 days of the recorded receipt date.

c. Review detailed deposit slips for large deposit of currency. For those deposits showing significant amounts of cash being deposited, review the supporting cash receipts records to determine if aggregate contributions greater than $100 in currency were accepted from any one individual. (Note: Bank deposit slips may not show detail of the amount of currency deposited. If so, review of the cash receipts records and inquiry of candidate/treasurer is sufficient).

If the cash records indicate that a candidate/committee received a contribution of $500 or more ($500 in aggregate from one individual donor) after the final pre-election report cut-off date, but before the date of the election, verify that such contribution was reported to the State supervisor within 24 hours after its receipt by examining late contribution notices filed at the State.

d. Review each cash receipt $50.01 to $250.00 reported on the campaign finance report noting that the name and address (municipality and state is sufficient) are included on the report.

e. Review each cash receipt over $250 reported on the campaign finance report noting that the name, address (municipality and state is sufficient), occupation and name of employer are included on the filed report.

f. Review the underlying cash receipts records maintained by the candidate/committee noting that the name and address of each contributor who gave over $10 is available.

g. If no address is listed for a contributor that gave over $10, contact the candidate/committee for the address and mail a standard negative confirmation to the contributor at the address supplied by the candidate/committee.

h. Review underlying cash receipts records and campaign finance reports to determine that all amounts received from one individual contributor during a reporting period have been aggregated and reported at that aggregate total on the campaign finance report. (Note: the pre-election and post-election reporting periods are considered two separate and distinct reporting periods for this procedure).

i. Review underlying cash receipts records for checks received as contributions but returned NSF. Checks received by the candidate/committee that are returned due to insufficient funds should be shown as a credit amount (separate line item) in the appropriate contributions (receipts) section of the campaign finance report with an appropriate explanation that it was an NSF check unless the check is redeposited (and subsequently clears the bank by the candidate/committee). (Note: an exception is not cited if the NSF check is listed as an expenditure on the campaign finance report rather than as a credit to contributions as preferred; however, the explanation of the expenditure should then note that it was an NSF [returned] check as opposed to an actual cash outlay).

3. Obtain the audit checklist and supporting data from the candidate/ committee treasurer relating to fund-raising events.

a. Review the detail provided by the candidate and treasurer, and inquire whether they have maintained adequate cash receipt records supporting these events to enable identification of donors and contribution amounts in accordance with the Act.

b. Trace totals of cash collected at these events to validated deposit slip and deposit on bank statement. (Note: If this procedure cannot be performed, reliance on the overall proof of cash may be sufficient).

4. Obtain audit checklist and supporting documentation for all loans, rebates or other miscellaneous receipts.

a. Determine if the candidate/committee received any loans during the reporting period and, if so, were all loans reported properly (i.e., loans received must be recorded as a receipt in the summary schedule of receipts and supplemental schedules where appropriate). If such loans are unpaid at the end of the reporting period, they should appear on the schedule of unpaid debts as well.

i. Loans received by a committee from its candidate must be recorded as an expenditure on the individual candidate campaign finance report, as well as being recorded as a receipt on the campaign finance report of the committee.

b. Review loan agreements and other correspondence relating to refunds, rebates, etc., and note that provisions and terms of such agreements are in agreement with what was reported on the campaign finance reports.

c. Validate any loan balances, installment contracts, or other advances from third parties, directly with the payer. Confirm outstanding balance, due dates, interest rate and any other relevant data.

d. If a loan was made to the candidate or another committee of the candidate, trace applicable data to the candidate or committee cash records and campaign finance forms.

e. If an unpaid debt is recorded on the campaign finance report, examine supporting schedule for unpaid debts. If the debt represents a loan, verify the proceeds of the loan were recorded as a receipt. If the loan is not included in the current reporting period receipts, obtain prior campaign finance reports to determine whether the loan was recorded as unpaid debt and as a receipt in the prior reporting period.

f. Compare the balance of unpaid debts from one reporting period to the next. Ascertain that all increases in debt are recorded on schedule or receipts or represent unpaid vendor invoices and all reductions are recorded on the schedule of expenditures as repayment of debt or as payment of previously outstanding vendor invoices.

5. Obtain supporting documentation for in-kind contributions received.

a. Review the campaign finance reports to determine that in-kind contributions were properly reported. In-kind (non-cash) items are not to be included in the total cash receipts or expenditures of the report. They are to be included on Schedule II, In-Kind Contributions and Valuable Things Received, Detailed Summary Page and Line F of the Cover Sheet only. (Note: If in-kind contributions received in a reporting period are over $250, Form DSEB-502 – Campaign Finance Report must be filed with State even if there are no other receipts, expenditures or liabilities incurred).

b. Review the basis by which a value on in-kind contributions, free services, non-cash contributions of items, such as office equipment, transportation, entertainment, etc. was established and determine if it seems reasonable under the circumstances.

c. If the value of the in-kind contribution was indicated by the donor:

i. Examine donor correspondence in support of the value assigned.

ii. Confirm, directly with the donor, pertinent information regarding the contribution, such as the item or service contributed, the value assigned, date of contribution. (Use standard confirmation form developed.)

6. Review the reports to determine that they include a record of any residual unexpended funds. Inquire of the candidate/committee what plans have been made for these funds. (Note: An ending cash balance of zero may be the one indication that residual unexpended funds may have been disposed of during the reporting period).

a. Determine the residual funds were disbursed in the following proper manners:

i. May be used for any lawful expenditure as defined in the Act.

ii. May be returned, pro-rata to all contributors, by the candidate or treasurer. (Note: This manner is rarely used, according to the Bureau of Elections.)

a) Select 50% of the dollar coverage of the contributors, at random, and compare the amount contributed to total contributions. This % multiplied by the residual funds to be returned, should be the amount returned to the contributors.

