All - We have received a letter from KREF regarding a campaign finance violation due to the late submission of the 2018-1H report, with a "Conciliation Agreement" asking for $270 ($50 + $10 per day). To avoid lengthy conversation on the conference call on Thursday, I wanted to outline the situation here. The CRM will help, but that doesn't account for counter deposits. These really need to be tracked and run through the treasurer so whoever that treasurer is doesn't have to go through all sorts of hoops to get the information. What I am going to suggest on Thursday is as follows: (1) LPKY Executive Committee agrees to the Conciliation Agreement, and will send payment to KREF by Monday. (2) I will personally donate $300 to the party on Friday, of which $30 will be renewal of my dues and $270 will be a tagged donation toward paying the fine. (3) LPKY Executive Committee creates a bylaw to have EVERY transaction, including and especially counter deposits, go through the Treasurer or through the State party website (CRM), so the Treasurer knows where money came from and went. Any donations received without the treasurer present will include a form capturing the Name, Address, Occupation, and Employer of that donor, unless specifically tagged as an anonymous donation per KREF guidelines. (Ideally, this would come through Rules, but that committee hasn't met in two months.) The background: I resumed duties as Treasurer on April 1st, and got the records about a week later. I was informed by the outgoing treasurer that there were issues with the 2017-2H report. I audited the books and the 2017-2H report, and indeed there were mistakes in filing. Filing an amended report required significant forensic accounting. Most painful were the counter deposits, which required numerous trips to the bank to get information, and then getting the required information for each person. KREF was informed of the issue on May 1st, and was informed that we were working in good faith to resolve it. This process of correcting the books for 2017-2H continued until July 31st, when the 2017-1H amended report was sent to KREF. Simultaneously during this period, KREF also sought corrections to historical D4 reports and reports for defunct affiliate parties as well. The 2018-1H report was due on July 31st. Because 2017-2H wasn't completed until that day, we were definitely going to be late. Again, KREF was informed of the issue, and that we were working in good faith to get the 2018-1H report submitted ASAP. The process to build the 2018-1H report took 21 days. Again, counter deposits caused most of the pain, and a research request from BB&T was returned on August 21st, the report was finalized that night, and the report was mailed the following day on August 22nd. In October, the 2018-1H report was desk-audited, and found to have an error (separate page for reporting convention/event income was missing). This error was corrected and sent back to KREF a week later. I received the letter from KREF on December 3rd, with a notice that they would like a reply by the 13th. -- Ken C. Moellman, Jr. LPKY State Party Treasurer
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Ken Moellman