Description
The complaint alleged the Monroe Street Business Association and Gary Jarvis may have violated RCW 42.17A.205 by failing to register as a political committee, RCW 42.17A.255 by failing to report an independent expenditure, and RCW 42.17A.320 by failing to list sponsor identification on political advertising.
Patrick Keegan stated he purchased the billboard on behalf the Monroe Street Business Association, which is why he listed the organization as the sponsor. Keegan also stated he was unaware of the requirements of political advertising, and had relied on legal counsel from Dunn & Black, P.S. Once he was educated on the definition of political advertising and independent expenditures, on November 13, 2019, Keegan sent a C-6 Independent Spending and Electioneering Communications form to the PDC, reporting a $5,100 independent expenditure against three Spokane City Council members (Breean Beggs, Candace Mumm, and Karen Stratton) for a billboard from November 2016 to June 2017.
Based on information provided in the complaint and responses, the Monroe Street Business Association did not meet the definition of a political committee as defined in RCW 42.17A.005(37). Based on these findings, staff has determined in this instance the alleged failure to register as a political committee, report an independent expenditure, and list sponsor identification on political advertising does not amount to a violation warranting further investigation.
Pursuant to WAC 390-37-060(1)(d) Patrick Keegan will receive a formal written warning concerning the requirement to report independent expenditures that support or oppose candidates. The formal written warning will include staff's expectation Patrick Keegan will report all political advertising in the future in accordance with PDC laws and rules.
The Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.
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).