A complaint was filed against Service Employees International Union Political Education & Action Fund (SEIU PEAF), a federal political committee, alleging violations of: (1) RCW 42.17A.250 by failing to timely and accurately file Out-of State Political Committee reports (C-5 reports) as an out-of-state committee: (2) RCW 42.17A.405 by failing to receive $10 from ten registered voters in Washington State prior to making contributions to candidates; and (3) RCW 42.17A.442 by failing to received $10 from ten registered voters in Washington State prior to making contributions to another political committee.
As noted in the complaint return letter, SEIU PEAF failed to timely report $1,534,947 in contributions received from SEIU in Washington, DC for the 2018 elections, and that information was not disclosed until March 12, 2019 when the amended C-5 reports were filed. While the amount of late reported contributions was significant, there were several mitigating factors considered by staff that included SEIU PEAF:
(1) disclosed no additional expenditures as having been made in 2018 on the amended C-5 reports;
(2) timely disclosed the $747,983 in expenditures made as contributions to political committees in Washington state and registered with the PDC on the initial C-5 reports;
(3) did not spend any of the $1,534,947 in late reported contributions received from SEIU in Washington state; and
(4) received a total of $8,128,222 in aggregate contributions from SEIU in Washington, DC, so the $747,983 spent in Washington state in 2018 by SEIU PEAF, represented 9.2% of total expenditure activities.
Based on these findings, PDC staff has determined that the facts in this instance do not amount to a finding of an actual violation warranting further investigation. However, pursuant to WAC 390-37-060(1)(b), PDC staff will be formally warning SEIU PEAF concerning the importance of timely and accurately filing C-5 reports disclosing contribution and expenditure activities undertaken by an out-of-state political committee as required by PDC laws and rules.
This formal written warning conveys staff’s expectation that SEIU PEAF will fully comply with the C-5 reporting requirements in the future, should the committee make additional contributions to candidates or political committees registered with the PDC in Washington State. The Commission will consider this formal written warning if there are any future PDC law or rule violations by SEIU PEAF.
Based on this information, PDC staff is dismissing the remaining allegations in this matter against the Service Employees International Union Political Education & Action Fund PAC in accordance with RCW 42.17A.755(1).
Disposition: Case Closed with Written Warning (Resolved 05/07/2019)