Section 9-13(c) of the Illinois Election Code requires the Illinois State Board of Elections to select a specified percentage of registered political committees for an audit. 26 Illinois Administrative Code 100.175, paragraphs e and f outline the areas that should be covered and included in the practitioner’s report to the Board of Elections.
With regards to this Illinois State Board of Elections (Board) requirement, the term “audit” is an undefined statutory term other than the guidance and criteria outlined in paragraphs e and f of the above-cited administrative rules. The statute’s use of the term “audit” for this purpose is inconsistent with accounting standards and the assurance that attaches with the standards.
In consultation with the Board, it is the Illinois CPA Society’s interpretation that the ISBE requirement is tantamount to “other attest engagements outlined in Section 8.05(a)(2) of the Illinois Public Accounting Act (225 ILCS 8.05).
In complying with random selection of political committee audits, the Board is looking for a good faith effort of compliance. CPAs should closely follow the guidance outlined in paragraphs e and f of the administrative rules and include that information in the reported to be submitted to the Board.
By the use of the undefined statutory term of “audit” for this requirement, the Board is not looking for assurance that would normally attach to an audit in accordance with audit standards. Rather, the Board is receptive to a wide range of submissions; the greater the number of transactions (by the dozens), the more detail and information that should be included in the report.
If the Board requires additional information after the initial report submission, they will notify the political committee of the information they require to satisfy the statutory requirement. As long as the political committee has made a good faith effort of compliance of the random audit by filing a report, the Board will not impose a fine on the committee if it is determined that additional information may be required.
Questions should be directed to either Mr. John Levin or Tom Newman of the State Board of Elections at 217.782.4141.
Illinois Election Code (10ILCS 5/9-13)
Illinois Administrative Code, Title 26, Sect. 100.175
Illinois Public Accounting Act (225 ILCS 450/8.05)