Podlodowski, Tina: Alleged violations of Chapter 42.17A RCW for failure to timely and accurately report debts, contributions, expenditures, and committee officers (June 2017).

Case

#19370

Respondent

Tina Podlodowski

Complainant

Glen Morgan

Description

The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Glen Morgan on June 2, 2017. The complaint alleged that Tina Podlodowski, a 2016 candidate for the office of Washington State Secretary of State, may have violated several provisions of Chapter 42.17A RCW as detailed below. 
PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the responses provided by Tina Podlodowski; queried the Respondent’s data in the PDC contribution and expenditure database; and reviewed the Candidate Registrations (C-1 reports), Monetary Contributions reports (C-3 reports), and Summary Full Campaign Contribution and Expenditure reports (C-4 reports) filed by the 2016 Voters for Tina Campaign (Campaign) to determine whether the record supports a finding of one or more violations. 

Staff did note there were expenditures made by the Campaign, either as reimbursements to individuals or volunteers, or payments made to a consultant or vendor for which it appears a more detailed description and possibly a sub-vendor breakdown likely should have been provided.  The response provided by the Campaign identified several items where run dates and number of items printed should have been included.

At the request of staff, the Campaign amended their reports to provide additional detailed disclosures and bring the 2016 Campaign into compliance, which included filing  amended C-4 reports disclosing the run dates and the number of items printed for political advertising expenditures.  Staff would classify these issues as reporting discrepancies which are minor or technical in nature and does not believe the violations rise to the level of any enforcement action.

As noted in the letter to the Complainant, several the allegations listed in the complaint concerned information disclosed on amended C-3 and C-4 reports filed by the Campaign. Staff’s review of the initial and amended C-3 and C-4 reports filed by the Campaign confirmed a good faith effort was made to comply with the PDC reporting requirements for the 2016 election. Staff found that the Campaign: (1) filed 6 amended C-3 reports and 18 amended C-4 reports, demonstrating a good faith effort to provide additional and/or updated disclosure information as the Campaign became aware of it; (2) were in frequent contact with PDC staff throughout the 2016 election in order to comply with the reporting requirements; and (3) timely filed the overwhelming majority of the initially filed C-3 and C-4 reports disclosing  $923,668 in total contributions received and total expenditures made.  

PDC staff found no evidence of a material violation that would require conducting a more formal investigation into the complaint or pursuing enforcement action in this instance. However, staff has reminded the Campaign to provide a more detailed breakdown for expenditures made to reimburse individuals or payments made to consultants or vendors, including the sub-vendor and TV station breakdown, in the future. In addition, Tina Podlodowski will be made aware of the changes to the disclosure of debt and other reporting requirements as part of the passage of ESHB 2938 (2018).  

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1). 
 

Disposition

Case Closed with Reminder

Date Opened

June 05, 2017

Areas of Law

RCW 42.17A.205, RCW 42.17A.235, RCW 42.17A.425

Documents

• 19370 Podlodowski Tina Complaint.pdf
• 19370 Podlodowski Tina Response.pdf
• 19370 Podlodowski Tina Reminder Letter.pdf