Audit Process

The post-election audit happens in three stages:

Initial Documentation Request (IDR)

• This is the first step of the post-election audit. It is the first opportunity following the election to provide documentation not previously submitted (and includes a checklist for your convenience!). 

• This documentation request includes reports of unreported, misreported, and uncleared transactions, similar to the reports in your statement reviews. 

• Requests specific forms and reports from the campaign such as the Subcontractor Disclosure form, C-SMART Fundraising Events report, and the required post-election forms. 

• During this stage, you must ensure that copies of paid campaign communications (such as flyers, mailers, and posters) and all other expenditure documentation have been uploaded to C-SMART. This will help reduce the amount of potential requests that would be sent in the next documentation request, the Draft Audit Report.  
  

Draft Audit Report (DAR) 

• This is the second step of the post-election audit. It is another opportunity to submit  documentation, update C-SMART reporting and submit explanations to the CFB related to your campaign’s compliance.  

• A comprehensive review of the documentation submitted through your IDR response is performed to compile the DAR.  

• Given the extensive nature of this request, the DAR will include preliminary findings of non-compliance with the Campaign Finance Act and CFB Rules. Examples include over-the-limit or prohibited contributions, non-campaign-related expenditures, missing bank documentation, and late or missing disclosure statements. 

• The DAR includes a qualified expenditure report for public funds recipients. This report details how many expenditures are qualified based on submitted documentation, and what documentation is needed to qualify additional expenditures. 

• The DAR includes any potential public funds repayment obligations. 

• Not responding to the DAR can result in serious penalties, in addition to penalties related to non-compliance and any repayment obligations. 

Enforcement Notice and/or Public Funds Repayment Obligation 

• Not all campaigns receive an Enforcement Notice and/or Public Funds Repayment Obligation. 

• Enforcement Notices are for DAR findings that were unaddressed or insufficiently addressed in the campaign’s response.  

• Public Funds Repayment Obligations may come in your DAR, Enforcement Notice, or in a separate email communication. 

• The Enforcement Notice is one more opportunity to respond to audit findings before the audit is sent to a Board hearing. 

• Campaigns work with CFB lawyers to respond to the Enforcement Notice. Your Candidate Services Liaison is not able to assist or answer questions regarding the Enforcement Notice. 

Final Audit Report (FAR) 

• This report will be sent to your campaign to conclude the post-election audit.  

• The FAR details any findings, violations, and penalties determined by the Board.  

• The FAR details any public funds repayments owed to the Public Fund.  

• If a post-election public funds payment is due to the campaign, it will be issued with the final audit.
  
  
• The FAR is posted to your CFB Portal account and published for the public on the CFB's website. 

Response Deadlines and Extensions 

As of July 2025, the CFB has implemented the following policies regarding response deadlines and extension requests. 

Initial Documentation Request (IDR): 

• Response due within 30 days of the IDR’s issue date. The exact deadline will be stated on the cover letter of your IDR. 

• Campaigns may request up to a two-week extension from the original response deadline, if necessary. 

• Under unforeseeable extenuating circumstances, an additional two-week extension may be granted. 

Draft Audit Report (DAR) 

• For campaigns that did not receive public funds, the response deadline for the DAR will be 30 days from the date the DAR is issued. 

• For campaigns that received public funds or could potentially receive public funds post-election, the response deadline for the DAR will be six weeks from the date the DAR is issued. 

• Under unforeseeable extenuating circumstances, an additional four-week extension may be granted. 

• No addition extensions will be granted beyond this for all election cycles. 

How to Request an Extension: 

• Extension requests must be made in writing to AuditMail@nyccfb.info at least 48 hours prior to your campaign’s response deadline. Please copy your assigned Candidate Services liaison in your request and include the candidate’s name, election cycle and a brief explanation for the request. 

• For extension requests based on extenuating circumstances, campaigns must also submit documentation explaining and demonstrating these circumstances. Unforeseeable extenuating circumstances are events beyond the control of the campaign that make it impossible for the candidate or treasurer to respond in a timely manner. 

Extension requests are subject to the CFB’s approval, and a written determination will be sent to campaigns via the CFB Portal within 24-48 business hours from the request. 

Post-Election Audit Deadlines 

The Campaign Finance Act sets the following deadlines for the CFB to complete a campaign’s draft audit report and final audit report for campaigns that have submitted a final disclosure statement. The deadline is calculated from submission of the final disclosure statement. 

These DAR and FAR completion deadlines do not apply if your audit raises issues of serious violations. These include potential campaign-related fraud, other potential criminal activity, activity that may result in a breach of certification, or potential significant violations of the spending limit. 

Additionally, deadlines will be extended (in the Campaign Finance Act, this is called “tolling”) if your campaign: 

• submits a late response to any request for information; 

• submits an inadequate response to any request for information; 

• requests an extension to its response deadline; or 

• consents in writing to an extended deadline. 

You will receive a notice in the Message Center of your CFB Portal account if the deadline to complete the DAR and/or FAR is extended for any reason. If the delay is caused by a late or inadequate response by your campaign, the deadline is extended until an adequate response is received. If the CFB asks for and your campaign grants additional time to complete the audit, the deadline will be extended for the number of days agreed upon. If the CFB grants your request for an extension, the deadline will be extended for the number of days agreed upon.