Smith, Norma: Alleged violation of RCW 42.17A.445 for transfer of campaign funds, not surplus funds, to the House Republican Organizational Committee (EY 16, Sep 17)




Norma Smith


Walter Smith


PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by Norma Smith; and the applicable PDC reports filed by Respondent, to determine whether the record supports a finding of one or more violations.

Staff found:

  • Rep. Smith did not use campaign funds to make a $30,000  “contribution” to the House Republican Organizational Committee, as alleged.  Rather, she made a “Transfer of Surplus Funds” from her campaign account on August 8, 2016.
  • On September 12, 2016, Rep. Smith filed a C-4 report covering the period July 26, 2016 to August 31, 2016.  The report included a monetary expenditure on August 8, 2016 for $30,000 to House Republican Organizational Committee, with a description of “Contribution.”
  • On September 28, 2017, Rep. Smith amended the September 12, 2016 C-4 for the same period, showing a $30,000 expenditure to House Republican Organizational Committee, with a description of “Surplus Funds Transfer.”
  • Rep. Smith was not required to transfer the surplus funds to a separate surplus funds account before making the transfer.  She should have described the expenditure as a “Surplus Funds Transfer” on the original C-4 report.  This clarification was made on the amended report.

Staff determined that in this instance, the alleged personal use of campaign funds does not amount to a violation warranting further investigation.  PDC staff reminded Norma Smith about the importance of properly describing expenditures that are transfers of surplus funds to avoid confusion about the nature of the expenditure. 

PDC found that no further action is warranted and dismissed this matter in accordance with RCW 42.17A.755(1).


Case Closed with No Evidence of Violations

Date Opened

September 05, 2017

Areas of Law

RCW 42.17A.445

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