Case #24638
Respondent name: Pam Roach
Complainant name: Walter Smith

The complaint filed on September 1, 2017 alleged that during her 2016 campaign for Pierce County Council, Pam Roach may have violated:

  1. RCW 42.17A.235 and .240 by failing to timely file C-4 reports of contributions and expenditures on two occasions, totaling $1,381, filed 332 total days late; 
  2. RCW 42.17A.235 and .240 by failing to timely file C-3 reports of contributions received on five occasions, totaling $7,750, filed a total of 539 days late;
  3. RCW 42.17A.220 by failing to timely deposit contributions received into the campaign account, within five business days, on three occasions, totaling $1,950, deposited a total of 70 days late;
  4. RCW 42.17A.240(6) as implemented by WAC 390-16-037 and WAC 390-16-205 by:

A.  Reporting a payment to “Visa” of $1,374.20 for payment of a Labels and Lists invoice without listing the vendors providing the services, with such information being 318 days late as of the date the complaint was filed.

B.  Reporting an obligation/debt to “Chase Cardmember Services” of $10,111.52 without listing the vendors owed that provided the services, with such information being 304 days late as of the date the complaint was filed.

C.  Reporting a payment to “Chase Cardmember Services” of $10,111.52 without listing the vendors or sub vendors actually paid that provided the services, with such information being 263 days late as of the date the complaint was filed.

Staff found:

Alleged Violation of RCW 42.17A.235 and .240 by failing to timely file C-4 reports of contributions and expenditures on two occasions, totaling $1,381, filed 332 total days late. 

  • On 5/24/16, the campaign filed a C-4 report for October 2015, reporting contributions totaling $4,450 and expenditures of $375.  The report was filed 196 days late, but over five months before the November 8, 2016 general election. The contributions were timely reported on C-3 reports.
  • On 5/25/16, the campaign filed a C-4 report covering December 2015, reporting contributions totaling $15,800 and expenditures of $1,006.  The report was filed 136 days late, but over five months before the November 8, 2016 general election.  The contributions were timely reported on C-3 reports.

Alleged Violation of RCW 42.17A.235 and .240 by failing to timely file C-3 reports of contributions received on five occasions, totaling $7,750, filed a total of 539 days late;

  • When Ms. Roach filed her initial C-1 on 9/3/15, she was required to report all contributions received and expenditures made prior to that date.  She received $1,800 in contributions prior to 9/3/15 that were not reported on C-3 reports until 10/13/15, 40 days late.
  • In addition, the campaign reported contributions totaling $5,950, with contributions totaling $1,850 reported 163 days late and contributions totaling $4,100 reported 133 days late.

Alleged Violation of RCW 42.17A.220 by failing to timely deposit contributions received into the campaign account, within five business days, on three occasions, totaling $1,950, deposited a total of 70 days late.

  • The campaign received a $500 contribution on 10/22/15 that was required to be deposited by 10/29/15.  It was deposited 39 days late on 12/7/15.
  • The campaign received two contributions, one for $500 on 11/10/15 and one for $950 on 11/12/15, that were required to be deposited no later than 11/19/15.  They were deposited 12/4/15, 15 and 16 days late.

Alleged Violation of RCW 42.17A.240(6) as implemented by WAC 390-16-037 and WAC 390-16-205 by:

A.  Reporting a payment to “Visa” of $1,374.20 for payment of a Labels and Lists invoice without listing the vendors providing the services, with such information being 318 days late as of the date the complaint was filed.  Eileen Erickson, who took over as Treasurer in May 2016, after Conner Edwards stopped serving as Ms. Roach’s Treasurer, stated that the 10/11/16 payment to “Visa” of $1,374.20 was actually a reimbursement to Ms. Roach for using her personal Visa to purchase lists from L2political.com.  On 9/26/17, Ms. Erickson filed an amended C-4 for the period 9/1/16 to 10/17/16 and correctly reported the $1,374.20 expenditure as a reimbursement to Pam Roach with a description of “Check made out to Visa to reimburse Pam Roach for L2political.com invoice.”  The amendment was filed 343 days late.

B.  Reporting an obligation/debt to “Chase Cardmember Services” of $10,111.52 without listing the vendors owed that provided the services, with such information being 304 days late as of the date the complaint was filed.  Ms. Erickson stated that the $10,111.52 debt was to Ms. Roach’s consultant, and not to Chase Cardmember Services, as stated on the initial C-4 report filed 11/1/16.  On 9/26/17, Ms. Erickson filed an amended C-4 for the period 10/18/16 to 10/31/16, properly disclosing a debt on Schedule B, Part 3, listing the Vendor as GTT/FAA Partners, Burien, WA, with a description of, “consult/design 10,000 sub vendor L2political.com 111.52.”  The amendment was filed 329 days late.

C.  Reporting a payment to “Chase Cardmember Services” of $10,111.52 without listing the vendors or sub vendors actually paid that provided the services, with such information being 263 days late as of the date the complaint was filed.  On 9/26/17, Ms. Erickson filed an amended C-4 for the period 11/1/16 to 11/30/16, disclosing a monetary expenditure on Schedule A to GTT/FAA Partners, with a description of “GTT/FAA Partners, Consult/design flyers $10,000, sub-vendor.”  The amendment was filed 288 days late.

Eileen Erickson, Treasurer for Ms. Roach, was prompt and thorough in her response when asked by staff about the alleged violations.  She immediately filed amended reports to clarify the reimbursement to Ms. Roach and the obligation and later payment to GTT/FAA Partners.

The late-reported C-4 and C-3 reports were for 2015 contribution and expenditure activity and, although late, were filed five months before the 2016 election.  Also, the late deposits of contributions occurred in 2015.

Disposition: Resolved through Statement of Understanding (Resolved 08/23/2019)
Date opened: 09/05/2017
Area of Law: RCW 42.17A.220, RCW 42.17A.235, RCW 42.17A.240, WAC 390-16-037

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