Cowlitz County Democratic Central Committee: Alleged violation of RCW 42.17A.235 & .240 for failure to timely file C-3 and C-4 reports. (EY25 APR25)

Case

#170044

Respondent

Cowlitz County Democratic Central Committee

Complainant

Conner Edwards

Description

The Public Disclosure Commission (PDC) completed its review of the complaints filed by Conner 
Edwards on April 1, 2025, and April 25, 2025. The complaints alleged violations of RCW 42.17A.235 
and .240 for failure to timely file Cash Receipts, Monetary Contributions (C-3) and Receipts & 
Expenditure Summary (C-4) reports.
 

Applicable Laws and Rules

A committee that selects the Full Reporting option on their C-1pc report is required to report 
contributions and expenditures to the PDC on Cash Receipts Monetary Contributions reports (C-3) and 
Campaign Summary Receipts & Expenditures (C-4) reports pursuant to RCW 42.17A.235 & RCW 42.17A.240. 
The due dates for these reports are based upon the election cycle, the committee’s election 
participation, and their financial activity.

Background and Findings
•  The CCDCC is a Bona Fide Political Party Committee for Cowlitz County. The most recent Political 
Committee Registration (C-1pc) filed on April 16, 2025, for the Non-Exempt Fund account, identified 
the CCDCC as a Continuing Committee under the Full Reporting option.
•  The Committee timely filed C-4 report #110181056, for period September 1, 2023 – October 16, 
2023, on October 17, 2023, and then submitted amended report #110277165, adding an expenditure for 
postage, on March 29, 2025. Upon being notified about the complaint, the Committee again amended 
their reporting, with C-4 report #110280927, on April 18, 2025, to remove the expenditure for 
postage. The postage was previously, and timely, reported in the exempt account and erroneously 
reported in the non-exempt account. The Treasurer explained the issue:
“This mistake is mine. During my internal audit I noticed that this expense for postage was 
‘missing’ from the PDC. After consulting with my executive board, I realize that this contribution 
occurred through our exempt account and was already reported to the PDC. See the following link. https://www.pdc.wa.gov/political-disclosure-reporting- 
data/browse-search-data/committees/co-2023-34908. My plan is to readjust the 2023 campaign for the 
CCDCC, remove this transaction, as it was already reported from the exempt account.”
•  Similarly, for C-3 report #110277164, submitted on March 29, 2025, a contribution was 
erroneously reported from the WA Dems to the non-exempt account when it had been previously 
reported by that account. On April 16, 2025, the Committee amended the report, see C-3 #110280738, 
fixing the reporting in the non-exempt account by removing the contribution.
•  C-3 report #110277172, for a deposit of $100 on October 18, 2023, was not filed until March 29, 
2025. The new committee Treasurer stated the reporting of this contribution was missed by the 
original treasurer and caught by the new treasurer during an audit. The late reporting was the 
result of their internal audit. PDC staff noted the report showed a $100 Small Contribution by one 
person. The Treasurer amended the C-3 again on April 19, 2025, to reflect the individual 
contributor’s name and address.
•  Issues associated with C-4 reports covering January and February 2024 were addressed in PDC Case 
162592. The resolution in that case included a dismissal of reporting issues during calendar year 
2024.
•  PDC Staff found that in three instances of its C-1pc filing, the Committee spelled “democratic” 
as “democractic” in the filing name of the committee. This does make searching for the Committee 
more difficult but is not a violation.
•  The Respondent does have previous warnings of similar PDC requirements.

Summary and Resolution
Under WAC 390-37- 060, the executive director, at any time prior to consideration by the 
commission, may dismiss a complaint which on its face, or as shown by investigation, provides 
reason to believe that a violation has occurred, but also shows that the respondent is in 
substantial compliance with the relevant statutes or rules, or shows that formal enforcement action 
is not warranted. The lack of detail in reporting of which levies were being supported and the 
errors in reporting caused by the Committee’s internal audit do not amount to violations that 
warrant further investigation.

The violations of PDC laws and rules made by you are remediable in nature and do not warrant 
further investigation or enforcement action. The late reported expenditure(s) or contribution(s) 
involved totaled no more than $1,500, and the violations were inadvertent, minor, and otherwise 
have been cured. They did not materially harm the public interest beyond the harm to the policy of 
Chapter 42.17A RCW inherent in any violation.
In addition, you took corrective action within five business days after being notified of 
noncompliance by PDC staff and substantially met filing deadlines for all other required reports 
within the preceding 12 months.

Any allegations regarding reporting by the Committee for the 2023 calendar year that are not 
otherwise addressed are hereby dismissed. Allegations regarding reporting by the Committee for the 
2024 calendar year were addressed in PDC Case 162592. The resolution in that case included a 
dismissal of reporting issues during calendar year 2024.

Based on this information, the PDC has dismissed this matter in accordance with RCW 42.17A.755(1).
 

Disposition

Case Closed with No Evidence of Violations

Date Opened

April 08, 2025

Areas of Law

RCW 42.17A.235, RCW 42.17A.240

Documents

• 170044 Cowlitz County Democratic Central Committee Complaint.pdf
• 170044 COWLITZ COUNTY DEMOCRATIC CENTRAL COMMITTEE Response.pdf
• 170044 Cowlitz County Democratic Central Committee (2).pdf
• 170044 Cowlitz County DCC Response to Supplemental Complaint.pdf
• 170044 CCDC Case Closure Letter.pdf