The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Glen Morgan on August 22, 2017. The complaint alleged that Myron (Mike) Kreidler, the incumbent Washington State Insurance Commissioner and a candidate for re-election to that office in 2016, may have violated Chapter 42.17A RCW as detailed below.
PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the responses provided by Mike Kreidler; 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 Friends of Mike Kreidler Campaign (Campaign) to determine whether the record supports a finding of one or more violations.
As noted in the letter to the complainant, a number of 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 filed 22 amended C-3 reports and 39 amended C-4 reports dating back to 2004, demonstrating a good faith effort to provide additional and/or updated disclosure information as the Campaign became aware of it.
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. 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 an amended C-4 report disclosing the station by station breakdown for the $48,000 expenditure made to Cerillion N4 Partners for a Cable TV Buy. 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.
The issues above are mitigated by the fact that the Campaign was in frequent contact with PDC staff throughout the 2016 election in order to comply with the reporting requirements, and timely filed the overwhelming majority of the initially filed C-3 and C-4 reports. In addition, the Campaign disclosed receiving more than $130,000 in contributions received and spent more than $120,000 in expenditures.
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, please be 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).