People for Moon PAC: Alleged Violation of RCW 42.17A.240 for failure to accurately describe expenditure. (EY '17, Jul '19)

Case

#55460

Respondent

People for Moon PAC

Complainant

Glen Morgan

Description

The PDC received a complaint alleging that People for Moon PAC (the "Respondent") may have violated RCW 42.17A.240 and WAC 390-16-037 by failing to accurately describe an expenditure on a C-4 report filed with the PDC. PDC staff reviewed the allegations; the applicable statutes, rules and reporting requirements; the response provided by the Respondent; and the Respondent’s reporting history to determine whether they support a finding of one or more violations.

Staff’s review found the following:

On a C-4 report it filed with the PDC on October 31, 2017, the Respondent described an expenditure as "political-digital advertising." Pursuant to WAC 390-16-037, expenditures disclosed on a C-4 report should be described “in detail,” including how the recipient of the expenditure (e.g. vendor) will use the goods and/or services purchased, and numerical descriptions (e.g. the number of items printed).

In it's response to the complaint, the Respondent indicated its belief that the original C-4 report met reporting requirements but nonetheless amended its C-4 report on August 20, 2019 to include additional expenditure details in the interest of transparency.

The Respondent made a minor or ministerial error on its report, which did not materially impact the public interest. Upon notification of the error, the Respondent timely amended its report, making the necessary technical correction.

PDC staff reminded the Respondent of the importance of fully and accurately describing expenditures on C-4 reports, found that no further action was warranted, and dismissed the case in accordance with RCW 42.17A.755(1).

Disposition

Case Closed with Reminder

Date Opened

July 31, 2019

Areas of Law

RCW 42.17A.240, WAC 390-16-037