Washington Fairness Coalition: Alleged violation of RCW 42.17A.320 for failure to disclose, in sponsor identification, the top 3 donors to the political committees listed as top 5 contributors. (EY '19; Oct '19)

Case

#59437

Respondent

Washington Fairness Coalition

Complainant

Glen Morgan

Description

The complaint alleged Washington Fairness Coalition, a 2019 Ballot Proposition Committee supporting Referendum 88, may have violated RCW 42.17A.320 by failing to disclose the “Top Three Donors to PAC Contributors” in political advertising.

Because incidental committees are not political committees, they may be listed as a Top 5 Contributor without further disclosure concerning the incidental committee. You also alleged WFC needed to disclose the Top 3 Donors to the Seattle Foundation. However, the Seattle Foundation is not listed as one of WFC’s Top 5 Contributors, and even if it was listed as a Top 5 Contributor, it is not a political committee. None of the Top 5 Contributors to WFC are political committees, and as such, the requirement to list the Top 3 non-PAC donors to the Top 5 Contributors is not applicable. 

Based on these findings, staff has determined that, in this instance, the alleged failure to disclose the Top 3 Donors to a PAC’s Top 5 Contributors is not a violation that warrants further investigation. 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 No Evidence of Violations

Date Opened

October 30, 2019

Areas of Law

Areas of law not found

Documents

• 59437 Washington Fairness Coalition Complaint.pdf
• PDC Case 59437 Washington Fairness Coaltion closed no violation.pdf