Commission meeting highlights: September 2026
Commission issues fines for late, missing personal financial affairs statements
The Public Disclosure Commission began its Sept. 24 regular meeting with several enforcement cases related to missing or late personal financial affairs statements, or F-1 reports.
F-1 reports are required for most candidates and sitting officials and are intended to reveal potential conflicts of interest. The reports are due for candidates within two weeks of beginning a campaign, and for sitting officials annually in April.
PDC staff open cases every year for missing reports, and those cases where the respondents have prior violations may be heard before the full Commission.
Okanogan-Douglas Hospital District 1 Commissioner Tracy Shrable was fined $3,000 for failing to file their 2025 F-1, due in April 2026. Shrable has one prior violation for the same area of law.
The Commission suspended half of the fine on the condition that Shrable file the missing reports and pay the unsuspended portion of the fine within 30 days.
Robert Weber, a Grant County Fire Protection District 10 Commissioner, was fined $500 for a late 2025 F-1 report. Weber has one prior violation for the same area of law. He appeared at the hearing on Sept. 24, and told the Commission that he had initially had trouble with the PDC’s online filing system, but had filed both missing reports.
The Commission suspended half the fine on the condition that the unsuspended portion of the fine is paid within 30 days and that Weber have no further violations for the next four years.
In the final case heard Thursday, former Whatcom Community College Trustee John Pedlow was represented by his wife, who reported that her husband had a major stroke in 2023, and that she missed reminders sent to his email about filing the 2025 F-1. Pedlow is no longer serving as a trustee of the college.
The Commission issued a fine of $250, with all suspended on the condition that the report is filed.
Three additional cases were scheduled to be heard, but were continued to the Commission’s October regular meeting. These respondents did not receive notice of the hearing at least 10 days prior, as is required.
PDC staff brief commission on questions related to last-minute contribution limits
PDC Deputy Director Kim Bradford and General Counsel Sean Flynn briefed the commission on two issues related to limits on pre-election campaign contributions at the Sept. 24 meeting.
The first stemmed from a case that came before the Commission in June, in which a state Court of Appeals candidate allegedly violated RCW 29B.40.070, which creates pre-election contribution limits of $75,000 for statewide candidates and $7,500 for local candidates within 21 days of the general election.
The Commission directed staff to dismiss that case without prejudice, citing the question of whether the Court of Appeals is eligible for the higher or the lower limit as well as constitutional issues that had been raised the respondent.
Flynn explained PDC staff’s position that Court of Appeals candidates are eligible for the lower rate because the position is not elected statewide, but in a district with a limited area. Commissioners expressed support for that interpretation.
Flynn then discussed a related topic, regarding questions about the constitutionality of those pre-election limits. Flynn said that it is not PDC staff’s role to make a constitutional analysis. Nor does the Commission does have authority to consider whether a law before them is constitutional.
Flynn said the law may be difficult to enforce given this question, and the PDC could be subject to litigation if it attempts to enforce the law at this point. He said staff needs some direction on how to deal with cases involving this law when it comes up.
Potential approaches could include taking no action and dealing with individual cases as they come up, issuing a Commission interpretation on the law, or asking the Legislature to repeal the law.
Leach said he was opposed to the “do nothing” approach.
“I think having unwritten rules in campaign law is a very bad idea because one candidate may know, ‘Oh they’re not going to enforce that.’ … The other person may not be as well informed … and doesn’t spend the money because they took the time to read the statutes and the regulations … and they think that’s the difference in the race they lost by six votes,” Leach said. “Whatever our position is it should be discoverable by people who are running for office.”
The commissioners discussed their options, with several members supporting a formal Commission interpretation and policy statement. Segal suggested the Commission also research the possibility of asking the courts for a declaratory judgment.
The Commission did not vote on either issue. Leach suggested the Commission continue to consider the issue and revisit the conversation at its October meeting with additional input from staff.
Agency continues preparation for 2027 legislative session
The PDC plans to ask the Legislature to again consider legislation to amend pre-election reporting timelines during its 2027 session.
Staff asked the Commission to decide on the direction of the requested legislation at their October regular meeting. The agency has presented a version of the proposal to the Legislature for the past four years to make pre-election reporting both more transparent for voters and more streamlined for filers.
Flynn gave the Commission a description of the past efforts, noting that some history might be helpful since three of the five commissioners have joined in the past few months.
Currently full-reporting candidates and committees are required to file expenditure reports 21 and 7 days before elections. This worked well when people voted in person on Election Day, but is less effective when people receive ballots weeks before the election and are encouraged to vote early. It also results in a “dark period” of six weeks in September and early October during which campaigns don’t report expenditures.
The most recent PDC proposal would set static calendar dates – expenditure reports would be due on the 10th and 25th of pre-election months. However, Bradford noted that there would be more days between the last report and the election under this method.
The Commission plans to discuss this again in October.
PDC to launch text-message reminders
PDC Chief Information Officer James Gutholm announced at the Sept. 24 Commission meeting that the PDC plans to launch a new text-message reminder system on Sept. 30.
Filers may choose to receive reminders for reporting deadlines relevant primary and general elections, April and February special elections, or for monthly expenditure reporting dates (C-4 reports.)
This is the first time the PDC has offered reminders by text message. All filers already receive regular reminders to the email account they provided to the PDC with their campaign registrations. Improving compliance with mandatory expenditure reporting deadlines is one of the Commission’s strategic goals.
The PDC will publish more information about how to sign up when the program goes live.
Enforcement update
During the month of August, the PDC received 51 new complaints, closed 37 cases and had 175 cases open as of August 31.
Of those open cases, 66 were under initial review and 105 undergoing a formal investigation. An additional four cases were either scheduled to come before the commission for a hearing or discussion or pending deferred enforcement
Of the 37 closed cases, two were dismissed with no evidence, nine were resolved with reminders, eight with technical corrections, nine with warnings, five with statements of understanding, one under the complaint publication process, two with brief enforcement hearings and one with a full commission hearing.
On Wednesday, Sept. 23, staff dismissed with a reminder a case regarding an allegation of lack of reporting for political advertisements by the Washingtonians for Ethical Government against Let’s Go Washington.
Staff found no evidence of payments by the committee to political commentator Brandi Kruse and determined that although Kruse had been paid previously by other political committees for speaking engagements, that didn’t mean that all of her speech could be classified as an in-kind contribution to the campaign.
“However, this is a close case and PDC staff is reminding LGW about the importance of ensuring that any professional services provided to LGW and either paid directly by LGW or paid or donated by another person (including the individual providing the services) to benefit LGW are reported as an expenditure or an in-kind contribution,” the reminder from PDC staff states.