Snohomish County GOP Leaders Fund: Alleged violations of RCW 42.17A.205 for failure to timely register as a political committee, and RCW 42.17A.235 for failure to accurately and timely report contributions and expenditures (June 2017)

Case

#19239

Respondent

Snohomish County GOP Leaders Fund

Complainant

Ramay Donny

Description

This complaint alleged that Snohomish County GOP Leaders Fund (the "Respondent") violated RCW 42.17A.205 for failure to timely register as a political committee after making contributions to Friends of Nate Nehring on 2/21/17, and RCW 42.17A.235 for failure to accurately and timely report contributions and expenditures. 

PDC staff reviewed the allegations, statutes, rules, and reporting requirements, the Respondent's registrations, C-3 & C-4 reports and found the following: The Respondent 1) was registered as a political committee; 2) failed to file the required C-4 reports between 2012-2018; 3) only filed a total of eight C-3 reports for 2012, 2013, 2014 & 2015, including amendments; and 4) did not file any C-3 reports for 2016-2018. 

In February of 2019, the Respondent informed PDC staff that it currently qualifies for the Mini Reporting Option, and retroactively qualified for the Mini Reporting Option for years 2016-2018, despite having selected the Full Report Option on its committee registrations (C-1PC reports). Committees that receive less than $5,000 in contributions, receive and make less than $5,000 in expenditures in a calendar year, and receive no more than $500 in aggregate contributions from a single contributor qualify for the Mini Reporting Option and are subsequently not required to file C-3 & C-4 reports disclosing contribution & expenditure activities. 

On February 14, 2019, the Respondent filed a new C-1PC committee registration for 2019, selecting the Mini Reporting Option, and three amended registrations for 2016-2018, retroactively claiming the Mini Reporting Option. The Respondent also disclosed to the PDC its 2017 contribution & expenditure activities, including $2,000 in contributions to the Nehring campaign. 

The Respondent does not have any prior violations or complaints filed with the PDC and is a relatively small, unsophisticated committee with modest expenditures totaling less than $5,000 a year, which would have qualified it for the Mini Reporting Option. Based on these facts, PDC staff has determined that, in this instance, the failure to file C-3 & C-4 reports disclosing contribution & expenditure activities under the Full Reporting Option does not amount to a finding of an actual violation warranting further investigation. 

The PDC formally warned the Respondent of the importance of timely and accurately filing C-3 & C-4 reports disclosing contributions & expenditures as required by PDC laws and rules for a committee under the Full Reporting Option. This formal warning conveys staff's expectation that the Respondent will fully comply with the C-3 & C-4 reporting requirements in the future, should it select the Full Reporting Option on its C-1PC committee registration or exceed the limitations of the Mini Reporting Option. The Commission will consider this formal written warning if there are any future PDC law or rule violations by the Respondent. Based on this information, the PDC has dismissed the complaint in accordance with RCW 42.17A.755(1).

Disposition

Case Closed with Written Warning

Date Opened

June 02, 2017

Areas of Law

RCW 42.17A.205, RCW 42.17A.235

Documents

• 19239 Snohomish Co GOP Leaders Fund Response.pdf
• 19239 Snohomish Co GOP Leaders Fund Complaint.pdf
• 19239 Snohomish Co GOP Leaders Fund Warning Letter.pdf