Case #59773
Respondent name: Yes for Homes Coalition of San Juan County
Complainant name: Glen Morgan

The PDC received a complaint alleging that Yes for Homes Coalition of San Juan County (the “Respondent”) may have violated RCW 42.17A.240 and WAC 390-16-037 by failing to provide sufficient expenditure details on C-4 reports during election year 2018. 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:

RCW 42.17A.240(6) requires committees to report the name & address of each person to whom an expenditure is made in the aggregate amount of more than $50 during the period covered by the report, including the amount, date and purpose of each expenditure. Pursuant to WAC 390-16-037, expenditures disclosed on the 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). WAC 390-16-205 further requires each committee to report any expenditures, paid to a sub-vendor or other third party, by a vendor it employs or retains. 

The Respondent filed five C-4 reports in 2018 that appeared to lack sub-vendor breakdowns and/or expenditure details regarding signs, digital ads, printing, mailer, and advertising. The Respondent amended five C-4 reports from 2018 to include the missing information on December 11 and 13, 2019.

Based on these findings, staff determined that, in this instance, the Respondent’s failure to report sub-vendor breakdowns and complete expenditure descriptions on C-4 reports does not amount to a violation that warrants further investigation. However, the PDC reminded the Respondent about the importance of providing sub-vendor breakdowns and detailed expenditure descriptions on C-4 reports. 

The Respondent made minor or ministerial errors on required reports, which did not materially impact the public interest. Upon being notified of the errors, the Respondent amended its reports, making the necessary technical corrections as requested by staff. The PDC has dismissed this matter in accordance with RCW 42.17A.755(1). 

Disposition: Case Closed with Reminder (Resolved 12/23/2019)
Date opened: 11/06/2019
Area of Law: RCW 42.17A.240, WAC 390-16-037