Dung Thi Tuyet Ho (Janet Ho): Alleged violation of RCW 42.17A.235, .240, and .320 for failure to timely and accurately report contributions and expenditures and provide complete sponsor identification on campaign advertising.(EY25 MAY25)

Case

#173512

Respondent

Dung Thi Tuyet Ho (Jane Ho)

Complainant

Conner Edwards

Description

The Public Disclosure Commission (PDC) completed its review of a complaint filed with the PDC.

Applicable Laws and Rules
Per RCW 42.17A.235 and .240, a candidate that selects the Full Reporting option on their registration 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) pursuant to RCW 42.17A.235 & RCW 42.17A.240. The due dates for these reports are based upon the election cycle, the candidate's election participation, and their financial activity.

Pursuant to RCW 42.17A.240(7), expenditures are disclosed on C-4 reports, which must include, but are not limited to: 1) the name and address of each person to whom an expenditure was made in the aggregate of more than $750 during the period covered by the report; 2) the amount, date, and purpose of each expenditure; and 3) the total sum of all expenditures. Purpose details should state the goods or services provided by the vendor, including the number of items purchased, identify any candidates or ballot propositions supported or opposed by the expenditure, and the name & address of any sub-vendors used. For advertising expenditures, campaigns should describe the type and number of ads, where they appeared or were broadcast, and when (e.g. run dates). An in-kind contribution is disclosed like an expenditure on the PDC’s Online Reporting of Campaign Activity (ORCA) software.

RCW 42.17A.320 requires that all political advertising supporting or opposing a candidate or ballot proposition includes the sponsor's name and address.

Background and Findings

Janet Ho's candidacy is for City Of Tukwila Council Member, Position 7.  She filed a PDC Candidate Registration on November 20, 2024. for the Full Reporting option.
 

  • As alleged, the April C3, due May 12, 2025, was filed on May 20, 2025, 8 days late.  There was a corresponding C4 report also due by May 12, 2025, that was not filed until June 9, 2025.  The C3 reported a $1000 loan from the candidate and were the only funds received in April.  The C4 showed no expenditures and only reported the loan as funds received.
  • Also, the website was missing complete sponsor identification at the time of the complaint.  Upon being notified about the requirements, the Respondent promptly updated the website which now includes complete sponsor ID.
  • Ms. Ho is a first time candidate and has not similar Warnings or Violations.

    Summary and Resolution
    Having reviewed the complaint and the supporting evidence, PDC staff has determined that Ms. Ho appears to have violated RCW 42.17A. After consideration of all the circumstances, further proceedings would not serve the purposes of the Fair Campaign Practices Act. Under WAC 390-37-070, 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. 

    Based on this, the PDC has dismissed this matter in accordance with RCW 42.17A.755(1) and WAC 390-37-060(1)(d). PDC staff has reminded Ms. Ho about the importance of timely reporting contributions and expenditures and to ensure complete sponsor identification is included on all political advertising. She is expected to comply with PDC statutes and rules in the future.
     

Disposition

Case Closed with Reminder

Date Opened

June 02, 2025

Areas of Law

RCW 42.17A.235, RCW 42.17A.240, RCW 42.17A.320

Documents

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