SEIU 775 Ballot Fund: Alleged violation of RCW 42.17A.235 and .240 for failure to timely file expenditures reports. (EY25 FEB25)

Case

#166613

Respondent

SEIU 775 Ballot Fund

Complainant

Conner Edwards

Description

The complaint alleged violations of RCW 42.17A.235 and .240 for failing to timely file expenditures reports prior to the February 11, 2025, special election.

  • The complaint alleged that SEIU 775 Ballot Fund, a continuing political committee, contributed to a political committee participating in the February 11, 2025, special election, and was required to file the 21-day and 7-day pre-election C-4 reports for that election. 
  • Raise The Wage Burien, a committee supporting Initiative Measure No. 1 in the City of Burien in the February 11, 2025, special election, reported receiving a $2,500 contribution from SEIU 775 Ballot Fund on January 27, 2025, on a Cash Receipts Monetary Contributions report (C-3 report) filed on January 27, 2025. 
  • By contributing to Raise The Wage Burien within 60 days of the February 11, 2025, special election, SEIU 775 Ballot Fund was obligated to file a 7-day pre-election Campaign Summary Receipts & Expenditures report (C-4 report) on February 4, 2025, disclosing activities through February 3, 2025. 
  • On February 7, 2025, SEIU 775 Ballot Fund filed a monthly C-4 report covering activities from January 1-31, 2025, and disclosing the $2,500 expenditure to Raise The Wage Burien. 

It appears that the failure to file a 7-day C-4 report was the result of a lack of understanding of the requirements regarding expedited reporting deadlines prior to special elections, and SEIU 775 Ballot Fund did not intentionally withhold information prior to the February 11, 2025, special election, as demonstrated by filing the monthly C-4 report just three days after the 7-day C-4 report was due.

Based on our findings, staff has determined that, in this instance, failure to timely file a 7-day C-4 report does not amount to a violation that warrants further investigation.

Pursuant to WAC 390-37-060(1)(d), however, SEIU 775 Ballot Fund is receiving a formal written warning concerning the failure to timely disclose expenditures prior to elections. Staff expect that SEIU 775 Ballot Fund update its reporting schedule to include expedited reporting prior to the elections in which it is participating and to submit C-4 expenditure reports by the expedited deadlines in RCW 42.17A.235. The Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.

The PDC has dismissed this matter in accordance with RCW 42.17A.755(1).

 

Disposition

Case Closed with Written Warning

Date Opened

February 07, 2025

Areas of Law

RCW 42.17A.225, RCW 42.17A.235, RCW 42.17A.240

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