38thLDDems (PAC): Alleged violation of RCW 42.17A.205 for failure to file a complete committee registration; RCW 42.17A.235, and .240 for failure to timely report a contribution; and RCW 42.17A.320 and WAC 390-18-010 for incomplete sponsor ID on a POLAD (EY25 APR25)

Case

#170043

Respondent

38th LD Democrats

Complainant

Conner Edwards

Description

The Public Disclosure Commission (PDC) completed its review of the complaint filed by Conner
Edwards on April 1, 2025. The complaint alleged violations of: (1) RCW 42.17A.205 for failure to
file a complete committee registration; (2) RCW 42.17A.320 and WAC 390-18-010 for incomplete
sponsor identification on a political advertisement (POLAD); and (3) RCW 42.17A.235 and .240 for
failure to timely report a contribution in election year 2025.

Applicable Laws and Rules

RCW 42.17A.205 requires every political committee to register with the PDC by filing a Committee
Registration (C-1pc report) within two weeks of organization or the date it first has the
expectation of receiving contributions of making expenditures in any election campaign, whichever
is earlier. Any material change to the information disclosed on the C-1pc report should be reported
to the PDC within 10 days of the change. The statement of organization shall include:
(b)The names, addresses, and electronic contact information of all related or affiliated committees
or other persons, and the nature of the relationship or affiliation;
(c) The names, addresses, and titles of its officers; or if it has no officers, the names,
addresses, and titles of its responsible leaders;
(d) The name, address, and electronic contact information of its treasurer and depository.

RCW 42.17A.320 requires that all political advertising supporting or opposing a candidate or ballot
proposition includes the sponsor's name and address. WAC 390-18-010 indicates that all advertising
must clearly state that it has been paid for by the sponsor.
Pursuant to RCW 42.17A.235 & RCW 42.17A.240, a committee that selects the Full Reporting option on
its Committee Registration (C-1pc) report is required to report contributions and expenditures to
the PDC on Cash Receipts Monetary Contributions reports (C-3 reports) and Campaign Summary Receipts
& Expenditures reports (C-4 reports). The due dates for these reports are based upon the election
cycle, the committee’s election participation, and its financial activity.

Background and Findings

• The Committee first registered an exempt account in May 2018 and continues to be a registered
Bonafide Committee under the Full Reporting option.
• Prior to April 1, 2025, the day the complaint was filed, the Committee’s PDC registration named
Shaina Langley, Chair; Charles Adkins, Treasurer; and Jacob Read, Ministerial Treasurer and
Compliance Consultant, as officers of the Committee. Following the complaint, and upon inquiry by
PDC staff, the Committee reviewed statutory requirements and determined that Josh Brunner should be
listed as the Vice Chair and updated the registration on April 30, 2025.
• The Committee has a website at https://www.38thlddemocrats.com/about. Prior to the complaint,
the website clearly showed the Committee’s name, Executive Board to include contact information for
the Chair, Vice Chairs, Treasurer, and Secretary, and the address and general contact information
for the Committee. The website did however not include the term “Paid for By” as required for
complete sponsor identification on political advertising. The website was updated on April 21,
2025, to include the required terminology to bring the site into compliance.
• Per the complaint, a contribution of $2,500, received on January 24, 2025, and deposited on
January 30, 2025, was reported 37 days late on March 18, 2025. The contribution should have
been reported by February 10, 2025.
• The Committee has no prior warnings or violations of similar PDC requirements.
Summary and Resolution

The Committee worked effectively and promptly with PDC staff to remedy the issues outlined in the
complaint. Officers explained the late reporting of the $2,500 contribution as the “result of a
lapse in our standard operating procedures. The errors that resulted in the lapse and delayed
report have been corrected and will not impact our future reports. We apologize for the late report
of this deposit.”

Based on our findings, staff has determined that, in this instance, any violation that may have
occurred was minor and has been cured. After consideration of the circumstances, further
proceedings would not serve the purposes of this chapter. 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 Committee’s failure to timely
file a C-3 report, include the Vice Chair on the C-1 report, and include the words “Paid for By” as
part of the sponsor identification on their website does not amount to a violation that warrants
further investigation.

Pursuant to WAC 390-37-060(1)(d), however, you are receiving a formal written warning concerning
failure to timely disclose a contribution, update the C-1 with Committee officer information, and
include complete sponsor identification on the Committee’s website. The formal written warning will
include staff’s expectation that you, in the future, follow all applicable requirements related to
reporting of contributions and expenditures and sponsor identification on a website. 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 has dismissed this matter in accordance with RCW 42.17A.755(1).

Disposition

Case Closed with Written Warning

Date Opened

April 08, 2025

Areas of Law

RCW 42.17A.205, RCW 42.17A.235, RCW 42.17A.240, RCW 42.17A.320, WAC 390-18-010