7. Review committee campaign finance reports, including the supporting detail schedules, and the underlying cash records of the committee, for any transactions with the candidate.

8. Perform a similar review of candidate’s records for any transactions with the committee and verify the committee has properly reported all such transactions.

C. Expenditures and Cash Disbursements

(Note: Ascertain that expenditures are properly documented and reported and the proper approvals are obtained in accordance with candidate/committee procedures.

1. Account for the numerical sequence of the checks (expenditures) reported on Schedule III – Statement of Expenditures.

2. Using standard format designed to show summary of expenditures tested, select a high dollar cut-off (HDC) expenditure amount (HDC will vary for each candidate/committee being audited.)

3. For each expenditure over the HDC reported on Schedule III – Statement of Expenditures on the campaign finance report:

a. Verify that each expenditure is identified as to name and address of vendor, the date paid and the purpose of the expenditure, in accordance with Section 1626(b)(4) of the Campaign Finance Reporting Law.

b. Trace the expenditure to recording in the cash disbursements journal agreeing all data. (Note: If no cash disbursements journal is maintained by the candidate/committee, examination of the cancelled check in the next audit step will suffice).

c. Examine the cancelled check agreeing the amount paid, date paid and name of payee. Note proper endorsement of payee on back of the cancelled check.

d. Examine cancelled check for authorized signature (check signer). Treasurer should control all committee disbursements. Other signers must be appointed by the treasurer, in writing, as assistant treasurers.

e. Examine supporting documentation for the expenditure:

i. Purchase order

ii. Vendor invoice

iii. Voucher

iv. Memoranda

v. Signed receipt

(Note: If no supporting documentation is available for the expenditure, the cancelled check may be sufficient evidence; however, all reasonable efforts should be made to obtain some type of supporting documentation other than the cancelled check).

f. From review of the supporting documentation ascertain that the expenditure falls into one of the lawful categories stipulated in Section 1634.1 of the Campaign Finance Reporting Law and defined in Section 1621(d) of the Campaign Finance Reporting Law. (Note: Specific examples of some lawful expenditures include printing costs; traveling expenses; advertising costs; postage; telephones; stationery; rent of office space; payment of clerks, typists and other employed personnel; transportation of electors to and from polls; employment of watchers at primaries and elections; and contributions to other political committees.)

g. If the campaign-related purpose of the expenditure is not clear, inquire of the candidate/treasurer as to the campaign related purpose of the expenditure.

(Note: Depending on the amount of the expenditure and the quality of the supporting documentation, discuss with audit supervisor the need to confirm certain expenditures; i.e., if the supporting documentation for a large expenditure is poor, consider the need for confirmation).

4. For all other expenditures reported (those under the HDC) verify that the candidate has provided vouchers (cancelled check at the very minimum) for all those over $25.

a. From the description on the voucher or other supporting documentation, ascertain that the expenditure falls into one of the lawful expenditure categories.

5. Review all selected invoices and other supporting documentation for any indications of in-kind contributions, such as services performed with “no charge” listed on invoices or unusual or large % discounts.

6. Confirm with the vendor any expenditure transaction which appears to be an in-kind contribution (i.e., debt is forgiven by vendor) where the amount said differs from the invoice or where a difference exists in the amount recorded in the cash disbursement book, bank records and Campaign Finance reports.

7. Based on exceptions noted during the preceding procedures for expenditures and cash disbursements, discuss with audit supervisor to determine if scope should be extended.

8. For all expenditures made for advertising purposes (See supporting vendor invoices reviewed during other expenditure procedures):

a. Obtain copies of transcripts or actual examples of each specific advertising material or communications advocating the election of the candidate.

i. Note that the advertisement or communication clearly and conspicuously states that the communication was authorized by the candidate or committee or clearly and conspicuously states the name of the person who made or financed the expenditure for the communication. Note that the disclaimer need not appear on pins, pens, buttons, bumper stickers and similar small items on which it cannot be conveniently printed. Consider confirmation of advertisements with vendors on a test basis. Prepare a control list of advertisements confirms.

D. Other Procedures

1. Perform a search for unrecorded liabilities.

a. Examine all disbursements made between the report cut-off date and the date the report was filed.

b. Review supporting invoices and determine from description on invoices when the services were performed. If the invoice date indicates goods delivered or services performed prior to the day the report was filed, trace the item to inclusion in unpaid debts. (Note: monthly office rent or equipment lease payments to be made need not be included as an unpaid debt or obligation at the end of the reporting period as long as the payments are current).

c. List all invoice amounts applicable to the reporting period and not recorded as unpaid debts in b. above on a separate work paper.

d. Review any schedules of unpaid debts filed with the campaign finance reports. If there are unpaid debts for the pre-election reporting period, trace the items listed to payment in the following period’s campaign finance report (30 day post-election report) or continuation of the debt.

2. Consider confirmation of accounts payable with vendors if internal controls are deemed lacking. Review debt settlement practices to assure that settlements with corporate vendors are not actually in-kind contributions. Determine whether normal vendor collection practice appeared to have been conducted with the candidate/committee, e.g., was account turned over to collection agency for nonpayment? Was payment waived although committee/candidate still had cash balances and was solvent? Did vendor attempt collection through installation agreement?

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