Common Purpose PAC: Alleged violations of RCW 42.17A.235 & .240 for failure to timely & accurately report contributions & expenditures. (EY '19; Oct '19)

Case

#59777

Respondent

Common Purpose PAC

Complainant

Glen Morgan

Description

A complaint was filed against the Common Purpose PAC, a single-year local political committee registered with the PDC to support 2019 candidates seeking office in the City of Sea-Tac, alleging that Common Purpose PAC may have violated RCW 42.17A.235 and .240 by failing to file Monetary Contributions reports (C-3 reports) and Summary Full Campaign Contributions and Expenditures reports (C-4 reports) disclosing contribution and expenditure details, including orders place for activities undertaken by the Committee.

The Response stated that Common Purpose PAC has been registered with the Federal Election Commission (FEC) as a “federal hybrid PAC …organized and operated out of Seattle, Washington,” and “unlike other federal PAC’s engaging in state or local election activity in Washington, the Committee does not qualify as an “out-of-state committee” 

Since Common Purpose PAC (Committee) registered as a committee within 21 days of the November 5, 2019 general election, the reporting requirements included filing a 7-Day Pre-General Election C-4 report due on October 28, 2019 covering the period October 14 through 28, 2019, and a Post-General Election C-4 report on December 10, 2019.  In addition, Common Purpose PAC was required to file weekly C-3 reports for the 2019 general election from October 23 through November 4, 2019. 

On October 28, 2019, the Committee timely filed the 7-Day Pre-General Election C-4 report disclosing no contribution or expenditure activities had been undertaken, including no orders placed.  On November 4, 2019, the Committee timely filed a C-3 report disclosing that a $3,811.51 contribution had been received from Common Purpose PAC on November 1, 2019 and deposited on the same day. 

On November 5, 2019, the Committee also timely filed a C-5 report disclosing that it is a federal PAC domiciled in Washington State submitting the first report in 2019, and that the PAC has “not been registered to work in any state election before now.”   The C-5 report disclosed that on November 1, 2019 the PAC made in-kind contributions to four candidates for Sea-Tac City Council of $952.97, totaling $3,811.51 for an expenditure made to Progressive Strategies NW and included Ali Egal, Takele Gobena, Damiana Merryweather, and Senayet Negusse. 

The candidates disclosed receiving a $952.88 in-kind contribution from the Committee on their 7-Day Pre-General Election C-4 reports filed on October 28, 2019 for a joint mailer that was mailed on October 29, 2019.   In addition , after receiving the complaint, the Committee filed an amended 7-Day Pre-General Election C-4 report on November 20, 2019, disclosing four orders were placed on October 24, 2019 with Progressive Strategies to print the mailer.

Staff’s review of the facts found that Common Purpose PAC: (1) was a federal committee registered with the FEC and domiciled in Washington State for all of calendar year 2019; (2) made contributions to local candidates in Washington state for the first time and late in the 2019 election cycle, and fully cooperated with PDC staff; (3) based on the Commissions rule, was a first-time committee that was required to register and report with PDC based solely on being domiciled in Washington State; (4) the federal committee file a voluntary C-5 report five days early; and (5) the candidates that received in-kind contributions for the mailer timely disclosed that activity on the C-4 reports.  

Based on these findings, staff has determined in this instance, the late filed reports do not warrant further investigation.  PDC staff has reminded Common Purpose PAC to timely and accurately register and report as an in-state committee, including filing C-3 and C-4 reports disclosing contribution, expenditure and orders placed, should it undertake activities involving candidates or ballot propositions in Washington State in the future as required for a political committee.  The PDC has dismissed the complaint in accordance with RCW 42.17A.755(1). 

Disposition

Case Closed with Reminder

Date Opened

November 06, 2019

Areas of Law

RCW 42.17A.235, RCW 42.17A.240

Documents

• 59777 Common Purpose PAC Complaint.pdf
• Common Purpose PAC response (Morgan) PDC Case 59777.pdf
• Common Purpose PAC Complaint Return with Reminder Cover Ltr (Morgan) PDC Case 59777.pdf