[Lpk-execomm] Campaign finance

[Ken Moellman]

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