Friends of Community and Technical Colleges PAC: Alleged violation of RCW 42.17A.235 & .240 for failure to timely and accurately report campaign expenditures (EY24 APR24)

Case

#153132

Respondent

Friends of Community and Technical Colleges PAC

Complainant

Glen Morgan

Description

A complaint was filed against the Friends of Community and Technical Colleges PAC, a political committee registered with the PDC, alleging a violation of RCW 42.17A.235 and .240 by failing to timely and accurately file a Summary Full Campaign Contribution and Expenditure report (C-4 report), disclosing all expenditure activities made during the month of March 2024.

On May 19, 2019, the Committee filed an Amended Committee Registration (C-1pc report) as a continuing political committee under the Full Reporting Option, listing Marty Brown as Treasurer, and Anne Fennesey as the Committee Manager or Media Contact.  

The complaint alleged that the Committee made a $200 contribution to Debra Entenman, a 2024 State Representative candidate seeking re-election to that office in the 47th Legislative District and failed to disclose the contribution.  Staff’s review confirmed that on April 9, 2024, the Debra Entenman Campaign filed a Monetary Contributions report (C-3 report) disclosing the receipt of a $200 monetary contribution from the Committee on March 31, 2024, that was deposited the same day.

Based on PDC staff’s initial review, the Committee filed the March 2024 C-4 report early on March 9, 2024, disclosing a $500 expenditure made to Mi Centro in Tacoma, with the description “Charity” but the C-4 report did not include the $200 contribution.  WAC 390-05-400 is the PDC rule entitled “Changes in dollar amounts” and included in the chart for the changes in calendar year 2023, the value for itemizing expenditures under RCW 42.17A.240(7) was increased from $50 to $200.

On Thursday, May 2, 2024, Mr. Brown the Committee  Treasurer submitted a response within an hour of receiving the complaint from PDC staff, stating that the Committee sent a $200 contribution check to Debra Entenmann on November 18, 2023 prior to the legislative freeze period and reported it on December 2, 2023 (Report #110190502). Mr. Brown added that the Debra Entenman Campaign did not cash the $200 check until March 31, 2024.

Staff confirmed that on December 2, 2023, the Committee timely filed the 2023 Post-General Election C-4 report covering the period October 31 through November 30, 2023, disclosing $1,334 in monetary contributions received and $4,391 in expenditures made.  The C-4 report disclosed a $352.11 expenditure made to Wix for Committee website work, and $4,038 in "non-itemized expenditures" during the period, that the committee said included the $200 contribution made to the Debra Entenman Campaign which was below the expenditure threshold required to be itemized.

PDC staff found no evidence of a violation that would require conducting a more formal investigation into the complaint or pursuing any enforcement action in this instance. Based on the above rule, the Committee was not required to itemize the $200 expenditure/monetary contribution made to the Debra Entenman Campaign, since it did not exceed the $200 threshold found in WAC 390-05-400.  PDC staff dismissed this matter in accordance with RCW 42.17A.755(1).  

Disposition

Case Closed with No Evidence of Violations

Date Opened

May 02, 2024

Areas of Law

RCW 42.17A.235, RCW 42.17A.240

Documents

• 152956 Friends of Community and Technical Colleges PAC Complaint.pdf
• 153132 Friends of Community and Technical Colleges PAC response.pdf
• 153132 Friends of Community and Technical Colleges PAC dismissal ltr.pdf