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  • FEC Record: Compliance

Comments sought on proposed embezzlement policy

November 1, 2006

The Commission requests public comment on a proposed enforcement policy regarding reporting errors that result from a misappropriation of funds. A companion document proposes internal controls that political committees could use to guard against embezzlement and unintentional reporting errors. Under the proposed policy, committees that implement certain minimum safeguards would not be held liable if a subsequent misappropriation led to reporting errors. Comments on both documents are due by November 30, 2006.

The Commission’s proposal responds to a recent increase in the number of enforcement cases involving misappropriation of committee funds, often by committee employees. To address this problem, the Commission proposes that political committees adopt certain internal controls aimed at reducing the incidence of misappropriation.

The proposed safeguards, developed by the FEC’s Audit Division, draw upon established accounting practices and other sources, including the Small Business Administration (SBA) and the Government Accountability Office (GAO). Some of the recommended safeguards include regular account reconciliations and the separation of accounting duties.

The Commission asks that members of the regulated community and other interested persons submit comments on these proposals either by e-mail to, or in written form to Federal Election Commission, 999 E Street NW, Washington, D.C., 20463, ATTN: Joseph Stoltz. The Commission strongly encourages commenters to use electronic mail to ensure timely receipt and consideration. Both the proposed enforcement policy and the internal controls document are available on the Commission’s website. For more information, please contact the FEC Audit Division Director Joseph Stoltz at 202/694-1200 or 800/424-9530.