Anderl, Lisa: Alleged violation of RCW 42.17A.240(2) for failure to report complete address information for donors giving more than $100 in the aggregate & RCW 42.17A.405(14) for accepting over limit contributions (EY19; Jul 21)

Case

#96486

Respondent

Lisa Anderl

Complainant

Richard D. Erwin, Jr.

Description

The Public Disclosure Commission (PDC) has completed its review of the complaint filed on July 14, 2021. The complaint alleged that Lisa Anderl, a 2019 City Council candidate for the City of Mercer Island may have violated: (1) RCW 42.17A.240(2) for failure to timely disclose complete address information for individual donors giving more than $100 in the aggregate on Monetary Contribution reports (C-3 reports); and (2) RCW 42.17A.405(14) for accepting over limit contributions from a political action committee.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the responses provided by the Respondent; the applicable PDC reports filed by the Respondent; and queried the Respondent’s data in the PDC contribution and expenditure database, to determine whether the record supports a finding of one or more violations.

The Respondent was a first-time candidate in the 2019 election. It appears that the missing donor address information was due to a general misunderstanding of the detailed address disclosure requirements expected on C-3 reports and not done intentionally to mislead the public. The acceptance of the over limit contribution appears to be unintentional and due to a lack of awareness by the Respondent of the restrictions on individuals performing ministerial duties for only one campaign.

Pursuant to WAC 390-37-060(1)(f), the PDC received a completed Statement of Understanding (SOU) on February 10, 2022, from Lisa Anderl acknowledging a violation of RCW 42.17A.405(14) for accepting over limit contributions from Mercer Islanders for Sustainable Spending, a political action committee. Ms. Anderl paid a $150 civil penalty in accordance with WAC 390-37-143 (Brief Enforcement Penalty Schedule), which resolves the issue.

Based on our findings staff has determined that, in this instance, failure to timely file eight C-3 reports with complete house number and street addresses for ten individual donors, and failure initially to identify the committee treasurer as ministerial, does not amount to a finding of a violation that warrants further investigation. Pursuant to WAC 390-37-070, PDC staff is dismissing the remaining allegations and reminding Lisa Anderl about the importance of the accurate disclosure of all contribution and expenditure activities, specifically the inclusion of a full address for individual donors giving more than $100 in the aggregate, and the timely and accurate filings of all future PDC reports in accordance with the statutes and 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).

Disposition

Resolved through Statement of Understanding

Date Opened

July 29, 2021

Areas of Law

RCW 42.17A.240

Documents

Penalties

Total penalties: $150

Balance Due: $0

Anderl, Lisa

Penalty

$150 (SOU)

Payments

$150 on 01/31/2022 (PAID)