Post-Election Audit Process:
Frequently Asked Questions About the Draft Audit Response

The draft audit report is the document sent to your campaign after the election summarizing the CFB’s preliminary audit findings.  The report is based on the CFB staff’s review of the documents submitted by your campaign throughout the election and in response to the initial documentation request.  The report may contain preliminary findings of potential violations of the Act and Rules as well as potential public funds repayment obligations. Your campaign’s response to the draft audit report is an opportunity to resolve these matters.  The draft audit report is not a public document and does not represent any final determination by the Board.

The CFB’s publication, Post-Election Audit Deadlines, found here, illustrates the post-election timeline.

A complete response requires that each finding be fully addressed.  This usually requires a two-part response consisting of a narrative and documentation for each finding.  The narrative is the explanation of what happened and the documentation is evidence supporting that explanation.  Often, findings will also require amendments to your disclosure statements.  All necessary amendments to disclosure statements, documentation, and narratives should be submitted together on or before the due date.  Additionally, it is important to label the narrative and documentation with the corresponding finding number and section.

CSU offers Draft Audit Report trainings (see calendar).

A finding is a specific issue listed in the draft audit report that must be addressed by your campaign.  A finding is not an accusation or an assessment of penalties.  It is a question or a request for clarification or information.  Each finding is accompanied by a recommendation on how best to address the finding.  Each finding should be addressed individually in the campaign’s response.

Yes.  All extensions must be requested in writing to your auditor.  Be sure to include the candidate name, election cycle, and the additional amount of time you need to respond.  If you ask for an extension, you will delay the completion of the audit process. 

Yes. The CFB developed a training program designed to walk you through the process and help you understand some common findings and recommendations. CSU offers Draft Audit Report trainings (see calendar).  Contact your CSU liaison if you would like to schedule a session. Meanwhile, if you have any questions, you can call your CSU liaison, who will either answer your questions or connect you with an auditor. Please see the Post-Election Audit Deadlines, found here, for more information on how attending this training will affect the completion of the audit process.

Yes, it is important that each finding be answered by documentation even if the documentation was submitted previously. The documentation and narrative should be clearly labeled with the finding number and any applicable statement and transaction ID numbers. In some cases, the same document will be needed to respond to multiple findings; please list all applicable references on the document.

Please read the finding carefully to understand whether the CFB is asking for additional documentation, or clarification of documentation previously submitted. The CFB always tries to avoid asking you for documents you have previously submitted .

In almost all cases, the answer will be yes. Findings in the draft audit report often raise reporting issues that must be addressed by making additions and corrections in C-SMART.

After data entry is complete, in order to see which statements were modified, the campaign should run the Modified Statement Report in C-SMART. Run and submit amendments for each statement listed. Additionally, you should run an amendment for the last statement of the election cycle because new transactions will only appear in that disclosure statement. Remember, entering or modifying a transaction in C-SMART does not update the information on file with the CFB. If you make changes in C-SMART without filing amendments you will be looking at data that are different than what is on file with the CFB.

A thorough response addresses each finding contained in the draft audit report in the order presented and includes narrative explanation, documentation, and amendments to disclosure statements, as needed.  All documents are clearly referenced with finding numbers, as well as statement and transaction ID numbers (if appropriate).  Documents are submitted in the order of the findings and are in the order they are discussed in the narrative.  Specific requested documents are included and identified.  All documents are legible.  CFB staff can follow your response.  Please note that a thorough response does not guarantee that all findings will be completely resolved and does not guarantee that there will be no findings of violation and no repayment obligations.

You will be assessed a substantial financial penalty (Campaign Finance Act §3-711(2)(b)).  In addition, unanswered findings in your draft audit report will be referred to the CFB Legal Unit for assessment of separate penalties.

If a final public funds payment is due to the campaign, it will be issued with your campaign’s final audit.  See Post-Election Public Funds Payment Information, found here, for more detail.

Once the draft audit response is received, the CFB staff will perform a review of the response.  The more fully and completely you respond to the draft audit report, the easier the process will be.  There may be additional questions asked or additional documents requested.  If necessary, the staff will recommend that penalties be assessed and that public funds be returned, in which case you will be notified and have an opportunity to respond.   A final audit is only issued after the Board makes a final determination regarding both penalties and repayment obligations.  The final audit reports are published on the CFB’s website after being sent to your campaign.