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ELECTRICAL WORKERS 46 PAC: Alleged violation of RCW42.17A.235&.240 failing to timely & accurately rpt contrib.&expends, maint rcds not less than 5 yrs; RCW42.17A.220(4) acpt over-lmt anon contribs; WAC390-16-034 failing to rpt empr info(EY2019-24, APR24)
ELECTRICAL WORKERS 46 PAC: Alleged violation of RCW42.17A.235&.240 failing to timely & accurately rpt contrib.&expends, maint rcds not less than 5 yrs; RCW42.17A.220(4) acpt over-lmt anon contribs; WAC390-16-034 failing to rpt empr info(EY2019-24, APR24)
Case
#153421
Respondent
Electrical Workers 46 PAC
Complainant
Glen Morgan and Conner Edwards
Description
PDC staff reviewed the allegations and evidence submitted; the applicable statutes, rules, and reporting requirements; the response(s) provided by the Electrical Workers 46 PAC (the “Respondent”); the applicable PDC reports filed by the Respondent; the Respondent’s data in the PDC contribution and expenditure database; and other relevant information, to determine whether the record supports a finding of one or more violations.
Since 2017, the Respondent has operated as a continuing committee registered with the PDC under the Full Reporting option. The Respondent accepted contributions from members, but did not participate in elections between 2018 through 2022 due to reduced staff capacity and COVID. Up until 2017, as well as during 2023, the Respondent accepted contributions from members and took part in elections by making expenditures in the form of contributions to candidates and political action committees.
It appears the Respondent is unsophisticated and small. The PAC is entirely funded by individual members and is managed by a small group of individuals. Inexperience and good-faith errors in reporting activity were the cause of the noncompliance. The Respondent states that “it acknowledges its past errors and now understand and recognizes its responsibilities under the FCPA [Fair Campaign Practices Act].”
Electrical Workers 46 PAC completed a Statement of Understanding (SOU) and paid a $450 civil penalty in accordance with WAC 390-37-143 (Brief Enforcement Penalty Schedule), acknowledging a first occasion of late filed C-3 and C-4 reports for the period of 2019, 2020, 2021, and 2022; and for a second occasion of late filed C-4 reports identifying expenditures made by the PAC as a contributions to campaigns in 2023 that went unreported until 2024. The $450 penalty assessed resolves the corresponding allegations in the complaints.
As well, pursuant to WAC 390-37-060(1)(d), the Electrical Workers 46 PAC will receive a formal written warning concerning their failure to comply with RCW 42.17A.235(8) for maintaining books of account, bills, receipts and all other financial records of the political committee for not less than five calendar years; and RCW 42.17A.220(4) for accepting over-limit anonymous contributions in 2020. The Commission will consider this formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.
Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).
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