The complaint alleged Washington Fairness Coalition, a 2019 Ballot Proposition Committee supporting Referendum 88, may have violated RCW 42.17A.320 by failing to provide sponsor identification in political advertising.
It appears the omission of sponsor identification, including the top five contributors was unintentional and not purposely omitted to mislead the public. The identity of the top five contributors was available to the public on the committee’s Monetary Contribution (C-3) reports submitted prior to the advertisements being presented to the public. In addition, the committee has included appropriate expenditure details on Receipts and Expenditures Summary (C-4) reports. Although Washington Fairness Coalition has no previous violations of RCW 42.17A, the committee employs a professional treasurer and is aware of the sponsor identification requirements for political advertisement it sponsors.
Based on our findings staff has determined that, in this instance, failure to include the top five contributors on these advertisements does not amount to a finding of a violation that warrants further investigation. Pursuant to WAC 390-37-060(1)(d), however, Washington Fairness Coalition will receive a formal written warning concerning failure to include complete sponsor identification, specifically the top five contributors required by statute, on political advertisements it sponsored. The formal written warning will include staff’s expectation that the committee includes complete sponsor identification on all political advertisement it sponsors in the future. 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).